GE Capital Limited     
IFPR Disclosure Statement

I. Introduction to GE Capital Limited

This document is designed to meet the disclosure obligations of GE Capital Limited (the “Firm”) as set out in the Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”) of the Financial Conduct Authority (“FCA”) handbook of rules and guidance (the “FCA Handbook”).  .

For the purposes of MiFIDPRU, the Firm is categorised as a small and non-interconnected firm (“SNI Firm”).

The disclosures set out below are made pursuant to MIFIDPRU.  This disclosure document has been prepared by the Firm in accordance with the requirements of Chapter 8.6 of MIFIDPRU.  The Firm issues such disclosures at least annually. Unless otherwise stated, all information is provided as at 01 April 2023.

II. Remuneration Disclosure Requirements

PART A: QUALITATIVE DISCLOSURES

1. Objectives and Approach of the Firm’s Financial Incentives

The Firm’s financial incentives aim to create a direct link between reward and performance and to incentivise employee in a manner that is consistent with  the Firm’s risk profile, including potential conflicts of interest. The Firm’s remuneration structure is evaluated regularly to ensure its continued alignment with the Firm’s regulatory requirements. The objective of the Firm’s remuneration structure is to align individual and team contributions with performance objectives in a manner that:

  • is consistent with and promotes sound and effective risk management;
  • does not encourage excessive risk taking;
  • recognizes that the Firm does not hold client money or have assets under management and generally does not provide ongoing investment advice once a particular transaction has completed, and therefore the Firm has a limited risk profile;
  • includes measures to avoid conflicts of interest in accordance with the Firm’s policies, including the Conflicts of Interest Policy which is supplemented by various procedures; and
  • is in line with the Firm’s business strategy, regulatory obligations, objectives, values, and long-term interests.

2. Fixed and Variable Remuneration

In accordance with regulatory requirements, total remuneration is determined in light of:

  • individual performance both commercially and with reference to the appraisal profess and methods detailed in the Firm’s Remuneration Policy;
  • the performance of the relevant business unit; and
  • the results of the Firm as a whole.

The assessment of performance to determine variable remuneration takes into account financial as well as non-financial criteria. The non-financial criteria are intended to form a significant part of the performance assessment process (e.g., consideration of the individual’s employees conduct); and evaluate the individual’s performance in relation to effective risk management and compliance with the Firm’s policies and procedures (including those designed to meet regulatory requirements). 

3. The decision-making process and governance around the Remuneration Policies and Practices 

The Firm has set up governance processes aimed at ensuring the oversight of rewards, management of any potential conflicts of interests, and the review of the alignment between rewards and performance.

  • The Firm’s Remuneration arrangements are reviewed and approved annually by the Firm’s Executive Board.  The remuneration arrangements are subject to internal review by Human Resources, Finance, the Senior leadership team, and Legal & Compliance. 
  • Remuneration decisions are made by the Firm, following procedures implemented by the Human Resources department which include consultation with line managers of employees and presentation and approval by senior leadership. Such remuneration decisions include application of relevant financial and non-financial criteria (as further described herein).
  • Legal & Compliance and the head of HR liaise to discuss compliance and conduct matters as relevant to the Firm and specific employees as part of the appraisal process. 

As the Firm is a SNI Firm, it does not have a remuneration committee.

 4. Key Characteristics of Remuneration Policies and Practices

The Firm has adopted policies and procedures which:

  1. are designed to ensure that the Firm maintains and applies a sound and prudent remuneration process which are designed to ensure that it does not impair compliance with any of its legal and regulatory obligations; and
  2. have been prepared in line with the Firm’s business strategy, objectives, values and interests, including consideration of the Firm’s risk appetite and strategy, the Firm’s culture and values, and any long-term impacts on the business;
  3. are intended to identify and manage any conflicts of interest and promote sound and effective risk management and prudent risk taking.

 

COMPONENTS OF REMUNERATION:

The Firm provides the following categories of remuneration to its employee, which may be fixed or variable as specified below:

– fixed base salary ; and       
– non-discretionary benefits (e.g. - medical insurance, car allowances)     
– discretionary bonuses (variable).

 

SUMMARY OF REMUNERATION CRITERIA:

Remuneration is based on an assessment of both financial and non-financial criteria generally including the following elements:

Criteria Pertaining to the Firm:

– the performance and profitability of the Firm;     
– the Firm’s risk appetite and strategy;     
– the Firm’s desire to identify and manage any conflicts of interest; and     
– the Firm’s culture and values.

Criteria Pertaining to Individual Business Units:

– the performance and profitability of the relevant business unit;     
– the objectives set for the relevant business unit; and      
– where applicable, the long-term effects of the investment recommendations made by the business unit.      
In line with the Firm’s regulatory requirements, personnel in control functions will be compensated, amongst other factors, by reference to the objectives linked to those functions (i.e., independently of the performance of the business areas they control).

Criteria Pertaining to Individuals:

– the individual’s responsibilities and history with the Firm;     
– performance in relation to the individual’s job description and terms of employment;     
– the individual’s compliance with the Firm’s policies and procedures; and     
– the individual’s adherence to the Firm’s culture and values.

 

PART B: QUANTITATIVE DISCLOSURES

Total Remuneration (Fixed and Variable)

The Firm paid a total amount of remuneration to all employees of £6,563,561.46 in 2022 , the last year of audited figures, comprising in fixed remuneration and in variable remuneration.