Remuneration policy

 CCLA Group Policy Statement 2016

This Policy is approved by the Board of CCLA Investment Management Limited and represents the remuneration arrangements of both CCLA Investment Management Limited and CCLA Fund Managers Limited collectively referred to as CCLA. Where arrangements apply only to one firm this is noted.

Scope of Policy

The remuneration policy applies to all members of the company, with additional controls for staff identified as Remuneration Code Staff.

Purpose and Objectives of the Policy

The objectives of the policy are:

  • To set out the principles governing the Company’s remuneration system
  • Ensure the remuneration is in line with applicable regulation on remuneration
  • Ensure that remuneration is properly monitored
  • To inform management of the applicable rules as well as on their remuneration systems

Effective Date

The Policy will become effective upon approval by the Board of CCLA Investment Management Limited on the 25th April 2016.

Annual Review

The policy, the remuneration system and the practical operation shall be reviewed by the remuneration committee on a regular basis and at least once a year.

General Requirement

A firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote sound and effective risk management.

A firm must:

  1. Maintain a record of its Remuneration Code Staff in accordance with the general record-keeping requirements; and
  2. Must take reasonable steps to ensure that it’s Remuneration Code Staff understand the implications of their status as such, including the potential for remuneration which does not comply with certain requirements of the Remuneration Code to be rendered void and recoverable by the firm.

CCLA Investment management is subject to CRD IV and the UCITS Remuneration Codes.  Due to the nature of the business the company is categorised as proportionality level three. 

CCLA Fund Managers Limited is subject to the AIFM Remuneration Code. This policy covers all three codes.

CCLA does not trade on its own account and so its principle risk is operational risk.  Remuneration Code Staff (“Code Staff”) for both entities have been defined as all individuals in Significant Influence Functions which are all the Executive Directors and the Head of Assurance.  An up to date list of Code Staff is maintained by HR, and reviewed by Compliance and the Remuneration Committee on an annual basis. 

The job descriptions of all Code Staff highlight their status as Code Staff and provide a warning that any remuneration paid in contravention of the Code is recoverable.

 

Remuneration Principles

Risk Management and risk tolerance

CCLA has a single Remuneration Policy that applies to all staff with specific reference to Code Staff where appropriate.  Staff remuneration is agreed following an assessment of market conditions for each role, individual performance against objectives, and on the financial performance of CCLA overall.  For all staff this is by way of an annual salary and a discretionary bonus part of which may be deferred.

Executive Directors are also eligible for participation in CCLA’s Long-term incentive plan (LTIP) based on company share ownership. 

Rewards are not associated with the sale of individual products.

CCLA completes an Internal Capital Adequacy Assessment (ICAAP) on annual basis where the key operational risks are identified and modelled to identify the potential financial loss that could arise.  This is then reviewed alongside the Fixed Overhead Requirement and in the context of the available Capital of the firm.  The ICAAP is discussed by the Executive Committee and approved by the Audit Committee of the Board and the Board.  The Pillar 1 and Pillar 2 information is provided to the Remuneration Committee in order to allow them to assess levels of remuneration in the light of the capital available to support the business.

Supporting business strategy, objectives, values and interests

When remuneration levels are assessed the Remuneration Committee reviews performance indicators about key aspects of the firm in order to ensure that remuneration policy is in line with CCLA’s business strategy, objectives, values and long-term interests of the firm.  

Avoiding conflicts of interest

CCLA’s Conflicts of Interests Policy applies to all staff.  It is designed to avoid conflicts arising between customers’ interests and those of CCLA staff or CCLA as a whole.  In particular, it notes that there are not any financial incentives in place for sales and non-sales staff to meet particular targets. The remuneration policy references the Conflicts of Interest Policy.

Governance

Staff remuneration levels are reviewed by a Remuneration Committee of the Board which meets at least annually and comprises non-executive directors.  The Committee also specifically approves individual salary, bonus payments, deferral arrangements and LTIP participation for Code Staff.

The Compliance function conducts an annual review of the Remuneration Policy for compliance with regulatory requirements prior to it being presented to The Board of CCLA IM for final approval.

Control Functions

The Head of Assurance reports directly to the Chief Executive of CCLA and has a direct reporting line to the Chairman of the Audit Committee of the Board who is non-Executive.  This gives the Head of Assurance both independence and authority.

Remuneration for the Head of Assurance is determined following an assessment of market data for the role and individual performance against objectives.  The financial performance of CCLA overall will always have an impact on the firm’s ability to pay variable remuneration but it is not a leading factor in determining variable remuneration for the Head of Assurance.  The Remuneration Committee will receive specific market data on remuneration together with an overall performance assessment with a recommendation from the Chief Executive and formal input from the Chairman of the Audit Committee. 

Remuneration and capital

Levels of variable remuneration are assessed by the Remuneration Committee in the light of the profitability of the firm and the adequacy of its regulatory capital as set out in the ICAAP.

Exceptional government intervention

This does not apply to CCLA.

Profit-based measurement and risk adjustment

All variable remuneration paid by CCLA is on a purely discretionary basis.  It is based on the performance of the firm, and on work already performed rather than on anticipated results.  

