MIFIDPRU Public Disclosure Document

Tresidor Investment Management LLP

For the period 1st January 2022 – 31st December 2022

Overview and summary

Tresidor Investment Management LLP (“Tresidor”, “the Firm”) is regulated by the Financial Conduct Authority (“FCA”) as a Markets in Financial Instruments (“MiFID”) firm and subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook. The Firm was also registered as an Alternative Investment Fund Manager (“AIFM”) under the Alternative Investment Fund Manager Directive (“AIFMD”).

For the purposes of MIFIDPRU, the Firm has been classified as a small non-interconnected (“SNI”) firm.

The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.

This Public Disclosure Document has been prepared based on the audited financial statements covering the financial period 1st January 2022 – 31st December 2022.

The Firm’s main business activity is to provide investment management services to Funds on behalf of institutional investors or high net worth individuals.

Remuneration arrangements

The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).

In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:

  • Tresidor’s remuneration philosophy and practice do not encourage excessive or inappropriate risk-taking.

  • It is important to the Firm that every one of the senior team is aligned with firmwide results, and thus investors' results, and that they do not have competing incentives that might lead them to put themselves / their activities first.

  • The Remuneration Committee, comprised of the CIO, the CEO and the Chairman, is directly responsible for both the review of remuneration policy and its implementation each year, and will review the remuneration policy on an annual basis to ensure it continues to effectively achieve the aims above and is proportionate to the nature, scale and complexity of the risks inherent in the business model and activities of the Firm.

  • The Firm pays competitive salaries (and profit-linked draws for partners) that are measured against the asset management industry to remain on par with the market.

  • The Firm ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all Staff.

Tresidor’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categorized as either fixed or variable remuneration.

  • Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is pre-determined, non-discretionary, and not dependent on performance.

  • Variable remuneration is based on the Firm’s and individual staff members’ performance and is carefully designed as a multi-tier compensation structure to align each individual to focus on firmwide performance while also incentivising individual efforts. It is adjusted in line with capital and liquidity requirements where necessary. All staff are eligible to receive variable remuneration.

Performance criteria reflect the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment.

Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit, and:

  • includes discretionary pension benefits as well as life and health insurance; and

  • may include performance fee linked revenues, also referred to as carried interest, as referred to in SYSC 19G.1.27R.

The Firm ensures that fixed and variable components of total remuneration are appropriately balanced, and the fixed component represents a sufficiently high proportion of individuals’ total remuneration to enable the firm to conduct a flexible policy on variable remuneration. The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.

Quantitative remuneration disclosure

All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded. As an SNI firm and in accordance with MIFIDPRU 8.6.8, Tresidor is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.

For the performance year ending 31 December 2022:

Total fixed remuneration awarded:   £1,117,891

Total variable remuneration awarded:   £13,964,192

Total remuneration awarded:   £15,082,083

For further information, please contact:

Edgar Senior, CEO

edgar.senior@tresidor.com