Governance

Shareholder Rights Directive

Under the Shareholder Rights, Directive investment firms are required to explain how they engage with the companies that they invest in through an engagement policy or explain why an engagement policy has not been produced.

PIER Financial Investments has chosen not to produce an engagement policy because we primarily deal with retail clients and mainly invest in assets other than shares for those clients. We believe that an engagement policy is more appropriate to those firms who provide discretionary services in relation to shares for large institutional clients such as pension or investment funds.

Approved by the Board 5th November 2019.

MIFIDPRU annual disclosure for
PIER Financial Investments Limited
Remuneration Code

Date approved by the Governing Body: 11th July 2023
Next review date: June 2024

Objectives

This document sets out the policy of PIER Financial Investments Ltd (‘PIER’, the ‘Firm’ and ‘the Company’) in relation to the remuneration packages and incentive schemes offered by PIER which is categorised as a small and non-interconnected (SNI) firm under the Investment Firms Prudential Regime (IFPR).

The IFPR came into effect on the 1 January 2022 as a new regime for UK firms authorised under the Markets in Financial Instruments Directive (MiFID). It was implemented by the FCA as prudential regulation within the MIFIDPRU section of the FCA Handbook.

The MIFIDPRU Remuneration Code applies to all FCA investment firms within the scope of the Investment Firms Prudential Regime. It is based on the provisions of the Investment Firms Directive (IFD) and mirrors the structure of the previous BIPRU and IFPRU codes.

The Code is designed to achieve a proportionate remuneration regime for investment firms which furthers the objectives of ensuring alignment between risk and individual reward, discouraging excessive risk-taking, and promoting effective risk management.

Our remuneration policy is designed to:

  • be proportionate based on the size of our Firm and the scope of our regulated activities;
  • promote sound and effective risk management;
  • be proportionate based on the size of our Firm and the scope of our regulated activities;
  • promote sound and effective risk management;
  • ensure responsible business conduct;
  • ensure conflicts of interest are avoided;
  • reflect the culture of our firm and our ability to deliver good client outcomes to our clients and
  • deliver the regulated activities detailed below to both retail and professional clients.

PIER’s activities

PIER provides discretionary investment management services by means of risk-rated portfolios and its  distribution channel is through regulated financial advisory firms. The ultimate clients are individuals of these firms who satisfy the product governance criteria for the PIER model portfolios. PIER manages its investment business through firstly the mechanism of the PIER Investment Committee (‘IC’) and secondly by having contractual arrangements not only with external investment advisers (Stanhope and LGT) to provide investment advice (in the case of LGT also operational support), but also with various platforms to provide the relevant management services. PIER’s Risk Appetite Statement articulates the different types of risk faced by the Company and the PIER Risk Register reviews on-going risks and monitors the mitigating actions and plans developed by the Company. The Risk Register is reviewed quarterly by the Governance and Risk Committee.

Scope of policy

This policy applies to all staff within PIER.

Reviewing this policy

To ensure this policy continues to accurately reflect the process we follow, the Governance and Risk Committee will review this policy on an annual basis. The policy will be signed off by the Governing Body on an annual basis.

Remuneration Code Disclosure

The Firm’s Remuneration Code disclosures are published on its website. There are no significant changes in these Remuneration Code disclosures as compared to those for last year.

Definition of remuneration

For the purpose of this policy, ‘remuneration’ means any form of remuneration, including salaries, discretionary pension contributions and benefits of any kind.

Purpose

The policy aims to support PIER’s strategic objectives by attracting, motivating, and retaining talented staff whilst at the same time fulfilling its regulatory and legal requirements.

PIER’s objective is to develop and maintain remuneration practices which are structured to reward long-term performance and sound risk management in a way which is consistent with PIER’s culture and strategy. PIER regards its staff as key to delivering PIER’s positive culture and values to customers.

In this way the long-term interests of all stakeholders including customers and employees are aligned and the long-term success of PIER is supported.

