MIFIDPRU Remuneration Disclosure
Overview and summary
Hassium Asset Management LLP (“Hassium” or “the firm”) is a wealth management business providing discretionary portfolio management services and advisory services to high-net-worth individuals and wealthy families. Hassium is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom (UK) under Firm Reference Number 458250.
Hassium is subject to the UK Investment Firms Prudential Regime (IFPR). Under the IFPR and specifically the FCA’s Prudential Sourcebook for MiFID firms (MIFIDPRU), Hassium has been classified as a Small Non-Interconnected (SNI) MIFIDPRU investment firm. Hassium is subject to the FCA Rules on remuneration as contained in the FCA’s MIFIDPRU Remuneration Code located in SYSC 19G of the FCA’s Handbook.
As an SNI firm (without additional Tier 1 instruments in issue), Hassium is required (among other things) to publish a summary disclosure covering its remuneration arrangements under the Financial Conduct Authority (FCA) MIFIDPRU 8.6 Rules.
The performance reference date is from 1 April to 31 March (Hassium’s financial year) and this Remuneration Policy Statement disclosure is in respect to the performance period 1 April 2023 to 31 March 2024. It has been prepared on the audited financials as of 04 July 2024.
Approach to Remuneration for all staff
Employees have the opportunity to share in the success of the firm in years of good performance and also accept reduced levels of variable (bonus) pay in times of poor performance or losses. Hassium does not remunerate or assess the performance of its staff in a way that conflicts with its duty to act in the best interests of its clients. Hassium does not make any arrangement by way of remuneration, sales targets or otherwise that could provide an incentive to its staff to recommend a particular financial instrument to a client when the firm could offer an alternative financial instrument which would better suit the client’s needs. Hassium is mindful of ensuring that its remuneration policy and practices do not lead to a conflict of interest or incentivise its staff to act in a manner that favours their own interests or the firm’s interests to the potential detriment of any client or potential client.
Remuneration policies and practices
Hassium’s Remuneration Policy provides a framework to ensure all staff are fairly and competitively rewarded in return for a high level of service to the firm and is clients. In setting remuneration levels Hassium recognises the importance of attracting and retaining experienced staff.
Hassium pays all its staff remuneration, which comprises a fixed element and can also include a variable discretionary element. All remuneration is overseen by Hassium’s partners. An employee’s fixed remuneration element is based on pre-determined criteria. It is non-discretionary, transparent, permanent for the year and subject to an annual review. The fixed remuneration reflects a staff member’s professional knowledge and experience, their skills, the requirements of the particular role for which they are employed as set out in the staff member’s job description.
All staff are eligible for variable remuneration in the form of an annual discretionary bonus. This bonus is at the discretion of Hassium’s partners. The variable element aims to motivate and reward high performers who strengthen long-term client relations, generate income and increase customer value. The performance will be assessed on the basis of the fulfilment of various business targets or the attainment of certain financial and nonfinancial objectives. Such targets will be set by Hassium’s partners. There are no staff members paid only variable discretionary remuneration.
Annual and semi-annual reviews are in place to assess whether an individual has achieved their goals and objectives; met the core competencies required in their role; undertaken all required training and assess future development needs. The reviews are in compliance with the Financial Conduct Authority (FCA) requirements and include an assessment of competence and fitness and propriety for roles that fall under the Senior Managers & Certification Regime (SMCR) as well as those in Hassium’s business that are outside the SMCR.
Hassium deems the following non-financial qualitative metrics to be important in ensuring remuneration and similar incentives will not be primarily based on commercial criteria and therefore considers them in employee reviews:
• Meeting Hassium’s regulatory obligations.
• Adherence to the compliance and governance procedures that are in place, including relevant regulations.
• Fair treatment of clients and the quality of services provider to clients.
• Measures relating to building and maintaining positive external relationships with all Hassium’s stakeholders, and customer feedback.
• Prompt and transparent response on regulatory compliance attestations and completion of all continuing professional development.
• Good teamwork and culture, supporting each other, and working together.
Hassium does not discriminate against anyone on the grounds of any of the following characteristics (without limitation) age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion/belief, sex (gender) and sexual orientation.
Hassium’s compliance consultants provide comments and input at least on annual basis into its Remuneration Policy arrangements to ensure it is balanced and proportionate to nature, scale and complexity of the risks inherent in Hassium’s business model and regulatory activities; does not lead to any undue risk taking by any employees; and that it is compliant with Financial Conduct Authority (FCA) relevant requirements.
The composition and breakdown of Hassium’s remuneration for the financial year ended 31 March 2024 is:
Staff remuneration (GBP)
Fixed remuneration £432,570
Variable Remuneration £30,726
Total Remuneration £463,296