Introduction

The following disclosure is made by Omni Advisory pursuant to the FCA’s Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”) in respect of the financial year ended [31st December 2022].

Omni Advisory is authorised and regulated by the FCA in the UK as a Collective Portfolio Management Investment (“CPMI”) firm, and is therefore subject to the FCA’s Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”). Omni Advisory meets all the criteria for small and non-interconnected (“SNI”) investment firms, detailed in MIFIDPRU 1.2, and, so, is categorised as an ‘SNI investment firm’.

As an ‘SNI investment firm’ authorised and regulated by the FCA, Omni Advisory is required under Chapter 8 of MIFIDPRU to publish key information in order to assist users of its accounts and to encourage market discipline. In accordance with MIFIDPRU 8.1, as an ‘SNI investment firm’ the information which Omni Advisory is required to publish is limited to information relating to its remuneration policies and practices (per MIFIDPRU 8.6).

This disclosure has been prepared by Omni Advisory in accordance with the requirements of MIFIDPRU 8 and has been approved by the directors of Omni Advisory. Unless otherwise stated, all disclosures pertain to the financial year ended 31^st December 2022 and are seen as complimentary to Omni Advisory’s published financial statements for that period, its implementation of other MIFIDPRU rules, and its internal capital adequacy and risk assessment (“ICARA”) process.  Omni Advisory’s MIFIDPRU disclosures are published alongside the audited annual accounts.

Remuneration Policy and Practices

As an ‘SNI investment firm’, Omni Advisory is subject to the “basic” requirements of the MIFIDPRU Remuneration Code set out in SYSC 19.G of the FCA’s Handbook.  MIFIDPRU 8.6 of the FCA’s Handbook requires Omni Advisory to disclose certain information on at least an annual basis regarding its Remuneration Policy and related practices for all staff.

Omni Advisory’s Approach to Remuneration

The directors of Omni Advisory are responsible for its Remuneration Policy, which is designed to ensure that its compensation arrangements:

• are consistent with and promote sound and effective risk management;
• does not encourage risk-taking which is inconsistent with the risk profiles of the funds which it  manages;
• seek to avoid creating conflicts of interest; and
• are in line with its business strategy, objectives, values and long-term interests.

Compensation is based upon consideration of qualitative and quantitative factors, including the performance of the relevant individual and of the business. Variable remuneration is adjusted in line with relevant capital and liquidity requirements.

Objectives of Financial Incentives

Individuals are rewarded based on their contribution to Omni Advisory’s overall strategy. Other factors, such as performance, reliability, effectiveness of controls, business development and contribution to Omni Advisory generally are also taken into account when assessing the performance of staff.

Development of Remuneration Policy and Related Practices

The governance relating to the development of Omni Advisory’s Remuneration Policy and related practices has risk management, equality, and conflicts of interest at its core:

• Risk management:
  • setting a clear policy and procedure for setting variable remuneration including individual, team and firm performance;
  • alignment with Omni Advisory’s business strategy, values and long term-goals;
  • alignment with the protection of Omni Advisory’s clients, customers and investors;
  • ensuring variable remuneration does not undermine Omni Advisory’s viability, sustainability and its ability to meet its Overall Financial Adequacy Rule and Threshold Conditions; and
  • ensuring that financial and non-financial incentives do not promote excessive risk taking;
• Equality:
  • ensuring that remuneration is not biased by gender, race, ethnic origin, political views, sexual orientation, age, disability or any other discriminatory factors;
• Conflicts of interest:
  • adopting policies and procedures aimed at mitigating any potential conflicts that may arise between Omni Advisory, and its staff members, clients, customers, investors or investment strategies; and
  • maintaining a Conflict of Interests Register which includes potential conflicts relating to remuneration as well as any procedures implemented to mitigate such conflicts.

Components of Remuneration

Omni’s remuneration components are described below:

Performance criteria

Omni Advisory’s Remuneration Policy clearly defines the performance criteria used across the firm, including specific business units, and for individual performance.

Remuneration decisions are made based on a combination of:

• Omni Advisory’s long-term sustainability and viability including looking through the business and economic cycles;
• the impact on Omni Advisory’s Overall Financial Adequacy Rule and Threshold Conditions; and
• Omni Advisory’s business performance and results against its strategic objectives.

Remuneration decisions for individuals are made based on a combination of:

• individual performance against the specifications of the role;
• the level of responsibility and seniority;
• overall performance of the relevant business function;
• adherence to Omni Advisory’s purpose, values and culture;
• adherence Omni Advisory’s risk management and compliance framework; and
• compliance with Omni Advisory’s internal conduct policies and procedures.

Specific criteria are in place for those members of staff performing SM&CR control functions, whereby remuneration for such members of staff is not directly determined by the performance of the business, either positively or negatively. This is to ensure there are no conflicts of interests and that objectivity is not compromised.

Quantitative Disclosure

Aggregated quantitative information on remuneration paid to all staff:

Verification

The information contained in this disclosure has not been audited by Omni Advisory’s external auditors and does not constitute any form of financial statement.

[1] Following a group reorganisation, in March 2023 Omni Advisory was authorised by the FCA; and Omni Partners LLP, being the parent entity of the Omni group, transferred its regulated business, activities and related assets to Omni Advisory. In the interests of clarity, this table therefore includes information in relation to the remuneration of both Omni Advisory and of Omni Partners LLP staff in the period.