MIFIDPRU Public Disclosure Statement – FYE 31 March 2023


Hollyport Capital LLP (“Hollyport” or the “Firm”) is regulated by the Financial Conduct Authority (“FCA”) as a Markets in Financial Instruments (“MIFID”) firm and is subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”) Handbook. Under MIFIDPRU, the Firm is classified as a small non-interconnected (“SNI”) firm. The Firm is required to comply with the disclosure requirements as set out in MIFIDPRU 8.6.  


The Firm adheres to the FCA’s Remuneration Code as specified in SYSC19G, applying remuneration rules and guidance in a proportionate manner that reflects the size, internal organization and nature of the Firm, and scope and complexity of the activities it undertakes.

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

The Firm has formulated its remuneration policy and practices with reference to the guidance set out by the FCA. Hollyport considers the appropriate balance between fixed and variable remuneration and also seeks to avoid a conflict of interest between staff incentives and the best interests of customers.

The Firm’s financial incentives are designed to align risk and reward by:

  • Promoting sound and effective risk management;
  • Encouraging responsible business conduct; 
  • Supporting positive behaviours and healthy firm cultures;
  • Limiting risk-taking; 
  • Avoiding conflicts of interest; and
  • Being gender neutral, in line with the Equality Act 2010.

B. Governance and Decision-making Procedures 

The Firm has implemented and maintains a Remuneration Committee that oversees the compensation of the business, following the procedures established by the Human Resources Department. The overall variable remuneration pool and the variable remuneration of individuals are subject to review and approval by the Remuneration Committee.  The Firm’s remuneration arrangements are reviewed regularly.

The Firm assesses all staff under its performance management process on an ongoing basis, with an annual performance assessment outcome being used as a contributing factor in the determination of remuneration.

C. Key Characteristics of Remuneration Policies and Practices

Hollyport’s Remuneration Policy is reviewed annually by the Compliance Department and is approved by the Remuneration Committee. 

The Remuneration Policy has been developed based on a number of key principles which are:  

  • Remuneration should align to the Firm’s business drivers, corporate vision, and strategic priorities. 
  • Remuneration should adhere to wider people management practices, and only reward results which support a positive employment culture and customer values. 
  • Remuneration communications should be made simple, clear, and transparent for employees and shareholders. 

At the Firm, total reward typically comprised a salary, additional benefits, and bonus or profit-sharing arrangements.  Salaries are set in the context of affordability, external market considerations, internal relativities, and equal pay factors.  

D. Fixed and Variable Remuneration 

All staff receive fixed remuneration and are considered for discretionary variable remuneration.

The Firm reviews the base salary of staff on an annual basis, considering factors such as market information and individual performance.

All variable remuneration is dependent on the Firm’s overall financial result and takes into account current and future financial and non-financial risks. The amount of variable remuneration that is awarded to individuals is tied to individual performance, with reference to the Firm’s formal appraisal process. No variable remuneration is awarded to members of the management body who do not perform any executive function in the Firm.

E. Quantitative Remuneration 

For the period, the Firm paid a total amount of remuneration to staff of £18,374,312, comprising £13,509,676 in fixed remuneration and £4,864,636 in variable remuneration.