As at 31 December 2022
This is a MIFIDPRU 8 remuneration disclosure document of Natural Resources Global Capital Partners (the “Company” or “NRG”). NRG is classified as a SNI firm.
The board of directors determine remuneration policy to reflect the Company’s objectives for good corporate governance as well as sustained and long-term value creation for shareholders. In addition, it ensures that:
- the Company is able to attract, develop and retain high-performing and motivated employees in a competitive international market;
- employees are offered a competitive and market aligned remuneration package appropriate for an early-stage financial advisory business;
- employees feel encouraged to create sustainable results and that a link exists between shareholders of the Company, clients, employee interests and the wider Group’s interests.
The policy is focused on ensuring sound and effective risk management through:
- a stringent governance structure for setting goals and communication these goals to employees;
- alignment with the Company’s business strategy, values, key priorities and long-term goals
- alignment with the principle of protection of clients within the overall framework of the Company ensuring prevention of conflicts of interests; and
- ensuring that the total bonus pool does not undermine the Company’s capital base.
The Remuneration Code applies to all NRG staff. In particular, Remuneration Code Staff are those staff with performance linked variable pay and comprise staff that hold significant influence functions, are senior management, risk takers, staff who undertake controlled functions and employees receiving remuneration on a par with senior management.
The staff performance appraisal year runs from 1 January to 31 December in each year.
At the annual performance and appraisal interview, the individual employees and managers evaluate and document performance in the past year and set new goals. Decision on adjustment, if any, of the employee’s fixed salary or on annual performance-based pay are made on the basis of this appraisal.
The various remuneration components are combined to ensure an appropriate and balanced remuneration package. The five remuneration components are:
- Fixed remuneration (including fixed supplements);
- Performance based remuneration (variable remuneration);
- Pension schemes, where applicable;
- Other benefits in kind;
- Severance payments, where applicable.
Fixed remuneration primarily reflects a staff member’s professional experience and organisational responsibility as set out in the staff member’s job description, local market conditions and terms of employment. The fixed remuneration is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration primarily reflects a staff member’s long-term performance as well as performance that exceeds the staff member’s job description and terms of employment. This performance-based remuneration motivates and rewards high performers who significantly contribute to sustainable results, perform according to set expectations for the individual in question, strengthen long-term client relations, and generate income and shareholder value/value to the overall Company. Performance based remuneration may be disbursed as cash bonus, shares, share based instruments, including conditional shares and other generally approved instruments, all on the basis of applicable local legislation. NRG may in its absolute discretion award staff a bonus of such amount as it may in its absolute discretion determine, taking into account specific performance targets to be notified to members of staff. Any bonus payment to staff shall be purely discretionary and shall not form part of the contractual remuneration.
Pension schemes guarantee employees a basic cover in the event of critical illness or death and pension payment on retirement. The Company is required to commence automatic pension scheme enrolment on August 1st, 2017. In general, as of this date or earlier subject to a decision by Board of Directors, employees will be covered by defined contribution plans with a pension insurance company.
Other benefits are awarded on the basis of individual employment contracts and local market practice.
Severance payments are payable in accordance with relevant local legislation and applicable collective agreements. For the avoidance of doubt and subject to applicable legislation and collective bargaining agreements, no severance payment may include any variable remuneration, pension or other benefits.
Performance-based variable remuneration
Performance-based pay is awarded ensuring:
- an appropriate balance between fixed and performance-based components;
- that the fixed component represents a sufficiently low proportion of the total remuneration to make payment of the performance-based component possible; and
- that material risk takers cannot dispose of the share-based instruments for an appropriate period of time after transfer of the instruments to the risk-taker.
Performance-based remuneration (pools or pay-out) must be based on an assessment of the Company’s results and a number of KPIs reflecting the Company’s strategic key priorities. E.g. the KPIs cover the following:
- profit before tax;
- assessment of risk-adjusted return
- client satisfaction;
- compliance with internal business procedures; and
- expected loss.
Performance-based pay is granted to reflect the Company´s financial results and the individual employee’s performance. Further, both financial and non-financial factors shall be taken into consideration when determining the individual´s bonus, i.e. compliance with internal guidelines and procedures, including client related guidelines. A discretionary assessment is always made to ensure that other factors – including factors which are not directly measurable – are considered. As an overall starting point the Company ensures a balanced split between fixed salary and variable pay.
NRG ensures the assessment of performance is linked to its risk management and sustainable performance. This is set in a multi-year framework.