Annual disclosure for Thomson Tyndall for year ending 30/06/2024

Introduction

The Investment Firms Prudential Regime (IFPR) came into effect on the 1 January 2022 as a new regime for UK firms authorised under the Markets in Financial Instruments Directive (MiFID).

The IFPR was implemented by the FCA as prudential regulation within the MIFIDPRU section of the FCA Handbook.

These disclosures set out Thomson Tyndall Limited’s annual public disclosures as required under MIFIDPRU 8 for the year ending 30/06/2024.

Scope and application of disclosure

These disclosures relate to Thomson Tyndall Ltd. Thomson Tyndall Ltd is an SNI MIFIDPRU Investment firm, authorised and regulated by the FCA.

Thomson Tyndall Ltd is required to disclose on an individual firm basis and these disclosures have been prepared in line with the requirements of MIFIDPRU 8.

As an SNI MIFIDPRU firm under IFPR we are required to disclose the following remuneration information regarding our remuneration policy and practices under MIFIDPRU 8:

Qualitative Disclosures

  • Our approach to remuneration for all staff and the objectives of our financial incentives in respect of staff remuneration.

Our remuneration policy has been designed to encourage responsible business conduct and to ensure that the interests of our staff are aligned with those of our clients, enabling us to deliver consistently good client outcomes. We believe our remuneration policies and practices are appropriate and proportionate to the nature, scale, and complexity of the risks inherent in our business model and the permitted activities of our firm.

Employed non-advisory staff receive a combination of fixed remuneration (salary plus benefits) and variable remuneration. The fixed element is determined by the role and experience that the individual holds while the variable element is directly determined by their performance, adherence to the firm’s systems and controls, and the overall performance of the firm.

Employed advisory staff and consultants / investment managers receive a relatively high proportion of variable remuneration which is linked to ongoing revenue generated from investment and advisory activities; it is not awarded as a bonus and is not based on specific targets. Variable remuneration can be deferred or withheld in the event of specific circumstances, such as non-compliance with the firm’s systems and controls.

  • Our decision-making procedures and governance surrounding the development of the firm’s remuneration policies and practices.

As a SNI, Thomson Tyndall is not obliged to establish a Remuneration Committee and given the size, internal structure, and the nature, scope and complexity of the activities of the firm we have decided not to do so.

The senior management team therefore sets the remuneration levels which are then reviewed and approved by the Board, who are also responsible for ensuring that remuneration policies across the Firm are consistent with the promotion of effective risk management and good client outcomes.

  • The key characteristics of our remuneration policies and practices including the different components of our remuneration, together with the categorisation of those remuneration components as fixed or variable.

In setting our remuneration strategy we aim to strike a balance between offering competitive remuneration packages so that we can attract staff with a commitment to excellence, and promoting effective risk management and alignment between firm and client interests.

Remuneration typically comprises of fixed and variable elements. Fixed remuneration consists of base salary, pension contribution, and other benefits such as private medical insurance and life assurance which constitutes the fixed payment made to an employee for their services.

Thomson Tyndall has defined variable pay as discretionary bonuses, which are awarded based on firm and individual performance, and may include a share of revenue.

The remuneration of the directors is linked in part to the profitability of the firm and to the performance of the Board in line with the firm’s strategy and values; adherence to the firm’s risk management and compliance policies; and capital and liquidity requirements. It is agreed on an individual basis and includes a fixed element.

The remuneration of all employed non-advisory staff consists of salary and other benefits which are reviewed on an annual basis. The fixed proportion of total remuneration is set sufficiently at a level where it remains the largest proportion of the remuneration of each employee. These pay levels are reviewed on at least an annual basis to ensure that this remains the case and is in line with SYSC 19G.4.

Most non-advisory staff are eligible for a discretionary bonus, which is paid quarterly. A portion of the Firm’s profits are set aside during the annual budgetary process and individual shares are awarded based on contribution to the strategic aims of the business, adherence to the firm’s policies and processes, and progress in meeting individual agreed goals. The contribution of staff is assessed by line managers and directors against set criteria based on their role, with the final award being reviewed and approved by the Board.

The employed advisory staff across the group are part of a separate bonus scheme which is based on the revenue that they bring into the business combined with certain qualitative measures. The bonus payment can be deferred, adjusted or completely removed if the qualitative measures are not met. The qualitative measures are reviewed on an annual basis by the compliance team to ensure that these measures drive behaviours in line with the Firm’s values and do not lead to a conflict of interest.

Consultants receive a share of the revenue they generate, and this can be deferred or withheld in the event of specific circumstances, such as non-compliance with the firm’s systems and controls.

Share of revenue payments are only paid once Thomson Tyndall has received the fees on which payment might be due. Share of revenue payments will typically only apply to advisory staff at the Firm, are reviewed regularly, and are only payable once validated by a member of the Board.

Thomson Tyndall ensures it always maintains a balance between fixed and variable components of remuneration to mitigate any conflicts of interest between the Firm, its staff and its clients. The Board is ultimately responsible for ensuring that remuneration and similar incentives are not solely or primarily based on quantitative commercial criteria. Consequently, the Firm will take into account appropriate qualitative criteria which shall encompass adherence with relevant regulations, fair treatment of clients and the quality of services provided to clients.

2. Quantitative Disclosures

As an SNI MIFIDPRU investment firm, we are required to disclose the total remuneration of all our staff split between fixed and variable remuneration for our performance year end which is also our financial year end.

For our year ending 30/06/2024, our total remuneration is split as follows:

Type of Remuneration Amount £000s
Fixed Remuneration £ 901
Variable Remuneration £ 3,420
Total Remuneration £ 4,321