1. Introduction

The firms Remuneration Policy Statement is based on The AIFM Remuneration Code SYSC 19B of the FCA Handbook to satisfy the requirements for managers of AIFs and has been compiled having considered the relevant Rules and Guidance.

The Policy has been developed recognising the nature, scope and complexity of the Firm’s activities. It recognises the low complexity of the Firm’s funds and the instruments held by them. 

The Policy is designed to ensure that it is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profiles of the funds it manages. Further, it is intended to be market competitive, motivate employees to improve individual and corporate performance, to attract and retain key employees and align employee actions with the interests of clients.

The Policy is reviewed on an annual basis to ensure that it remains aligned with evolving business strategy, is consistent with best practice, promotes sound and effective risk management and is compliant with applicable regulations. Fundamentally the Policy is designed to avoid conflicts of interest


2. Responsibilities

There is no remuneration committee, instead the Board of Minerva Fund Management Solutions supervises the setting and reviewing of the remuneration levels of its employees. 

The Board oversees Executive pay. The Firm’s Compliance Monitoring Program checks on an annual basis that the remuneration Policy is being implemented correctly. The Board oversees the Remuneration of the Head of Risk and Compliance.


3. Application

The remuneration policy is designed to give a meaningful reward to staff whose performance deserves recognition. The Firm has two remuneration schemes that are applied to all Code staff. An Executive Incentive Scheme (EIS) and a Discretionary Bonus Scheme (DBS). Importantly, the payment of bonuses and the subsequent payment of any staged payments, will be dependent upon the profitability and ongoing profitability of the Firm. Our first requirement is to ensure that the Firm is well capitalised. Therefore, the key adjustment system used, will be that we may not pay any bonuses, or could subsequently withhold the payment of a staged payment, should the profitability of the business not allow it. Staff captured by the Code are aware of its content and purpose, and they are cognisant of their obligations to Treat Customers Fairly and avoid conflicts of interest which cannot be managed in a proportionate way.

The firm ensures that its remuneration policy and practises promote sound and effective risk management, making sure that risk-talking which is inconsistent with the risk profile of the fund is not encouraged. The Firm’s policy provides a weighting towards variable remuneration as part of this process. The variable element is at the discretion of the Board and is deferred over a three-year period. The Policy encourages appropriate long-term decision making in the best interests of end-investors.