MIFIDPRU Annual Disclosure

Annual disclosure for IBOSS Asset Management Limited (IAM) for year ending 31 December 2022.

Introduction

The Investment Firms Prudential Regime (IFPR) came into effect on 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 IBOSS Asset Management’s annual public disclosures as required under MIFIDPRU 8 for the year ending 31 December 2022.

IBOSS Asset Management Limited (IAM) is owned by Kingswood Group.

Scope and application of disclosure

These disclosures relate to IBOSS Asset Management Limited (IAM), an SNI MIFIDPRU Investment firm authorised and regulated by the FCA.

IAM 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:

Remuneration policy and practices

1. Qualitative disclosures

– Our approach to remuneration for all staff
– The objectives of our financial incentives
– The decision-making procedures and governance surrounding the development of the remuneration policies and practices our firm is required to adopt in accordance with the MIFIDPRU Remuneration Code, to include, where applicable:

The composition of and mandate given to the remuneration committee and
Details of any external consultants used in the development of the remuneration policies and practices

– The key characteristics of our remuneration policies and procedures to enable

An understanding of the risk profile of our firm and/or the assets it manages and
An overview of the incentives created by our remuneration policies and practices

– The different components of our remuneration, together with the categorisation of those remuneration components as fixed or variable

– A summary of the financial and non-financial performance criteria used across the firm, broken down into the criteria for the assessment of the performance of

The firm,
Business units, and
Individuals

2. Quantitative disclosures

– The total amount of remuneration awarded to all staff is split into fixed v variable remuneration.

1. Qualitative Disclosures

Our policy is designed to be proportionate based on the size of our firm and the scope of our regulated activities.

Our policy reflects our firm’s culture and our ability to deliver good client outcomes to our clients.

Our firm provides the following regulated activities to both retail and professional clients

Discretionary Fund Management Model Portfolio Service

Our remuneration packages and incentive schemes are designed to;

Promote sound and effective risk management
Ensure conflicts of interest are avoided
Encourage responsible business conduct
Promote risk awareness and prudent risk-taking
Be consistent with our firm’s culture and values
Provide good outcomes for consumers

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

Remunerate or assess the 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 Financial Adviser that impacts the 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.

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

We pay all our staff fixed remuneration. There is a discretionary bonus scheme in operation based on the profits of IAM. Any discretionary payments are made at the discretion of the Board of Directors and take clear performance indicators into account. Any discretionary payments to any staff will not be made without input from the SMF16 compliance function to ensure compliance with the requisite regulatory requirements and prevention of conflicts is factored into the decision-making.

We will discourage individuals from acting against the interests of any of our clients by ensuring no incentive is rewarded for promoting or selling one product or service over the other.

IAM utilise the services of IBOSS Limited for administration support, for which we have a contract in place. Staff performance is reviewed and taken into consideration.

IAM key objective is to grow the business organically, ensure we attract the right key personnel to the Company and retain them, ensure the business embraces regulatory principles and rules but protects long-term sustainable financial stability and profitability.

Our decision-making procedures and governance surrounding the development of IAM remuneration policies and practices.

Kingswood Group oversee IAM. Kingswood Group relies on the Group Nomination and Remuneration Committee, which responsible for considering Board appointments, reviewing Board structure, size and composition and identifying the need for Board appointments by reference to the balance of skills, knowledge and experience on the Board and the scale of the Enlarged Group.

The Nomination and Remuneration Committee is also responsible for establishing a formal and transparent procedure for developing policy on executive remuneration and to set the remuneration packages of individual directors.

This includes agreeing with the Board the framework for remuneration of the Group Chief Executive, all other executive directors, the Company Secretary and such other members of the executive management of the Company as it is designated to consider. It is also responsible for determining the total individual remuneration packages of each director including, where appropriate, bonuses, incentive payments and share options. No director will play a part in any decision about his own remuneration. The Nomination & Remuneration Committee also plays a crucial role in succession planning by analysing the Board’s needs and planning accordingly.

There is an Executive Committee: Executive responsibility for ensuring the overall performance of the firm and its strategy.

Risk Management Framework

IBOSS Asset Management Limited maintain and has ownership and responsibility for its risks.

Identifying and assessing risks
Managing & and controlling risks
Measuring risks and developing key risk indicators
Mitigating risk and balancing reward
Reporting and escalation

Kingswood Group maintains an independent 2nd line Risk & Compliance function that provides support and independent challenge to the first line. Responsibilities include:

Design & operation of the Risk Framework
Risk Assessment
Risk Appetite
Risk reporting
Challenge and oversee the adequacy of controls & action plans

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.

Fixed remuneration – all staff
Discretionary bonus – all staff
Sales bonus – Business Development Staff
LTIP – certain Management/Senior Staff

The Business Development Managers, who receive a sales bonus based on net assets under management. Their objectives are to promote our OEIC and DFM MPS and to manage the relationship with the existing firms who use our products and services. Their performance is monitored and reviewed. By basing any incentive on the net assets, it protects the business against market downturns and takes account of any business reductions, incentivising long-term retention. plus, we have the non-financial KPI’s; complaints are monitored, client feedback and servicing and competencies in achieving their objectives.

We have the following executive schemes in place:

Long-Term Incentive Plans incentive for some Senior Managers/staff;

The structure of the scheme’s awards are based on two conditions; group EBITA and the share price.
It is a three-year scheme ending December 2024. The scheme’s performance period is half-yearly. A new performance commences every six months based on the target EBITDA. Shares are awarded each half year if this is reached. At the end of 2024, the share needs to be 39 p or more for any payment to be made on top of achieving the target
The scheme is due for review when the current one ends in December 2024.

Discretionary bonus

IBOSS Limited, overseen by Kingswood Group, currently sets the variable remuneration of its staff in a manner that considers individual performance, the performance of the individual’s business unit and the overall results of IAM.

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. The staff are employed by IBOSS Limited, for which we have a contract for services; the current fixed remuneration allocated in the ICARA is below.
For our year ending 31 December 2022, our total remuneration is split as follows:

Type of Remuneration	Amount £000s
Fixed Remuneration	£ 543,892
Variable Remuneration	£ 34,629
Total Remuneration	£ 578,521