1. Overview
This document comprises the Remuneration Policy of TAP Securities Ltd ("TAP Securities" or the “Firm”).
TAP Securities is an FCA authorised and regulated MiFID investment firm. As such, it is subject to the UK prudential framework under the Investment Firm Prudential Regime ("IFPR") and the MiFID Remuneration Code, as detailed in SYSC 19G of the FCA's Handbook (the "Remuneration Code").
TAP Securities is a Small and non-interconnected MIFIDPRU Investment Firm (“SNI” or “Class 3 Firm”) and is therefore not subject to the full extent of the Remuneration Code (see SYSC 19G.1.7G, which outlines provisions applicable to SNI’s)
2. Governance
The Firm’ Directors (“Directors”) are ultimately responsible for establishing and embedding effective remuneration policies and procedures.
The Directors ensures that there is an appropriate balance between fixed and variable remuneration for all employees. All performance-related awards, financial and non-financial, are reviewed and approved by the Directors.
The Directors review the remuneration policies and on an annual basis to ensure that it is effective and fit for purpose. This includes ensuring that the remuneration policy aligned with the Firm’s long term business strategy, values and TAP Securities’ clients and customers.
3. Risk management
The structure of the TAP Securities’ remuneration policy is designed to ensure sound and effective risk management through:
• a clear policy and procedure for setting variable remuneration incl. individual, team and firm performance;
• alignment with the Firm’s business strategy, values and long term-goals;
• alignment with the protection of Firm’s clients, customers and investors;
• ensuring variable remuneration does not undermine the viability and sustainability of Firm and its ability to meet its capital and liquidity requirements;
• considering the implications of awarding variable remuneration through a multi-year framework; and
• ensuring financial and non-financial incentives do not promote excessive risk-taking.
The Directors review its policies and procedures, at least annually, to ensure they have been designed and implemented effectively and continue to be fit for purpose.
The Directors are ultimately responsible for the remuneration within the Firm and can exercise its discretion to adjust remuneration where it considers any award to be in breach of sound and effective risk management.
4. Gender neutral remuneration policies and practices
The Directors ensure that remuneration of employees is not biased by gender, race, ethnic origin, political views, sexual orientation, age, disability or any other discriminatory factors. The Firm does not tolerate any form of discrimination.
The remuneration policy is gender neutral, this means that it is based on equality for male and female workers for equal work or work of equal value. TAP Securities strives to promote equality within the Firm with respect to employment, career development, promotion and equal pay.
Compliance with the Equality Act 2010 is integral to the remuneration policy and procedures. All remuneration decisions are based on the individuals experience, performance and conduct.
During the annual review, the Directors consider the equity and equality of all remuneration decisions.
5. Conflicts of interests
The Firm has adopted policies and procedures aimed at mitigating any potential conflicts that may arise between staff members and the Firm and its clients.
TAP Securities maintains a Conflict of Interests Register which includes potential conflicts relating to remuneration, as well as the procedures that have been implemented to mitigate these conflicts.
In circumstances where the Firm is unable to mitigate a conflict, the conflict is disclosed to its clients and is included in the Risk Register. Where appropriate, additional capital is assigned to ensure that if such a risk were to materialise, the business would be able to absorb any consequences.
6. Remuneration components
The remuneration components are described as below:
Fixed remuneration
Base salary
• Reviewed annually by the Directors
Pension
• Fixed percentage of base salary paid as defined contribution
Benefits
• Private Healthcare
Variable remuneration
Short term incentive
• Annual bonus and/or transaction-related compensation
The Firm does not award discretionary pension benefits or other non-cash perquisites.
6.1. Fixed remuneration
Employees are awarded competitive fixed remuneration based on the role requirements, individual experience and industry benchmarking. This allows TAP Securities to attract and retain the right calibre of employee.
The fixed remuneration for employees consists of:
• Base salary: remunerates for role and position within the Firm.
• Pension: aims to ensure an appropriate standard of living for employees in retirement.
• Benefits: supplements the fixed remuneration offering in line with market.
6.2. Variable remuneration
Variable remuneration is awarded in a manner which promotes sound risk management, does not incentivize excessive risk-taking and aligns the employees with the long-term business strategy and interests of its clients, customers and investors.
The Firm does not utilise a variable remuneration cap or ratio.
TAP Securities pays annual discretionary variable remuneration to eligible employees. All full-time employees are assessed against the relevant variable remuneration criteria to determine their eligibility for and potential size of variable remuneration.
Variable remuneration is determined at the end of the relevant performance year for junior employees and may be paid at different times during the year. Variable remuneration for senior employees may be determined at the conclusion of a transaction and paid at that time.
Employees must remain employed by the Firm on the scheduled payment date to receive the bonus.
7. Variable remuneration criteria
7.1. Individual criteria
The remuneration decisions for individuals are made based on a combination of factors. The relative importance of a particular factor may vary depending on the role and seniority of the individual:
• Individual performance against the specifications of the role
• The level of responsibility and seniority within the role
• Overall performance of the relevant business function or unit
• Adherence to the Firm’s purpose, values and culture
• Adherence the Firm’s risk management and compliance framework
• Compliance with the internal conduct policies and procedures
7.2. Firm wide criteria
Firmwide remuneration policy is based on a combination of:
• The long-term sustainability and viability of the Firm incl. looking through the business and economic cycles
• The business performance and results of the Firm against the strategic objectives
The Firm ensures that individuals performing Control Function are senior members of staff who are competent in making decisions that focus on the best outcome for clients, and in the long-term interests of the Firm.
Where there is an actual or potential conflict, this is documented as required by the Firms Conflicts of Interest Policy and appropriate controls are put in place.
8. Personal investment strategies
The Firm is privately held and does not have listed shares; therefore, they are not readily realisable, and it would be realistically possible to use personal hedging strategies or liability-related contracts to undermine the risk alignment of the remuneration policy.
For the avoidance of any doubt, staff are not permitted to use strategies to circumvent or mitigate any aspect of the Remuneration Policy.
Additionally, such trading activity is captured within the Firm’s personal account dealings policy. Employees are required to obtain pre-clearance for any trade, which allows the control function to provide oversight.
9. Avoidance of the MIFIDPRU Remuneration Code
TAP Securities’ remuneration policies and procedures are designed to ensure full compliance to the SYSC 19G Remuneration Code. All remuneration payments are made through standard payroll systems and approved by the Directors at least annually.
