Home / Regulatory Disclosure

Regulatory Disclosure

Arma Partners LLP (“Arma” or the “Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm reference number 454270 and is a “MiFIDPRU firm” as defined in the FCA Rules.

The FCA, in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”), sets out the detailed prudential requirements that apply to the Firm. Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance that apply to Arma as a corporate finance adviser and MIFIDPRU investment firm with which the Firm must comply.

During the disclosure period, Arma Partners LLP was classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.

The disclosure contained herein sets out the Firm’s remuneration policies relevant to its staff in sufficient detail considering the nature, size and complexity of its activities. For these purposes, ‘staff’ is defined broadly and includes partners of the Firm itself, employees of its subsidiaries and secondees. Unless otherwise stated, all figures are in respect of the Firm’s financial year ending 31 March 2024.

Remuneration Policy and Practices

Overview

As an SNI MIFIDPRU Investment Firm, during the disclosure period, Arma was subject to the basic requirements of the MIFIDPRU Remuneration Code (as set out in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)) and therefore required to disclose certain information on its remuneration policy and practices relevant to its staff as well as certain quantitative aggregated information about the remuneration awarded to its staff.

The objectives of Arma Partners LLP’s remuneration policies and practices are to establish, implement and maintain a culture that:

  • promotes sound and effective risk management in the long-term interests of the Firm and its clients;
  • identifies and manages any conflicts of interest;
  • limits risk-taking inconsistent with the risk profile of the Firm;
  • ensures alignment between risk and individual reward;
  • encourages responsible business conduct; and
  • discourages behaviours that can lead to misconduct and poor client outcomes.

Arma also recognises that remuneration is a key element in attracting, motivating, and retaining motivated and quality staff in a competitive market while encouraging staff to sustain high levels of performance, productivity and results in line with the Firm´s business strategy and objectives. The Firm ensures that it does not remunerate or assess the performance of its staff in a way that conflicts with its ability to act in the best interests of its clients and therefore an appropriate balance between fixed and variable remuneration is always maintained.

In addition, Arma is dedicated to fostering a culture of excellence, teamwork, positive compliance and the achievement of outstanding outcomes for its clients. Performance based remuneration is therefore evaluated based on various financial and non-financial criteria aligned with these core values. Decisions on rewards are made thoughtfully, considering the effort, attitude and results demonstrated by staff.

Arma ensures that individual performance, the assessment process and any variable remuneration awarded is non-discriminatory and gender-neutral.

Characteristics of the Firm’s Remuneration Policy and Practices

Remuneration of Arma staff comprises appropriately balanced fixed and variable components, with the fixed component sufficiently high to enable the operation of a fully discretionary and flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements. Poor performance by an individual may result in no variable remuneration awarded. To retain key employees, enhance performance and safeguard essential skills and knowledge, the firm has implemented a retention bonus policy.

Fixed Remuneration

Fixed remuneration is set in line with market competitiveness at a level to attract and retain skilled staff and is comprised of base salary, pension and benefits (e.g. private health cover and life assurance). Base salary is reviewed annually and informed with reference to peer group and adjusted for other variables, including tenure, knowledge, ability and experience.

Variable Remuneration

Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s performance, the broader competitive markets in which the Firm operates as well as the financial and non-financial performance of the individual in contributing to the Firm’s success.

All staff are eligible for performance based variable remuneration. Awards may be deferred, designed to encourage staff retention and long-term commitment to Arma Partners LLP.

Awards of performance based variable remuneration take into consideration the Firm´s financial performance and cash position, market conditions as well as the individual´s assessment in accordance with Arma’s performance review process. When assessing individual performance, the Firm considers both financial and non-financial criteria including contribution to sustainable results,  impact on strengthening long-term client relations, compliance with the Firm´s policies and procedures, adherence to risk management procedures, as well as the demonstration of leadership (if applicable) and dedication to teamwork.

Awards of any form of variable remuneration may be adjusted as deemed necessary in consideration of the following:

  • termination of employment for any reason;
  • reasonable evidence of wilful misconduct or negligence;
  • suspension or disciplinary proceedings; and
  • any other factors that may publicly impact the Firm’s brand or reputation.

Governance and Oversight

Arma’s remuneration policy and practices are reviewed, approved and overseen by the Firm´s partner group on a regular basis. The Firm’s Legal and Compliance function provide input to the remuneration policy and the Firm´s Human Resources function supports the performance management process for all staff. The Firm ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of Arma and of its clients. The Firm´s remuneration policy and appraisal process are reviewed on a regular basis.

Quantitative Remuneration Disclosure

For the financial year, ending 31 March 2024 the total amount of remuneration awarded to staff of the Firm was £52,080,730 of which £14,580,539 comprised the fixed component of remuneration, and £37,500,191 comprised the variable component.