MIFIDPRU Public Disclosure Document
Carne International Financial Services (UK) Ltd
Date as at July 2023
For the period [12 months to 31st March 2023]
Name: Robin Cotterill
Function: CIFSUK Compliance Function
Review frequency: Annual
|Description of changes|
Table of contents
1 Overview and summary
1.1 Own funds requirements – MIFIDPRU
1.2 Concentration risk – MIFIDPRU
1.3 Liquidity – MIFIDPRU
2 Remuneration arrangements
2.1 Qualitative Remuneration
2.2 Quantitative Remuneration
Overview and summary
Carne International Financial Services (UK) Limited (“CIFSUK’’) is regulated by the Financial Conduct Authority (“FCA”) as a Markets in Financial Instruments (“MiFID”) firm and subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook.
For the purposes of MIFIDPRU, the Firm has been classified as a small non-interconnected (“SNI”) firm.
The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.
This Public Disclosure Document has been prepared based on the audited financials as at 31st March 2023.
CIFSUK’s main business activity are:
- AMX by Carne Fund Distribution;
- Distributor services for other Carne Group Management Company’s/AIFMs;
- Client Counterparty and Distributor for AMXZero; and
- Provision of Appointed Representative services to external asset managers, with CIFSUK acting as their Principal
CIFSUK’s main objectives are to:
- Provide products and services that facilitate advisory, distribution and marketing activities in the UK by Carne Group’s institutional clients;
- Deliver operational efficiencies to institutional investors and asset managers on the AMX by Carne Platform, by building new fund structures (particularly in relation to the UK), diversifying across a range of strategies and providing technology; and
- Provide unregulated intragroup services relating to product management, legal, client services and risk.
1.1 Own funds requirements – MIFIDPRU 4
As an SNI firm without permissions for dealing as principle or holding client money or client assets, CIFSUK is subject to a Permanent Minimum Requirement of £75,000.
CIFSUK calculates its own funds requirements based on the Fixed Overhead Requirement (“FOR”) calculation and is not subject to any K-factor requirements.
CIFSUK has further assessed any risks facing its business operations within its ICARA and quantified additional own funds and liquidity, where required.
1.2 Concentration risk – MIFIDPRU 5
CIFSUK does not conduct any trading on own account and does not have regulatory permissions for dealing as principal. CIFSUK therefore does not have any concentration risks on or off-balance sheet and does not operate a trading book.
1.3 Liquidity – MIFIDPRU 6
CIFSUK maintains minimum liquidity at all times in compliance with the Basic Liquid Asset Requirement (BLAR), being at least 1/3 of its FOR.
CIFSUK does not provide any client guarantees and therefore its entire liquidity requirement is driven by its expenses, as captured by the FOR.
As part of the ICARA, CIFSUK also maintains liquidity to satisfy its net wind-down costs and any additional liquidity requirements which the ICARA identified for supporting the ongoing business activities of the Firm.
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).
In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:
- The Firm’s remuneration policy is subject to initial and ongoing annual approval by the CIFSUK Board. It is also reviewed and updated when any changes are made to remuneration arrangements (including the launch of new remuneration schemes or changes in regulation). To ensure they are appropriate and proportionate to the nature, scale, and complexity of the risks inherent in the business model and the activities of the firm.
- CIFSUK Board has oversight of remuneration policy and their application to staff remuneration arrangements.
- CIFSUK ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all staff.
- Variable remuneration is adjusted in line with capital and liquidity requirements as well as the firm’s performance.
CIFSUK has not received any government capital injections, or any specific government guarantees and as such is not currently subject to SYSC 19G.6.2R. Should CIFSUK ever be subject to exceptional government intervention in the future, it will review the FCA’s requirements and ensure that no variable remuneration is paid to members of the CIFSUK Board or its staff unless it is justified within the parameters set out by the FCA.
CIFSUK’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categories as either fixed or variable remuneration.
Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
CIFSUKUK’s Remuneration Policy ensures that fixed and variable components of remuneration are appropriately balanced, such that the fixed component represents a sufficiently high proportion of total remuneration. Variable remuneration is based upon staff members’ performance or, in exceptional cases, other conditions.
Performance 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.
All remuneration proposals (fixed and variable pay), for all business units, are submitted, reviewed, and approved through the approval hierarchy embedded within the HR system and subject to oversight by the CIFSUK Board.
The Firm maintains further policies and procedures to minimise the risk of staff acting inappropriately, including the Conflicts of Interest Policy.
Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit.
The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.
The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.
2.1 Qualitative Remuneration
- Approach to remuneration for all staff - Remuneration policies are designed to reward performance, promote sound risk management, and discourage excessive risk taking.
- Objectives of financial incentives - Incentives are intended to reward performance in line with business strategy, company values, risk appetite and customer outcomes. They aim to attract, motivate, and retain talent.
- Decision-making procedures and governance - The Board oversees the remuneration policies and practices, obtaining input from control functions to assess consistency with risk appetite. Control functions perform reviews to ensure alignment with regulatory requirements under the MIFIDPRU Remuneration Code.
2.2 Quantitative Remuneration
All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded.
As an SNI firm and in accordance with MIFIDPRU 8.6.8, CIFSUK is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.
For the performance year ending 31 March 2023
- Total fixed remuneration awarded £2,053,792
- Total variable remuneration awarded £856,558
- Total remuneration awarded £ 2,910,350