Regulatory
Disclosures

Regulatory

Artorius Wealth Management Ltd is authorised and regulated by the Financial Conduct Authority. You can check this on the FCA Register at www.fca.org.uk/register (Firm Reference Number 677055). Artorius is a trading name of Artorius Wealth Management Limited.

This website is intended to be image advertising. It is not intended, and must not be construed as, providing regulated investment advice.

Remuneration Code Disclosure

Artorius Wealth Management Limited (‘Artorius’) is an SNI MIFIDPRU Investment firm, authorised and regulated by the FCA.

As an SNI MIFIDPRU firm, Artorius is required to disclose the following remuneration information regarding our remuneration policy and practices under MIFIDPRU 8.

Remuneration policy and practices

1. Qualitative disclosures

• Our approach to remuneration for all staff

• The objectives of our financial incentives

• The decision-making procedures and governance surrounding the development of the remuneration policies and practices our firm is required to adopt in accordance with the MIFIDPRU Remuneration Code, to include, where applicable:

• The composition of and mandate given to the remuneration committee, and

• Details of any external consultants used in the development of the remuneration policies and practices

• The key characteristics of our remuneration policies and practices to enable

• An understanding of the risk profile of our firm and/or the assets it manages, and

• overview of the incentives created by our remuneration policies and practices

• The different components of our remuneration, together with the categorisation of those remuneration components as fixed or variable

• A summary of the financial and non-financial performance criteria used across the firm, broken down into the criteria for the assessment of the performance of

  • the firm,

  • Business units, and

  • Individuals

2. Quantitative disclosures

• The total amount of remuneration awarded to all staff, split into fixed v variable remuneration

1. Qualitative Disclosures

Our approach to remuneration for all staff and the objectives of our financial incentives in respect of staff remuneration.

Artorius seeks to grow its business through the quality of its service. To meet that objective, Artorius remuneration packages are designed to attract and retain staff with the right skills, experience, knowledge and behaviours to support clients and deliver that quality of service. Remuneration seeks to strike a balance between the needs of the individual, the firm and its clients; it is designed to ensure that clients are treated fairly and their interests are not impaired, ensuring they receive good outcomes.

Any remuneration package or incentive scheme we have in place, or may introduce in the future, will:

• ensure the fair treatment of our clients and the quality of service provided

• take appropriate qualitative criteria into account

• maintain a balance between fixed and variable remuneration so the structure doesn't favour the interests of our firm or staff over those of our clients

• ensure conflicts of interest are avoided.

And will not:

• Remunerate or assess performance of our staff in any way that conflicts with our duty to act in the best interest of our clients and deliver good client outcomes.

• Include any arrangement by way of remuneration, sales targets or otherwise, that could provide an incentive to our staff to recommend a particular service or product to a retail client where a different service or product could be offered that would better suit their needs.

• Create a conflict of interest that would encourage individuals to act against the interests of any of our clients

• Be solely or predominately based on quantitative commercial criteria our decision-making procedures and governance surrounding the development of the firm’s remuneration policies and practices.

The Artorius Group has a remuneration committee, which is a sub-committee of the Group Board. The committee consists of a Group non-executive director who acts as Chair, Group Non-executive Chair and CEO. Members of the committee cannot vote on their own remuneration. The committee meets annually. It may meet in the interim to consider exceptional changes to fixed pay or if changes to the remuneration policy are proposed. The remuneration committee is responsible for setting the remuneration policy which applies to all staff and for approving all key remuneration decisions relating to fixed pay and variable pay which includes cash bonus awards and shares.

When recommending changes to fixed pay or variable pay awards (bonus & shares) to the remuneration committee for approval, the Artorius Wealth Management Board (AWM Board) along with relevant managers, will consider amongst other things, behaviours aligned with Artorius values, client focus, compliance scorecards, compliance with all policies and procedures, and in the case of Client Partners, client specific metrics. The AWM Board reserves the right to add other metrics to the scheme throughout the year if new risks/conduct issues are identified. External consultants are not used on a regular basis but will be considered should the need arise.

The key characteristics of our remuneration policies and practices including the different components of our remuneration, together with the categorisation of those remuneration components as fixed or variable.

Fixed Pay

The key element of remuneration is fixed pay. This forms the majority of remuneration. Other benefits provided to all staff include a defined contribution pension scheme and private medical insurance. Fixed pay is determined by considering internal factors (role and responsibility, affordability) and the external market. Fixed pay is reviewed annually to consider if an increase is appropriate.

