MIFIDPRU Public Disclosure Document
PAMPLONA CAPITAL MANAGEMENT LLP
Date as at 17 NOVEMBER 2023
For the period 1 JANUARY 2022 TO 31 DECEMBER 2022
Overview and summary
Pamplona Capital Management LLP (the ‘Firm’) is regulated by the Financial Conduct Authority (“FCA”) as a Markets in Financial Instruments (“MiFID”) firm and subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook.
For the purposes of MIFIDPRU, the Firm has been classified as a small non-interconnected (“SNI”) firm.
The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.
This Public Disclosure Document has been prepared based on the audited financials as at 31 December 2022, covering the financial period 1 January 2022 to 31 December 2022.
The Firm’s main business activity is to provide investment advice in relation to the assets of a number of private equity funds.
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).
In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:
The Firm’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categories as either fixed or variable remuneration.
Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration is based upon staff members performance or, in exceptional cases, other conditions.
Performance reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment, and
The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.
The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.
All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded.
As an SNI firm and in accordance with MIFIDPRU 8.6.8, Pamplona Capital Management LLP is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.
For the performance year ending 31 December 2022:
Total fixed remuneration awarded £3,631,400
Total variable remuneration awarded £5,946,256
Total remuneration awarded £9,577,656