RQA – MIFIDPRU 8 Disclosure
1. MIFIDPRU 8 DISCLOSURE
Robert Quinn Advisory LLP (“the Firm”), part of the RQC group, is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm acts as a principal firm for Appointed Representatives (“ARs”) that are (i) seeking to conduct the regulated activities of advising on investments, arranging (bringing about) deals in investments, and making arrangements with a view to transactions in investments and/or (ii) marketing financial products and services. The Firm does not undertake any investment business in its own name, all client agreements are entered into by the AR entities in their own names.
The Firm is categorised as a ‘SNI MIFIDPRU Investment Firm’ by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s MIFIDPRU 8 disclosure fulfils the Firm’s obligation to disclose to market participants’ key information on a firm’s remuneration policies and practices.
In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities.
This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model.
2. REMUNERATION POLICIES AND PRACTICES
The Firm is subject to the Remuneration Code (the “Code”) for MIFIDPRU Firms as codified in Section 19G of the SYSC sourcebook of the FCA handbook.
This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.
A. Qualitative Information
The Firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote effective risk management and do not encourage excessive risk taking.
The Firm ensures that the remuneration policy and its practical application are consistent with the Firm’s business strategy, objectives and long-term interests.
Given the nature and small size of our business, remuneration for all employees is set by the Firm’s senior managers and the executives of the Firm’s managing members.
Staff receive a salary which reflects their market value, responsibilities and experience.
Staff may also receive variable remuneration, such as an annual bonus, where the individual operates within the risk appetite of the company and has demonstrated appropriate behaviour.
Variable remuneration is intended to reflect contribution to the Firm’s overall success. Staff are assessed throughout the year and rated based on company and individual performance. The performance assessment considers both financial measures – such as earnings and profit margin – and non-financial measures – such as productivity/efficiency and quality, risk management, people and culture, customer focus, growth, and innovation.
The Firm’s linkage between variable remuneration and performance is based upon the following tenets:
1. Ensuring an appropriate balance of financial results between staff and shareholders
2. Attraction and retention of staff members
3. Aligning the interest of senior staff members via long-term incentive awards
4. Link a proportion of a staff member’s total compensation to the Firm’s performance
5. Discourage excessive risk-taking
6. Ensure client interests are not negatively impacted
B. Quantitative Information
The Firm may omit required quantitative disclosures in relation to remuneration where it believes that the information could be regarded as prejudicial to its adherence to the UK General Data Protection Regulations (which was adopted from the EU equivalent Regulation on 1 January 2021) and the Data Protection Act 2018 on the protection on natural persons with regard to the processing of personal data and on the free movement of such data.
Due to the size of the Firm and limited number of staff, quantitative disclosures in relation to remuneration have not been included.
