HCML Regulatory Disclosures
MIFIDPRU 8 Disclosure
Howden Capital Markets Limited FYE 30 September 2023
HCML’s remuneration approach and objectives
Management of our remuneration practices is a fundamental element of the culture and governance of Howden Capital Markets Limited (‘HCML’, ‘the Firm’, ‘we’, ‘us’, ‘our’), as part of Howden Group Holdings (the “Group”). Remuneration is a key driver of behaviour and it is important for us to ensure that risk and reward are suitably aligned and that we do not encourage excessive or inappropriate risk taking or short-termism. Our remuneration policy is also designed in accordance with FCA rules and guidance to achieve the following core objectives:
- Ensuring alignment between risk and reward to reflect HCML’s business strategy
- Promoting sound and effective risk management and risk awareness that considers the long-term interests of the Firm and its customers
- Supporting and encouraging positive behaviours and a healthy culture across the Firm
- Discouraging inappropriate behaviours, actions or conduct leading to poor customer outcomes
- Preventing conflicts of interest from adversely affecting the interests of its clients.
Governance and decision-making procedures
The HCML Board is responsible for overseeing the implementation of its remuneration procedures and ensuring their compliance with applicable remuneration codes and relevant Group policy. Fixed and variable remuneration is generally determined on an annual basis, or as required for new hires. HCML’s remuneration policy is reviewed annually by the HCML Board and by the Howden Group Remuneration Committee (the “Group RemCo”). The Group RemCo consists of non-executive directors and is chaired by an independent non-executive director. A full description of the Group RemCo’s role and practices are detailed in the Group’s Annual Report. Key activities include the consideration of and guidance in relation to employee incentive plans, executive remuneration and individual share award proposals.
The remuneration of senior staff in risk management and compliance functions is directly overseen by the Board. Furthermore, variable remuneration to staff with control functions is awarded according to objectives linked to their functions and remains independent from the business unit(s) they oversee.
The Firm also follows the relevant edition of the Howden Broking Group Salary Guidelines/Annual Compensation Review Manager Guidelines when setting fixed and variable remuneration for staff.
HCML staff receive fixed remuneration based upon their professional experience and organisational responsibility as set out in their job descriptions and terms of employment.
Staff are assessed under HCML’s performance management process on an ongoing basis with an annual performance assessment outcome being used as a contributing factor in the determination of remuneration. All staff that receive fixed remuneration are considered for discretionary variable remuneration (cash bonus and Group share schemes) where eligible.
Control function staff (risk management, compliance, finance and internal audit) are independent from the business they oversee and are remunerated in line with the achievement of the objectives of their functions. The determination of the level of remuneration of such staff is independent of the performance of the business areas they oversee.
Components of remuneration
HCML staff may receive the following forms of remuneration
- Fixed remuneration: salary
- Variable remuneration: cash bonus and Group share scheme participation
Quantitative remuneration disclosure (as required under MIFIDPRU 8.6)
The total amount of remuneration awarded to all HCML staff for the 12 months ended 30 September 202 was £1,175,485. Of this, £825,485 was fixed remuneration and £350,000 was variable remuneration.