MIFIDPRU

Investment firm remuneration is regulated by the FCA to help ensure pay and incentives do not promote or reward excessive risk taking.

The MIFIDPRU Remuneration Code applies to all performance periods starting on and after 1 January 2022. It requires remuneration arrangements to be proportional to the size of the firm and types of risk undertaken.

Small Non-Interconnected firms (SNIs) need to comply only with BASIC rules.

Medium size firms (Non SNIs), must obey the same Basic rules but must also identify Material Risk Takers (MRTs) and must control, disclose and report their pay specifically. These are the Standard requirements

Large firms (Large Non SNIs), must follow the same Standard requirements, but also apply Extended rules too. This involves a 50% independent remuneration committee and rules on variable pay deferral and payment in shares (or similar instruments) over at least three years, among other things.

Control of business behaviour and risk is important for all businesses. The ESG agenda of many companies tells us this clearly. For example, remuneration and incentives must be designed to both promote the right outcomes and avoid dysfunctional ones, like excessive risk taking or poor behaviour of other kinds.

Risk in Financial Services is a critical business and a societal issue too. So strong regulation of controlled risk taking is welcome, including the linked remuneration and incentive aspects.

Some of the MIFIDPRU Remuneration Code concepts might be worth examination and adoption by a wider set of companies than FS alone.

Robert Head

Lead Consultant

Robert works with organisations of all types as a reward consultant or interim reward professional providing reward solutions, interim management and consultancy.

Robert is experienced in working across multiple sectors (including public listed, private equity, commercial, financial, non-profit, and charity).

Robert has deep subject matter reward experience in corporate governance, executive reward, remuneration committees, reward strategy, reward policy, annual bonus, long-term incentives, transformation and change, corporate actions, mergers and acquisitions, and restructuring.

Robert is experienced in stakeholder management working closely with Chairs and executive directors including CEOs and CFOs, non-executive director members of remuneration committees, members of executive committees including business unit CEOs/Presidents, senior HR business partners and other line executives, senior management in other organisations, outside specialists and advisers, and investors.

Robert Head Corpgro

Jane Allen

Lead Consultant

Jane has over 30 years of Reward experience within listed multinational organisations and consultancy environments.

Her expertise covers Total Reward (strategy and programmes), benefits & wellness, pensions, executive compensation, Remuneration Committee support, annual and long-term incentives, VCPs (value creation plans), M&As and restructuring.

Jane has successfully established reward teams and best practices for all key reward processes, leading on complex local and international issues across UK and US listed, family owned, and PE backed ownership structures.

She has a keen interest in ESG and how this can be reflected within Executive Pay to align with the long-term sustainability of businesses. 

Jane is a Fellow of the Pensions Management Institute and a Chartered Insurer. She is an independent Trustee for The Economist Pension Plan.

Damian Carnelll

founder director

CORPGRO is a reward consultancy specialising in executive incentives particularly those connected with growth; and ESG.

Damian has extensive experience advising leading companies on all aspects of executive compensation and equity plans. He was previously with Willis Towers Watson, Aon, and Ernst and Young. 

Damian’s extensive experience in executive compensation and equity plans means he is fully familiar with Corporate Governance norms, institutional shareholder views and proxy voting both advisory and binding.

Damian Carnell Corpgro