Variable Pay

There are two elements of variable remuneration:

Cash bonus awards and share awards under an EMI scheme. Both elements take into account the performance of the business and an individual’s performance against their annual Key Performance Indicators (KPIs) and other performance related factors. The KPIs and other performance factors will consider financial and non-financial KPIs, behaviours (including adherence to Artorius values), and appropriate performance against a range of risk and compliance measures. Any variable awards are subject to ensuring the Group’s FCA regulated firms maintain prudent levels of capital adequacy and liquidity.

Cash bonus awards are made from a bonus pool which is determined annually based on company performance. Employee remuneration and incentives are entirely discretionary with all permanent employees being eligible to participate in both the discretionary bonus awards and share option scheme.

2. Quantitative Disclosures

As an SNI MIFIDPRU investment firm, we are required to disclose the total remuneration of all our staff split between fixed and variable remuneration for our performance year end which is also our financial year end. For our year ending 30 April 2024, our total remuneration is split as follows:

Best Execution Policy

Overview

It’s in the interests of our clients and our firm that we obtain the best possible result when placing orders for execution on behalf of our clients, with third parties, such as platforms, fund managers or stockbrokers. We’re required to take all sufficient steps to provide best execution when carrying out such transactions and, on your request, to provide you with a copy of the policy that we have adopted to achieve that objective.

This best execution policy applies to orders in investments such as funds and other securities. You should read this policy in conjunction with your client agreement.

Execution venues and third parties

An execution venue is effectively a trading venue such as a regulated stock market where investment transactions are executed. Our firm doesn’t execute orders or deals directly with execution venues.

Instead, we’ll place orders on behalf of our clients with appropriate third parties as explained below:

Investments on a platform: for investments held on our preferred platform(s) (an online investment administration service), client orders will be placed directly with the relevant platform. These are Credit Suisse & Seven Investment Management in the UK, Credit Suisse, Seven Investment Management & UBS in the Channel Islands and UBS, Lombard Odier, Julius Baer and Credit Suisse in Switzerland.

Investments not on a platform: for investments held directly with individual fund managers, client orders will be placed directly with the relevant fund manager for the particular investment.

Stocks and shares: we use our client’s platform, as above.

We’ll regularly assess the third parties available to us to identify those that will enable us, on a consistent basis, to obtain the best possible result when arranging the execution of your orders. The above list will then be updated, where necessary, following such assessment.

The third parties have responsibilities in relation to best execution and client order handling themselves. We’ll also undertake periodic monitoring to ensure that they’re meeting the relevant requirements.

Execution Factors

When transmitting orders to a third party, we’ll make every effort to ensure the best possible result for our clients taking into account the following factors:

• Price

• Cost

• Speed

• Likelihood of execution and settlement

• Size

• Nature of the order

• Any other considerations relevant to the execution of the order

For retail clients, the price and cost of execution of the order will normally be the most important aspect in obtaining the best possible result. We’ll therefore assume that this is the most important outcome for your transaction unless you tell us otherwise.

When bulk trades are placed across multiple platforms the Investment team will compare the times of the trades and price traded at across the platforms in order to monitor the outcome for clients. Where a platform trades at a significantly different time to the others (+ 1 hour) or the price is significantly different (+/- 1%) the investment team will contact the platform and identify the cause and where possible, take actions to prevent future significant differences.

Client specific instructions

If you’ve given instructions that price is not the most important factor in executing your instructions, we’ll make every effort to comply with your instructions but cannot guarantee this. This may be due to either the nature of the order, or the type of investment you wish to trade in.

We’ll make all decisions as to where the orders are placed and won’t usually accept specific instructions from clients regarding which third parties to use, such as a particular broker. If we do accept any client specific instructions you should be aware that this may prevent us from following the processes set out in this policy which have been designed to obtain the best possible results for the execution of those orders in respect of the elements covered by those specific instructions.

Charges

It’s our policy that commission and charging structures won’t influence either the selection of third parties to which we place client orders, or the order flow that follows as a result of the execution process. We’ll therefore not discriminate between the third parties used to arrange execution of your orders.

Monitoring and Review of our Execution Policy

We’ll regularly monitor the effectiveness of our best execution policy to identify and, where appropriate, correct any deficiencies. In particular, this will cover the third parties to which we transmit client orders in terms of their quality of execution. This review will be carried out regularly or whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients.

Staff understanding

All relevant staff are made aware of this policy to highlight and emphasise the importance of best execution.