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Connor Broadley Limited (‘the Firm’)
Accounting Reference Date: 1st April 22 – 31st March 23
Owner: Alexandria Marquis – Head of Compliance
Last reviewed: April 2023
The Investment Firms Prudential Regime (‘IFPR’), implemented in January 2022, requires all MiFID investment firms to make certain public disclosures according to Financial Conduct Authority (FCA) rules, increasing transparency and giving an insight into how the business is run.
Under the IFPR, Connor Broadley Limited (‘the Firm’) is categorised as a small and non-interconnected (‘SNI’) MIFIDPRU investment firm.
The Firm prepares public disclosure and other required external publications to increase confidence and transparency and provide stakeholders and market participants with an insight into how the Firm is run. We understand that public disclosures are a core part of market discipline, providing important information and transparency to participants to enable markets to work well.
An established internal controls framework is in place to ensure that the disclosure, including other external publications, meet the relevant regulatory requirements and standards. As such, prior to external publication, the documents are subject to internal verification and approval.
The Head of Compliance is responsible for the production of public disclosures. The draft disclosure document will be reviewed by The Company Secretary before its submission for approval to the Board.
The public disclosure requirements applicable to the Firm as an entity authorised to undertake MIFID regulated activities, are contained in MIFIDPRU 8 of the FCA Handbook, which came into force from 1st January 2022. The disclosure containing both qualitative and quantitative data is made annually, on a solo entity basis or more frequently in the event of a material change.
Based on the Firm’s IFPR prudential classification as being a SNI firm, the public disclosure document will be prepared to contain information in relation to remuneration policy and practices.
The disclosure drafting and validation/sign off process involves input from a number of internal stakeholders.
The Firm is required to publicly disclose the information specified in this Policy on an annual basis on the date it publishes its annual financial statements on Companies House, which is no later than 31st December in the year in which the accounting period ends.
The information under MIFIDPRU 8.1 that is required to be disclosed by the Firm, will be published on the Firm’s website: www.connorbroadley.co.uk.
The Firm did not issue Additional Tier 1 Capital (“AT1 capital”). As a result, the Firm is not subject to the disclosure requirements under MIFIDPRU 8.2, 8.4 and 8.5, relating to the risk management objectives and policies, own funds and own funds disclosure requirements.
The Investment Firm Prudential Regime (‘IFPR’) is the FCA’s prudential regime for MiFID investment firms which aims to streamline and simplify the prudential requirements for UK investment firms. The IFPR came into effect on 1st January 2022 and its provisions apply to Connor Broadley Limited (“the Firm”) as an FCA authorised and regulated firm.
Under the IFPR, the Firm is categorised as a small and non-interconnected (‘SNI’) MIFIDPRU investment firm.
Connor Broadley is a single legal entity and a limited liability Firm. The Firm is an independent owner managed business and the directors are the principal shareholders. The Firm conducts is business from a single office location in London which is also the Firm’s registered office. Connor Broadley provides holistic independent financial planning services and discretionary investment management services to UK resident private clients through a range of service propositions, all of which are based on a highly personalised and high-quality service offering. Additionally, the Firm provides benefits consulting and support services to corporate clients, including consultancy services, financial planning clinics, group risk and group medical scheme broking and services, and group pension scheme implementation and servicing. Connor Broadley is authorised and regulated by the Financial Conduct Authority (468321).
The Firm is required to publish disclosures in accordance with the provisions outlined in MIFIDPRU 8 of the FCA Handbook. This disclosure document covers all aspects of the disclosure requirements within the scope of the MIFIDPRU rules applicable to SNIs that have not issued additional tier 1 instruments. Specifically, disclosure relating to the Firm’s remuneration policy and practices.
The Firm is not a member of a UK Consolidation Group. The disclosure is prepared annually on an individual basis. The Firm will consider making more frequent public disclosure where particular circumstances demand it, for example, in the event of a major change to its business model or where a merger has taken place.
The disclosure is published on the Firm’s website.
The Firm believes that its qualitative disclosures are appropriate to its size and internal organisation, and to the nature, scope and complexity of its activities.
This disclosure has been ratified and approved by the Board of Connor Broadley Limited.
The annual audited accounts of Connor Broadley Limited set out further information which complements the information in this disclosure. The audited accounts are freely available from UK Companies House.
This document does not constitute any form of financial statement on behalf of Connor Broadley Limited. The information contained herein has been subject to internal review but has not been audited by the Firm’s external auditors.
This document sets out the public disclosure under MIFIDPRU 8 for the Firm as of 31st March 2023, which is the Firm’s accounting reference date.
As a MIFIDPRU investment firm, we must establish and implement disclosure requirements to provide investors, stakeholders and wider market participants an insight into how the Firm is run. This disclosure sets out the overarching requirements that apply to the Firm.
Connor Broadley Limited is committed to having robust internal controls to ensure the completeness, accuracy, and compliance with the relevant public disclosure regulatory requirements.
This document has been subject to internal governance and verification process, and approval by the Board in line with the Public Disclosure Policy that the Firm has adopted to ensure compliance with the regulatory requirements contained in MIFIDPRU 8.
The Policy requires internal challenge and oversight prior to approval and publication.
The below provides a reference to the MIFIDPRU disclosure rules in relation to remuneration policies and practices. Please note that firms are not required to publish their MIFIDPRU Remuneration Policy; they are, however, required to disclose a summary of their MIFIDPRU Remuneration Policy.
