REGULATORY DISCLOSURES
1. MIFIDPRU 8 DISCLOSURE
REMUNERATION DISCLOSURE
The Investment Firms Prudential Regime (IFPR) is the FCA’s new prudential regime for MiFID investment firms which aims to streamline and simplify the prudential requirements for UK investment firms. IFPR came into effect on 1st January 2022, and its provisions apply to LeCap Asset Management Ltd (the ‘Firm’) as an FCA authorised and regulated firm.
The public disclosure requirements of IFPR are set out in MIFIDPRU 8, replacing the previous Pillar 3 requirements under BIPRU 11.
At the Firm, our remuneration policy is designed to promote sound risk management and align the interests of our staff with the long-term objectives of the firm. As a Small and Non-Interconnected (SNI) firm, we adopt a simple and transparent approach to remuneration. This disclosure is made in accordance with the Firm’s size, internal organisation and the nature, scope and complexity of its activities.
The employees are paid a base salary, and a discretionary bonus based on their individual performance and market compensation for their role. The discretionary bonuses are based on the individual performance and the overall financial performance of the firm.
Key Principles of Our Remuneration Policy:
• are consistent with and promotes sound and effective risk management;
• do not encourage excessive risk taking;
• takes into account the long-term performance of the Group;
• include measures to avoid conflicts of interest;
• are gender neutral; and
• are in line with the Firm's business strategy, objectives, values and long-term interests.
This policy ensures that our remuneration structure is aligned with both regulatory standards and the prudent management of our firm. The level of variable remuneration granted, also referred to as a discretionary variable incentive award (or bonus), is entirely discretionary.
2. UK STEWARDSHIP CODE
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, the Firm is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code applies on a ‘comply or explain’ basis and is voluntary. The Code sets out a number of principles relating to engagement by asset managers or asset owners across all asset classes including listed equities and investments outside the UK.
Whilst supporting the objectives underlying the Code and adhering to the highest standards or corporate governance and due diligence in respect of its investments the Firm, believes that the Principals are not applicable to its investment activities at this time. Should that change in the future, the Firm will review its commitment to the Code and update this disclosure accordingly.
3. SHAREHOLDERS RIGHTS DIRECTIVE II
On 10 June 2019 the requirements of the Shareholder Rights Directive II (“SRD II”) came into force. These rules continue along a similar path as the UK Financial Reporting Council’s Stewardship Code ( the “Code”) which was updated by the Financial Reporting Council in 2020, in promoting common stewardship objectives between institutional investors and asset managers.
Given the similarity with the UK Stewardship Code, which is at present not deemed relevant to the type of activity undertaken by the Firm, it has been decided not to comply with SRD II at this current time. However, this position is subject to annual review, in conjunction with the Code, and any change to the current investment strategy of the Firm will be taken into account. The Firm does not deem it appropriate to publish an engagement policy and related annual disclosure under FCA COBS 2.2B.
4. PRIVACY POLICY
The Privacy Policy can be provided upon request.
