Remuneration policy  

This document sets out our policy with regards to the remuneration packages and incentive schemes within our firm.

All of the firm’s remuneration and incentive schemes are/will be designed to ensure that our clients are treated fairly, and their interests are not impaired by our remuneration policies creating a conflict of interest that encourages staff to act against the interests of any of our clients.

We will not make any arrangement by way of remuneration, sales targets or otherwise that could provide an incentive to our employees to recommend a product to a customer when our firm could offer a different product, which would better meet the needs of that customer.

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Scope of policy  

This policy will apply to all individuals whose activities have an impact (directly or indirectly) on the investment services we provide and whose remuneration may present the potential for conflict with the duty to act in the best interests of a customer.

All certified/approved staff(under SM&CR) are considered as falling under the scope of this policy.

We maintain a separate conflicts of interest policy, which determines our firm's overall approach to identifying, preventing and/or managing all types of conflicts including firm level arrangements and our firm’s requirements in relation to gifts and hospitality payments.

Oversight

Our firm’s senior management will have the overall responsibility to ensure that our firm operates remuneration practices that aim to ensure that the firm acts in the best interests of our firm’s customers at all times and in line with the FCA’s rules and guidance.

The senior management of our firm will be responsible for the day-to-day implementation of our remuneration policy and the monitoring of compliance risks related to this policy.

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Remuneration Performance Disclosure

Name and title of person responsible - Wes Wilkes - CEO

Period covered by the review - 1^st June 2023 – 1^st June 2024

The objectives of the Policy are:

•     To attract, retain and motivate talented employees of the quality required to manage the business successfully, whilst ensuring that remuneration is not excessive or detrimental to the health of the firm as a whole, including its clients.

•     To motivate and reward good, long term performance.

•     To meet relevant regulatory requirements, including the requirements of the FCA Remuneration Code

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Definition of remuneration  

For the purpose of this policy, ‘remuneration’ means all forms of financial or non-financial benefits or payments made by our firm (directly or indirectly) to individuals who provide investment services to our clients. For example: cash, shares, options, pension contributions, wage increases, promotions, health insurance. Dividend distributions to working shareholders are not considered as part of the remuneration policy.

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Our firm’s remuneration and incentive schemes  

Any remuneration package or incentive scheme we have in place, or may introduce in the future, will not:

·      Remunerate or assess performance of our staff in any way that conflicts with our duty to act in the best interest of our clients.

·      Include any arrangement by way of remuneration, sales targets or otherwise, that could provide an incentive to our staff to recommend a particular product to a retail client where a different product could be offered that would better suit their needs

·      Create a conflict of interest that would encourage individuals to act against the interests of any of our clients

·      Be solely or predominately based on quantitative commercial criteria

And:

·      Will ensure the fair treatment of our clients and the quality of service provided

·      Will take appropriate qualitative criteria into account

·      Maintain a balance between fixed and variable remuneration so the structure doesn’t favour our firm or staff over those of our clients

Bonus Schemes

The majority of staff remuneration is via salaried arrangement only.

Whilst there is a bonus structure in place to incentivise critical staff further, based on both financial and non-financial performance, payments under this structure are not guaranteed and are made entirely at the discretion of the Company Board. Payment of such incentives is dependent on the individual performance of staff members relative to their key functions and job descriptions. Key performance indicators for staff are determined on an individual basis, subject to the specific role and include assessment of adherence to company processes and controls in respect of risk and performance.  

IronMarket Ltd has a comprehensive Conflicts of Interest policy in place. All staff subject to the remuneration policy complete an annual Declaration which confirms that they have read and understood the policy and will notify any conflicts to the CEO/Compliance Officer.

There are no Executive Incentive Schemes in place.

Senior management responsibilities

Our management body / senior management team:  

·      Has approved this policy and will be required to approve all future changes

·      Is responsible for the day-to-day implementation of this policy

·      Is responsible for the monitoring of compliance risks related to this policy

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Reviewing this policy

To ensure this policy continues to accurately reflect the process we follow, the Compliance Officer will review this policy on an annual basis.