Introduction

The following disclosure is made by Omni Advisory and by Omni Partners LLP  (“Omni Partners”) pursuant to the FCA’s Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”) in respect of the financial year ended 31^st December 2023.

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

They are therefore required, under Chapter 8 of MIFIDPRU, to publish key information in order to assist users of their accounts and to encourage market discipline. In accordance with MIFIDPRU 8.1, as ‘SNI investment firms’ the information which they are required to publish is limited to information relating to their respective remuneration policies and practices (per MIFIDPRU 8.6).

This disclosure has been prepared by Omni Advisory and by Omni Partners in accordance with the requirements of MIFIDPRU 8 and has been approved by the directors of Omni Advisory and by the partners of Omni Partners. Unless otherwise stated, all disclosures pertain to the financial year ended 31^st December 2023 and are seen as complimentary to Omni Advisory’s or Omni Partners’ (as the case may be) published financial statements for that period, their implementation of other MIFIDPRU rules, and the relevant entity’s internal capital adequacy and risk assessment (“ICARA”) process.  Their MIFIDPRU disclosures are published alongside their respective audited annual accounts.

Remuneration Policy and Practices

As ‘SNI investment firms’, Omni Advisory and Omni Partners are 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 them to disclose certain information on at least an annual basis regarding its Remuneration Policy and related practices for all staff.

Approach to Remuneration

The directors of Omni Advisory are responsible for its Remuneration Policy.

The partners of Omni Partners are responsible for its Remuneration Policy.

Each Remuneration Policy is designed to ensure that the relevant entity’s 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 the relevant entity’s overall strategy. Other factors, such as performance, reliability, effectiveness of controls, business development and contribution to the relevant entity 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 each 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 the relevant entity’s business strategy, values and long term-goals;
  • alignment with the protection of the relevant entity clients, customers and investors;
  • ensuring variable remuneration does not undermine the relevant entity 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 the relevant entity, 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 Advisory’s and Omni Partners’ remuneration components are described below:

Category	Component
Fixed	Base salary
	Pension
	Benefits
Variable	Discretionary annual bonus
	Carried interest
	Sign-on bonus (extraordinary)
	Retention bonus (extraordinary)

Performance criteria

Each 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:

• the relevant entity’s long-term sustainability and viability including looking through the business and economic cycles;
• the impact on the relevant entity’s Overall Financial Adequacy Rule and Threshold Conditions; and
• the relevant entity’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 the relevant entity’s purpose, values and culture;
• adherence to the relevant entity’s risk management and compliance framework; and
• compliance with the relevant entity’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:

Category	£’000
Omni Advisory Limited
Fixed remuneration	645
Variable remuneration	206
Omni Partners LLP
Fixed remuneration	1,346
Variable remuneration	2,158

Verification

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