Remuneration Policy

Definitions

1.  Introduction

The Remuneration Policy (“Policy”) records the remuneration policy for Marlborough Select Platform Ltd (“Select Platform” / the “Company”). The Select Platform provides investment platform services to advised consumers allowing the adviser to manage their clients’ money including through ISAs, and SIPPs. The Select Platform is authorised and regulated by the FCA in the control of such business. The Company has adopted a remuneration policy in accordance with the requirements of MiFID II (Directive 2014/65/EU of 23 July 2014) and the MiFID Org Reg (EU 2017/565) and is subject to the Remuneration Codes set out by ESMA and in Chapters 19C and 19F of the FCA’s SYSC Handbook. The Company’s Policy also complies with the Investment Association’s Principles of Remuneration. The Policy is designed to ensure that the Company’s remuneration practices;

• are consistent with and promote sound and effective risk management,
• don’t expose the Company to excessive risk, and
• include measures to avoid conflicts of interest.

The Company considers the Policy to be appropriate to the size, internal operations, nature, scale and complexity of its activities.

2.  Remuneration code staff

The Policy will apply to the fixed and variable (if any) remuneration, including salaries and pension benefits received by the identified remuneration code staff. The identified remuneration code staff are those whose professional activities have a material impact on the risk profile of the Company, including but not limited to;

• senior management (in the context of remuneration code staff, this applies to those managers assessed as having a material impact on the Company’s risk profile)
• 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 and whose professional activities have a material impact on the Company’s risk profile.

3.  Fixed and variable remuneration

The structure of remuneration for remuneration code staff is designed to be in line with the Company’s business strategy, taking account of any conflicts of interest and the existing and future capital requirements of the business. It typically consists of fixed pay and variable remuneration, potentially consisting of an annual bonus and long term incentives. Remuneration is based on, but not limited to;

• an appropriate balance between fixed and variable remuneration, including the possibility of paying no variable remuneration,
• fixed remuneration, based on market rates and the experience and skill of the individual,
• variable remuneration that is discretionary and involves assessment of the performance of the individual, the financial performance of the Company, the performance of the business unit and its current and future risks,
• individual performance assessment will not solely relate to financial criteria but will also include compliance with regulatory obligations, adherence to effective risk management, adherence to the Company’s Code of Conduct, and adherence to the Company’s business principles and policies,
• the measure of the Company/Marlborough Group’s financial performance is based principally on net profits and not revenue or turnover,
• long term variable incentives are aligned to the Company’s strategic objectives,
• the reduction or cancellation of any variable remuneration in the case of an individual’s under-performance, and
• an appropriate element of shares or equivalent ownership interests applied equally between non-deferred and deferred components.

4.  Pension

The Company operates a self-invested personal pension scheme and contributions are set at an appropriate level to attract and retain high performing people. The Company doesn’t offer any discretionary pension benefits.

5.  Conflicts of interest

Conflicts of interest involve a failure by the Company to act in the best interests of its clients and a material risk of damage to the interests of those clients. To ensure that individuals act in a fair manner, the Company has procedures in place to reduce conflicts and manage risks. The management of potential remuneration conflicts includes:

• Any assessment for awarding financial remuneration, other benefits and career progression is clearly linked to performance criteria that encourages staff to act in the best interests of clients.
• Remuneration awards that aren’t solely linked to  sales.
• Clear structural segregation of business functions is in place to allow for their independent running and this is reflected in the composition of the Management Board.
• Group Board provides independent recommendations on remuneration.

The Company regularly reviews potential and actual conflicts and maintains an up to date conflicts of interest register.

6.  Annual review

On an annual basis the Company will review the terms of this Policy and assess whether the overall remuneration system operates as intended and is compliant with their obligations on remuneration. This Policy will be updated as and when required.

Appendix 1:

List of BIPRU Remuneration Code Staff (SYSC 19C.3.5)

Phil Gilder – Chief Executive Officer (SMF 1 and 3)

Sarah Peaston – Chair of the Governing Board (SMF 9)

Tracy Smith – Compliance (SMF 16 and 17)

Dom Clarke – Finance Director (SMF 3)

Nick Bridge – Head of Customer Support (SMF 3)