Under MIFIDPRU 8.6.2R, the Firm is required to disclose a summary of:
its approach to remuneration for all of its employees;
Under MIFIDPRU 8.6.5R, the Firm must also disclose the key characteristics of its remuneration policies and practices in sufficient detail to provide the reader with:
For purposes of MIFIDPRU 8.6.5R, the Firm must disclose at least the following information:
Under MIFIDPRU 8.6.8R(2), the Firm must disclose the total amount of remuneration awarded to all staff, split into:
As a MIFIDPRU investment firm, we must establish, implement and maintain gender neutral remuneration policy and practices that are appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the Firm. Our remuneration policy and practices are gender neutral and do not discriminate on the basis of gender or other characteristics.
The Firm is subject to the MIFIDPRU Remuneration Code and we commit to complying with the most stringent requirements in all instances. In the case of any variation, The Firm, considers which requirement is the most stringent on a provision-by-provision basis.
The Firm’s performance period is from 1st April 2022 to 31st March 2023.
The Firm has adopted a Remuneration Policy that complies with the requirements of Chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook.
The Firm’s remuneration approach is designed to support individual and corporate performance, encourage the sustainable long-term financial health of the business and promote sound risk management for the success of the Firm and to the benefit of its customers, counterparties and the wider market. Our remuneration approach promotes long-term value creation through transparent alignment with the agreed corporate strategy.
The Board believes the Firm’s remuneration structure is appropriate for the business and the industry it operates in and is efficient and cost-effective in delivering its long-term strategy.
Our remuneration structure includes provisions that in specific circumstances, allow the Firm to forfeit or withhold all or part of a bonus or long-term incentive award before it has vested and been awarded.
Undeserved and excessive remuneration sends a negative message to all stakeholders, including the Firm’s workforce, and causes long term damage to the Firm and its reputation.
The objectives of the Firm’s remuneration practices are as follows:
The Firm uses the following financial incentives:
Our financial incentives are designed to:
As a SNI, the Firm is not required to establish a Remuneration Committee. Given the size, internal organisation and the nature, scope and complexity of the activities of the Firm it has not formed a Remuneration Committee. Therefore, the Remuneration policy’s supervisory function is undertaken by the Firm’s Board.
The Board is responsible for reviewing and approving remuneration, and to ensure remuneration policies across the Firm are consistent with the promotion of effective risk management. The Board engages with other member of the senior leadership team, as appropriate. The Board is responsible for reviewing and approving salary amendments and the Firm’s bonus pool arising from the annual compensation review, with reports made to the Board as required.
The Board meets regularly and is composed of:
The Firm makes a clear distinction between fixed and variable remuneration.
Fixed remuneration primarily reflects a staff member’s professional experience and organisational responsibility as set out in the staff member’s job description and terms of employment; and is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration is based on performance and reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment. In exceptional cases, variable remuneration is based on other conditions. Variable remuneration includes discretionary pension benefits.
The Firm will ensure that the fixed and variable components of an individual’s total remuneration are appropriately balanced. In determining this balance, the Firm considers the following factors:
When assessing individual performance to determine the amount of variable remuneration to be paid to an individual, the Firm takes into account financial as well as non-financial criteria. Non-financial criteria should:
The Firm must take into account both financial and non-financial criteria when assessing the individual performance of its staff. This aims not only to discourage inappropriate behaviours but also to incentivise and reward behaviour that promotes positive non-financial outcomes for the Firm.
The Firm uses the following financial performance criteria:
The Firm uses the following non-financial performance criteria:
The criteria outlined above are used for the assessment of the performance of:
Measures of turnover, administrative expenses (including clawbacks / compensations), operating profit, profit before tax, proportion of recurring revenues and regulatory capital adequacy and liquidity requirements.
Performance is assessed against Firm objectives, as well as supporting business units and employees in achieving their unit and individual, role based, objectives. All objectives are designed to ensure the business meets it strategic goals and financial targets. These measures are primarily linked to client satisfaction and retention, collaboration, engagement, participation and progression of key metrics.
Measures of unit turnover, administrative expenses (including clawbacks / compensations), operating profit, profit before tax and proportion of recurring revenues.
Performance is assessed against business unit objectives and how these support Firm objectives, as well as supporting employees in achieving their individual, role based, objectives. All objectives are designed to ensure the business meets it strategic goals and financial targets. These measures are primarily linked to client satisfaction and retention, collaboration, engagement, participation and progression of key metrics.
Where there is just cause, clawed back commission and / or compensation paid to clients may be used as criteria to demonstrate a lack of performance of the firm as a whole, a business unit or an individual.
Performance is assessed against individual, role based, objectives and how these support both Firm and business unit objectives. All objectives are designed to ensure the business meets it strategic goals and financial targets. These measures are primarily linked to client satisfaction and retention, collaboration, engagement, participation and progression of key metrics.
Under MIFIDPRU 8.6.8R(2), the Firm must disclose the total amount of remuneration awarded to all staff, split into:
Fixed remuneration £2,594,685
Variable remuneration £466,607
Total amount £3,061,292
Connor Broadley is committed to observing the highest standards of ethical behaviour and as such expects its financial planners and all other employees to observe and abide by the following:
