Vintage Asset Management Limited
MIFIDPRU 8 ANNUAL DISCLOSURE STATEMENT
For the year ended 31st March 2025
Introduction
Vintage Asset Management Limited as a firm is required by the Financial Conduct Authority (FCA) to disclose information under the Investment Firms Prudential Regime (IFPR) which came into effect on 1st January 2022 for UK firms authorised under the Markets in Financial Instruments Directive (MiFID). The FCA has implemented the regime as prudential regulation within the MIFIDPRU section of the FCA Handbook and this statement covers the firm’s requirements under MIFIDPRU 8 for the year ending 31st March 2025. We publish our statement via the firm’s website rather than in the annual Report & Accounts.
Scope and application
Vintage Asset Management is a MIFIDPRU investment firm that is authorised and regulated by the FCA with number 489408. The firm is classified as a Small and non-interconnected entity (SNI) while we now provide this disclosure not as an individual firm and instead on the basis of an investment group following the establishment of a holding company Portugal Holdings limited, which owns 100% of the shares in the firm. Portugal Holdings has no other assets or liabilities aside from a loan into the firm nor does it trade on its own account so the approach reflects the position of the firm itself, while we keep under review the wider considerations of the related Vintage companies.
Remuneration policy and practices
We are required, under our designation as an SNI MIFIDPRU firm under IFPR, to make a disclosure of the following remuneration information regarding our remuneration policy and practices, covering both qualitative and quantitative matters.
For qualitative disclosures, we address our approach to remuneration for all staff, the objectives of any financial incentives and the procedures or the governance in relation to our remuneration policies and practices. This includes, as applicable, the make-up and mandate of a remuneration committee and the details of any external consultants we have engaged. The review is intended to enable a clear understanding of the risk profile of our firm, an overview of any incentives, the different components of our remuneration, a categorisation of those components as fixed or variable and a summary of the financial and non-financial performance criteria we use to assess performance.
The board of directors form the remuneration committee and acknowledge that it is their responsibility to ensure that the firm’s remuneration and dividend policies, practices and procedures are:
– in line with the firm’s business strategy, objectives and long-term interests;
– consistent with sound and effective risk management and not expected to encourage excessive risk-taking;
– appropriate to attract, motivate and retain suitable staff;
– representative of the underlying performance of the business and not expected to reward individuals for poor performance; and
– inclusive of measures to avoid potential conflicts of interest.
The firm has reviewed its remuneration policies to ensure that they remain appropriate, including taking into account considerations under the Consumer Duty. We consider the risk profile of the firm to be moderate, given its business as a discretionary fund manager and the nature of its portfolios; we do not consider this to have changed with the growth in the platform-based proposition, with the acquisition of business assets in 2023 and with the investment into the company in 2024.
The principal component of remuneration for the firm’s full-time staff is a base salary that we believe to be broadly in line with, if probably still lower than, that for those in similar firms even after a step change in pay levels for most of the staff in 2025. The firm pays into an independent pension scheme for its employees as required and it provides a number of benefits, such as healthcare and travel insurance, which account for a small proportion of the total.
The firm determines remuneration with reference to a number of factors including the performance of the individual and the firm as well as the individual’s adherence to the Company’s risk management and compliance procedures. The firm has in place two bonus schemes. The first, for the Investment Director, pays a fixed amount which is proportionate to the individual’s salary and replaces a prior scheme for the managing director that paid in the year a bonus equivalent to 10% of the operating profit. The second scheme, for the wider team, pays an amount which we review each year and which is subject to the meeting of specific targets that include delivering satisfactory investment returns, meeting client requirements on matters such as income payments and minimising trading errors. We believe that these schemes have been appropriate in their size, given that the variable component of any remuneration is a smaller proportion of the whole, and in their approach, in that they are aligned with achieving good outcomes for clients and avoiding potential conflicts of interest. We have a focus on ensuring stability in the business and we do not have in place schemes that provide an incentive to aim for an inappropriate level of growth. The Investment Director continues to hold shares in the company, now indirectly, as might other members of the team, which we believe should help with the retention of such staff.
In the year to 31st March 2025 certain directors received variable remuneration that was linked to the investment into the firm and to the EMI schemes that the firm had in place.
The firm did not pay dividends to shareholders in the year to 31st March 2025 and it does not have a current dividend policy.
The firm will award variable remuneration in the form of bonuses and dividends on consideration of the relevant factors, together with an assessment of any current or potential risks to the business in the context of these payments.
The remuneration committee believes that the policies, procedures and practices relating to remuneration and dividends have been aligned with the objectives of the business and the avoidance of excessive risk, as well as the performance and success of the assets under management.
For quantitative disclosures, the firm’s Code staff, all of whom have been approved by the FCA under section 59 of the Financial Services and Markets Act 2000 to perform a senior management function, received aggregate remuneration of £753,487 during the year ended 31st March 2025.
The split between the fixed and variable remuneration for our performance year-end, which is the same as our financial year-end, is as follows:
Fixed remuneration
(including employers’ National Insurance and workplace pension contributions): £412,638
Variable remuneration
– bonuses (including employers’ National Insurance) : £340,849
Total remuneration: £753,487