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Remuneration policy statement

This policy sets out our policy with regards to the remuneration packages and incentive schemes within our firm.


Remuneration policy statement


This policy sets out our policy with regards to the remuneration packages and incentive schemes within our firm.

All of our remuneration packages and incentive schemes are designed to ensure that our clients are treated fairly and their interests are not impaired, for example, by our remuneration policies creating a conflict of interest that encourages staff to act against the interests of any of our clients.

Scope of policy

This policy will apply to all individuals whose activities have an impact (directly or indirectly) on the investment services we provide.

Individuals who hold the following positions within our firm will fall under the scope of this policy:

  • Individuals holding Senior Manager Functions
  • Other Certification Staff
  • Paraplanners and Planning Support
  • Administrative Staff

Definition of remuneration

For the purpose of this policy, ‘remuneration’ means all forms of financial or non-financial benefits or payments made by our firm (directly or indirectly) to individuals who provide investment services to our clients.

This may include salary, pension contributions, wage increases, promotions, health insurance, discounts or special allowances, expense accounts. This list should not be seen as exhaustive.

Determination of remuneration

Staff remuneration will be determined by Colin Fogwill, Business Owner and Chris Sadler, Managing Director.

Our firm’s remuneration and incentive schemes

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 interest of our clients
  • Include any arrangement by way of remuneration, sales targets or otherwise, that could provide an incentive to our staff to recommend a particular product to a retail client where a different product could be offered that would better suit their needs
  • Create a conflict of interest that would encourages individuals to act against the interests of any of our clients
  • Be solely or predominately based on quantitative commercial criteria


  • Will ensure the fair treatment of our clients and the quality of service provided
  • Will take appropriate qualitative criteria into account
  • Maintain a balance between fixed and variable remuneration so the structure doesn’t favour our firm or staff over those of our clients

The firm’s approach to remuneration is based on:

  • When determining our remuneration strategy, the firm will take into account both financial and non-financial performance.
  • The firm’s approach to financial targets is that bonuses will be paid in relation to both new fees above an agreed level and on-going service.
  • The firm believes that in order to achieve positive outcomes for our clients, remuneration should be linked to Key Performance Indicators (KPI’s) which provide Management Information regarding investment adviser performance against agreed benchmarks as well as meeting financial targets.
  • The KPI’s include: client review completion; lost clients; non-standard charges/fees; complaints; completion of development plans; execution only cases; replacement business; cases not proceeded with; cancelled or lapsed cases;
  • The firm believes that its approach to remuneration delivers long-term benefits for its clients by encouraging investment advisers to deliver an on-going level of service.

Remuneration packages

Bonus schemes
We have the following bonus schemes in place:

Bonus scheme: Investment Advisers
The purpose of the Scheme is to reward investment advisers for helping to build and retain the firm’s client base.

The investment advisers participating in the scheme in 2023 - 2024 will be: Andrew Ball, Sophie Smith, and David Wild.

The discretionary bonus is calculated annually on a) new fees generated above the agreed target b) 12 months after new fees have been generated an amount is paid for on-going servicing of those clients based on assets under management.

In addition to the quantitative criteria above eligibility for a bonus will also be based on an adviser satisfying Key Performance Indicators as detailed in the firm’s Training & Competence Scheme.

Bonus scheme: Staff Discretionary Bonus Scheme
Should the firm, in the opinion of the Directors, have generated sufficient profit then at the discretion of the Directors bonuses may be paid to the Compliance Manager, Administration Manager, Paraplanners, Planning Support, Client Care Co-Ordinators.

Executive incentive schemes
We have the following executive scheme in place:

Directors’ Incentive Scheme:
The Directors incentive scheme which is discretionary is determined by the efficiency and profitability of the firm. Two remuneration code staff can participate in the scheme. The scheme is reviewed by the Board annually.

Senior management responsibilities

Our Board of Directors:

  • Has approved this policy and will be required to approve all future changes
  • Is responsible for the day-to-day implementation of this policy
  • Is responsible for the monitoring of compliance risks related to this policy
  • Will not implement or endorse a remuneration policy which could lead to any increase in risk to the firm through potential future complaints
  • Will not implement or endorse a remuneration policy which would lead to our clients being treated less fairly
  • Will consult with the SMF 16 – Compliance Oversight Function before any changes are made to remuneration/bonus policy that could potentially increase risks to the business

Reviewing this policy

To ensure this policy continues to accurately reflect the process we follow, Simon Briggs, Compliance Manager will review this policy on an annual basis.

For any further details regarding our remuneration policy, please write to Simon Briggs at

Remuneration Quantitative Disclosure

This disclosure is made in accordance with MIFIDPRU 8.6.8R
For the financial year ending 31st March 2023:

All Staff Fixed Remuneration £518,404.00
All Staff Variable Remuneration £84,706.00
All Staff Total Remuneration £603,110.00