Remuneration Policy

Purpose

BLUEBRIDGE ASSET MANAGEMENT LTD (“BLUEBRIDGE” or “the Firm”) is authorised and regulated by the FCA, with FRN: 1038693 as a Small and Non-Interconnected MIFIDPRU Investment Firm (‘SNI Firms’). This policy outlines the Firm’s approach to remuneration, ensuring compliance with FCA requirements and promoting a balanced, risk-averse culture.

Governance and Oversight

The Firm’s senior management is responsible for reviewing and overseeing the implementation of its remuneration policy at least annually. This review ensures that the policy remains proportionate, balanced, and does not promote excessive risk-taking. It also ensures ongoing compliance with relevant FCA requirements. While the senior management team leads this review process, the Firm’s governing body retains ultimate responsibility and oversight for all remuneration matters, including the policy’s annual review and its application across all staff.

Public Disclosure

In accordance with MIFIDPRU 8.6, BLUEBRIDGE is required to publicly disclose its remuneration practices and will publish after the end of each financial year the total employee remuneration for that year. The Firm’s governing body considers its remuneration framework to be appropriate and proportionate, taking into account the nature, scale, and complexity of the business model and its regulatory activities. This approach supports long-term sustainability and helps to avoid potential conflicts of interest, as required under Article 24(10) of the UK MiFID framework.

Remuneration Structure

The basic requirements in the MIFIDPRU Remuneration Code apply to all SNI Firms. BLUEBRIDGE pays all its staff remuneration which comprises a fixed element and can also include a variable component. The fixed and variable components of the salary will be clearly defined in each specific case.

Fixed Remuneration

An employee’s fixed element of their remuneration is based on pre-determined criteria. It is non-discretionary, transparent, permanent for the year, and subject to an annual review, whereby any possible increase is assessed. The fixed remuneration reflects a staff member’s professional knowledge and experience, skills, the requirements of the particular role for which they are employed, their qualifications, and his/her organisational responsibilities as set out in the staff member’s job description and terms and conditions of employment.

Variable Remuneration

Variable remuneration is not guaranteed and is assessed and, where deemed relevant by the governing body, distributed based on the individual’s performance and the financial performance of the Firm.

Remuneration and related incentives will not be based solely on quantitative commercial factors. In addition to financial performance, Bluebridge considers qualitative measures, such as behavioural indicators, customer feedback, and alignment with the firm’s core values. These criteria reflect adherence to regulatory requirements, fair treatment of clients, and the delivery of high-quality services.

Bluebridge is committed to maintaining an appropriate balance between fixed and variable pay components to mitigate any potential conflicts of interest between the firm, its employees, and its clients.

Performance Review

All employees undergo annual performance reviews to assess whether they have met their individual goals and objectives, fulfilled the core competencies required for their role, and completed all mandatory training, particularly regulatory training. Given the small size of the Firm in terms of headcount, the Firm's governing body will evaluate the performance of each employee on a case-by-case basis. The Firm's governing body must assess on a case-by-case basis that the conflicts of interest policy is not compromised. The annual reviews are in compliance with the FCA requirements and include an assessment of fitness & propriety for roles that fall under the Senior Managers & Certification Regime (SMCR) and this includes all sales staff.

Risk Management and Compliance

The Firm’s senior management promotes a culture of prudent risk-taking by adhering to established internal policies and regulatory standards. As part of the annual review process, BLUEBRIDGE considers a range of non-financial qualitative criteria aligned with its strategic objectives. These include compliance with regulatory obligations (such as treating customers fairly and avoiding upheld complaints), adherence to risk management and compliance policies, alignment with internal governance procedures, and a clean disciplinary record, including compliance with the FCA’s conduct rules.

Commitment to Equality

Finally, BLUEBRIDGE is committed to maintaining an inclusive and non-discriminatory workplace. The Firm does not discriminate on the basis of age, disability, gender reassignment, marital or civil partnership status, pregnancy or maternity, race, religion or belief, sex, or sexual orientation, in accordance with the Equality Act 2010.

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