The purpose of the Remuneration Code is to ensure firms establish, implement and maintain remuneration policies, procedures and practices that are consistent with, and promote, sound and effective risk management.
The Remuneration Code applies to ‘Remuneration Code Staff’ (‘Code Staff’). This includes senior management, risk takers, staff engaged in control functions and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the firm’s risk profile.
Whilst appreciating the contribution that can be made by a Remuneration Committee, CCAM considers that such a body would not be proportionate given the size and non-complex nature of both its activities and organisation. Instead, CCAM’s governing body undertakes this role and is responsible for setting CCAM’s policy on remuneration.
CCAM’s Remuneration Policy will be reviewed, at least, annually by the governing body to ensure that it remains consistent with the Remuneration Code Principles and CCAM’s objectives. The governing body will use all information available to it in order to carry out its responsibilities under the code, for example, information on risk and financial performance. In addition, the Compliance Officer, as part of CCAM’s regulatory monitoring, will include a review of the implementation of this Policy by the firm.
Link between pay and performance
Remuneration at CCAM can be made up of fixed (‘salary’) and variable (‘bonus’) components.
Salary is set in line with the market at a level to retain, and when necessary attract, skilled staff.
Any bonus paid is designed to both reflect the performance of a person in contributing to the success of the firm and their success in meeting, or exceeding, targets that have been set by the firm on an individual basis.
Where remuneration is performance-related then in addition to the performance of the individual CCAM will also take into account the performance of the business unit concerned and the overall results of the firm. Performance assessment will not relate solely to financial criteria but will also include compliance with regulatory obligations and adherence to effective risk management. In keeping with CCAM’s long term objectives, the assessment of performance will take into account longer-term performance.
The measurement of financial performance will be based principally on profits and not on revenue or turnover.
Awards will reflect the financial performance of CCAM and as such variable remuneration may be contracted where subdued or negative financial performance occurs.
Quantitative remuneration information
CCAM is required to disclose aggregate information on remuneration in respect of its Code Staff, broken down by business area and by senior management and other Code Staff. The relatively small size and lack of complexity of the firm’s business is such that CCAM only has the one business area, investment management and does not regard itself as operating, or needing to operate, separate ‘business areas’ and the following aggregate remuneration data should be read in that context.
The aggregate remuneration of the senior codes staff was £16.29m (audited accounts 2016)
This remuneration disclosure is made under the Basel Pillar 3 framework. Our non-remuneration Pillar 3 disclosures can be found here.