Introduction
QSix LLP (“QSix” or the “Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”). QSix is classified as an SNI (small and non-interconnected) MIFIDPRU investment firm and is subject to the basic disclosure requirements set out in the FCA Handbook MIFIDPRU 8.
Remuneration Policy and Practices
Overview
As an SNI MIFIDPRU Investment Firm, QSix is subject to the basic requirements of the MIFIDPRU Remuneration Code. The purpose of the remuneration requirements is to:
- Promote sound and effective risk management in the long-term interests of the Firm and its clients
- Limit risk-taking and avoid conflict of interest
- Encourage responsible business conduct
- Support positive behaviours and healthy firm cultures
- Discourage behaviours that can lead to misconduct and poor client outcomes
Characteristics of the Firm’s Remuneration Policy and Practices
Remuneration at QSix is made up of fixed and variable components, further detail of which is set out below. Staff are assessed according to QSix’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 receive fixed remuneration and are considered for discretionary variable remuneration (bonus) where eligible. These are two separate methods of financial reward. QSix’s remuneration policy is gender neutral and takes into consideration the Equality Act 2010.
Fixed component
This is set by considering factors such as market information in order to attract and retain skilled staff.
Variable component
QSix’s bonus scheme is a discretionary award scheme based on the performance of the Firm as a whole. All bonuses are dependent on the firm’s overall financial result to ensure a sound capital base. The bonus pool will take into consideration all types of current and future, financial and non-financial risks and be determined on a sliding scale, using a monthly salary multiplier as a guide.
On an individual level, the scheme is designed and linked to both financial and non-financial criteria, rewarding behaviours that promote positive non-financial outcomes for the firm and limiting behaviours contrary to the Firm’s values. Non-financial criteria considered when rewarding staff includes displaying leadership, teamwork or creativity, and adherence to the firm’s risk management and compliance policies, as set out in the Competencies Framework which is a key part of the appraisal process.
The bonus pool and other individual bonuses will be adjusted as deemed necessary by the Partner Board of the Firm in consideration of the following:
- Any compliance or regulatory issues that have occurred or are under investigations internally or externally
- Any persistent or significant breaches in either financial or non-financial KPI’s
- Any conduct related matters that have occurred or are under investigation internally or externally
- Any matters that adversely impact client outcomes
- Any other factors that may publicly impact the Firm’s brand or reputation. Control function staff are independent from the business units 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.
Governance and Oversight
QSix’s Partner Board is responsible for overseeing the implementation of QSix’s remuneration policy and ensuring compliance with the MIFIDPRU Remuneration Code. In order to fulfil its responsibilities, the Partner Board oversees the performance management process by reviewing and approving the remuneration policy, variable remuneration pool, eligibility of participation in variable remuneration as well as the approval of any variable remuneration awarded. HR support the Board in completing the performance management process for all staff, including ensuring staff remuneration is benchmarked against the market each year. The Partner Board ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of the Firm and of its clients. The appraisal process is reviewed annually.
Quantitative Remuneration Disclosure
For the financial year 1 April 2022 to 31 March 2023, the total amount of remuneration awarded was £4,165,616.39. The ratio between fixed and variable component is approximately 1:0.09.
