Remuneration Policy Summary

Mitchell & Mitchell Asset Management Ltd (MMA)

1. Purpose

This Remuneration Policy outlines how Mitchell & Mitchell Asset Management Limited ("MMA") manages remuneration across the firm. It is designed to ensure that MMA’s remuneration practices:

  • Align with the firm's strategic objectives and values

  • Encourage responsible business conduct and good client outcomes

  • Comply with the requirements of the FCA Handbook, including SYSC 19G (MIFIDPRU Remuneration Code), Consumer Duty, and relevant provisions under MiFID II

  • Avoid conflicts of interest and promote sound risk management

This policy supports MMA’s commitment to treating clients fairly and maintaining a culture that prioritises long-term value over short-term gains.

2. Scope

This policy applies to all MMA staff, including senior management, risk-takers, control functions, and any staff whose professional activities have a material impact on the firm’s risk profile (known as “Material Risk Takers” or MRTs).

3. Key Principles

3.1 Alignment with Strategy and Risk

Remuneration structures are designed to:

  • Support MMA’s long-term business objectives

  • Reflect individual and company performance

  • Avoid incentives that encourage excessive risk-taking

  • Maintain the integrity of financial markets and investor trust

3.2 Client-Centric and Duty-Aligned

In line with the FCA’s Consumer Duty, remuneration is designed to encourage behaviour that:

  • Supports good outcomes for retail clients and advisers

  • Enhances the value, understanding, and suitability of our services

  • Does not reward poor performance or decisions detrimental to clients

3.3 Proportionality

MMA applies a proportionate approach to remuneration in line with its size, internal organisation, nature and complexity of its activities.

4. Fixed vs. Variable Remuneration

  • Fixed remuneration is based on an individual’s role, responsibilities, experience, and market benchmarks. It represents a sufficiently high proportion of total pay to allow for flexibility around variable compensation.

  • Variable remuneration (e.g. discretionary bonuses) is performance-based, non-guaranteed, and awarded only where sustainable and risk-aligned. It is assessed against both:

    • Quantitative factors: including MMA’s financial results, operational outcomes, and regulatory compliance

    • Qualitative factors: including conduct, adherence to risk procedures, and contribution to positive client outcomes

There is no direct link between sales volumes and variable remuneration.

5. Risk Management and Governance

  • The policy is reviewed and approved annually by MMA’s Board.

  • The policy is aligned with MMA’s risk management framework, internal control environment, and governance structure.

  • Control functions (e.g. compliance, risk) are independent and not remunerated based on the performance of the business areas they oversee.

  • Where appropriate, MMA applies deferral, malus, and clawback provisions for variable remuneration in line with regulatory expectations.

6. Disclosure and Transparency

A summary of this policy is publicly available on the Mitchell & Mitchell website. Further information may be provided to clients or regulators on request, in line with MMA’s legal and regulatory obligations.

Version: May 2025
Approved by: MMA Board of Directors
Next Review Due: May 2026 or upon regulatory update