Oversight & Governance

In view of proportionality the Firm does not operate a Remuneration Committee. Our remuneration policy and structure are reviewed on an annual basis by the Governing Body in conjunction with the compliance and risk functions.  Our performance period is one year and currently runs for the period April to March. The members of the Governing Body are responsible for remuneration policy including:
  • determining the framework and policy for remuneration and ensuring it does not encourage undue risk-taking and addresses any potential conflicts of interest;
  • agreeing any major changes in remuneration structures;
  • reviewing the terms and conditions of any new incentive schemes and in particular considering the appropriate targets for any performance-related remuneration schemes;
  • considering and recommending the remuneration policy for the senior employees taking into account the appropriate mix of salary, discretionary bonus and share-based remuneration;
  • ensuring that the Compliance Function does an annual review of remuneration policy and also reviews any new incentive schemes before implementation;
  • giving due regard to best practice and any relevant legal or regulatory requirements including the MIFIDPRU Remuneration Code and Consumer Duty; and
  • reviewing the policy at least annually to take into account any external or internal changes.

Qualitative Disclosures

PIER’s remuneration policies and procedures

Any remuneration package or incentive scheme we have in place, or may introduce in the future, will not:

  • remunerate or assess performance of our staff in any way that conflicts with our duty to act in the best interests of or impact our ability to deliver good outcomes for our clients;
  • create a conflict of interest that would encourage individuals to act against the interests of any of our clients;
  • be solely or predominately based on quantitative commercial/sales/revenue generating criteria;

but will:

  • ensure the fair treatment of our clients and the quality of service provided;
  • take appropriate qualitative criteria into account;
  • maintain an appropriate balance between fixed and variable remuneration so the structure does not favour PIER or staff interests over those of our clients.

PIER does not currently operate any bonus schemes for its staff but does award modest ad hoc bonus payments.

As a regulated entity PIER employees are subject to the requirements of the Firm’s Training & Competence Scheme as well as the Senior Managers & Certification Regime and Code of Conduct Rules.

There is a formal feedback and appraisal process in place which supports PIER’s commitment to developing highly motivated staff who can deliver very good customer outcomes. The annual (as a minimum) assessment of performance against job roles and objectives influences the individual’s remuneration in terms of fixed remuneration and promotion opportunities and may occasionally trigger discretionary pay.

In taking any remuneration decisions the Governing Body will always aim to achieve the right balance between the fixed and variable components of total remuneration and to ensure that:

  • fixed and variable components are appropriately balanced, and
  • the level of the fixed component represents a sufficiently high proportion of the total remuneration to minimise any behaviours which might lead to customer harms.

No external consultants are used in the development of PIER’s remuneration policies and practices.

Fixed & Variable Remuneration

When assessing an individual’s remuneration, PIER considers both financial and non-financial criteria.

Non-financial criteria will depend on the employee’s role but may include:

  • measures relating to building and maintaining positive customer relationships and outcomes and
  • performance in line with PIER’s strategy and values, for example by displaying leadership, teamwork, adherence to the Firm’s internal controls and procedures in relation to risk management and adherence to compliance policies.

We pay all our staff fixed remuneration.  Any discretionary payments are made at the discretion of Governing Body and take clear performance indicators into account. Any discretionary payments to investment managers will not be made without input from the compliance function to ensure that compliance with the requisite regulatory requirements is factored into the decision making.

Fixed remuneration payable by PIER is based on the employee’s experience and responsibilities within the Firm as set out in the employee’s job description and terms of employment. Fixed remuneration is payable to all staff, is non-discretionary and includes the following:

  • Fixed salary
  • Company pension contributions
  • Other fixed benefits (some of which are optional and some of which are role-dependent) including life assurance, medical cover and exam support.

Eligibility for specific benefits may be dependent on the employee’s level of seniority, experience or the nature of their role. Variable remuneration reflects the long-term performance of an employee as well as performance which is more than that required to fulfil the employee’s job description and terms of employment.

Quantitative Disclosures

As an ‘Small Non-Interconnected’ MIFIDPRU investment firm, we are required to disclose the total remuneration of all our staff split between fixed and variable remuneration for our performance year end which is also our financial year end.

For our year ended 31/03/2023, our total remuneration is split as follows:

Type of Remuneration

Amount £000s

Fixed Remuneration

£ 409

Variable Remuneration

£ 3

Total Remuneration

£ 412

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