Levels of variable remuneration are assessed by the Remuneration Committee in the light of the profitability of the firm and the adequacy of its regulatory capital as set out in the ICAAP.

Pension policy

Pension arrangements have been reviewed and changed in order to ensure that they are in line with CCLA’s business strategy, objectives, values and long term interests and that of the funds it manages.  Arrangements follow a consistent scale for all staff which is based on age.

Personal investment strategies

Personal hedging strategies are prohibited.  CCLA place a restriction in the staff handbook that prohibits staff from taking out insurance contracts or other countermeasures that undermine risk alignment within CCLA. 

Avoidance of the Remuneration Code

CCLA does not reward any staff through any alternative vehicles or methods that could cause non-compliance with the code.

Remuneration Structures

The following principles relate to the structure of remuneration arrangements.  CCLA currently applies proportionality to the application of these requirements.

General requirement

All Code Staff are subject to the Approved Persons Code of Conduct, are contractually bound to operate within the firm’s risk tolerance levels and are not incentivised in any way to take undue risk.

As previously noted, remuneration for Code Staff is determined on the basis of an assessment of market conditions for each role, individual performance against objectives, and on the overall performance of CCLA.  Based on this assessment, recommendations are made by the Chief Executive to The Remuneration Committee and supported by appropriate documentation in each case.

Assessment of performance

Remuneration is not linked to the sale of individual products.  The size of the annual bonus pool is, however, related to the overall performance of the organisation.

Ratios between fixed and variable components of total remuneration

CCLA has assessed proportionality against the regulations and has identified that this principal can be dis-applied. The ratio between the fixed and variable components of remuneration is reviewed by the remuneration committee to ensure that they are appropriate.

Payments related to early termination

Payments related to termination for Code Staff are based on contractual arrangements and legal rights that are designed in a way that does not reward failure. 

Terms and conditions

Website terms of use policy

Welcome to CCLA's website for:

  • fund management services for The CBF Church of England Funds and the COIF Charities Funds (together referred to as "the Funds"); and for
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions ("Terms of Use") on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them. Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these terms and conditions you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time and where this is the case we will do so by updating this page. We therefore recommend that you check this page periodically to ensure that you understand the terms which will apply from time to time.

  1. Information about CCLA

Any reference to "CCLA" on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

CCLA Investment Management Limited (a company registered in England and Wales with Company No. 2183088) and CCLA Fund Managers Limited (a company registered in England and Wales with Company No. 8735639) are each authorised and regulated by the Financial Conduct Authority ("FCA") under the Financial Services and Markets Act 2000 ("FSMA"), and are entered in the FCA Register under Registration Numbers 119281 and 611707 respectively. CCLA Fund Managers Limited is a wholly owned subsidiary of CCLA Investment Management Limited.

CCLA Investment Management Limited is the manager of The CBF Church of England Funds and provides discretionary investment management services for individual client portfolios. CCLA Fund Managers Limited is the manager of the COIF Charities Funds. The registered office of CCLA Investment Management Limited and CCLA Fund Managers Limited is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

2. Who may use this website

The information in this website is primarily intended for "charities" in the United Kingdom (and in particular the information in relation to the Funds is intended for UK "charities" only).  "Charities" for these purposes are charities or charitable organisations who are registered with the Charity Commission, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958 or section 24 of the Charities Act 1993, or equivalent organisations in Scotland or Northern Ireland. Certain investments or services to which this material relates may only be available to such persons. This material must not be relied upon or acted upon by any other persons in the United Kingdom.

3. The purpose of this website

This website is for information purposes only and is intended as a general introduction to CCLA and its products. The website content and any products and/or services described within it are subject to change without notice. We do not accept any liability to you, or any third party, for the accuracy, completeness or appropriateness of the information and materials made available on this website and your use of any information or materials is entirely at your own risk provided that nothing contained in this section or elsewhere in these terms shall limit or exclude our liability to you to the extent that such liability is attributable to a breach by us of the FCA's rules, FSMA or any other applicable law.

Any application or investment must only be made on the basis of the relevant investment documents which will be issued to you when you make an enquiry about investing in a CCLA fund, such as, for example, the scheme particulars and terms and conditions. Nothing contained on this website constitutes the provision of investment, tax, legal or other advice.

Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

4. Risk warning

The value of the Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

Please refer to the Funds’ scheme particulars for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

The investments and investment services referred to on this website may not be suitable for all eligible investors.

As the Funds are not authorised unit trusts within the meaning of FSMA, investments or deposits in the Funds are not covered by the Financial Services Compensation Scheme (FSCS).

However, unitholders and/or shareholders may be eligible for compensation under FSCS if CCLA cannot meet its obligations. There are limits on who can claim and the amount of compensation available. Further information about FSCS is available at www.fscs.org.uk

5. CCLA's liability for website content

The information on this website does not necessarily reflect our views and opinions. Neither should any suggestions or advice contained on the website be relied upon in place of individual advice. You are responsible for checking the accuracy of relevant facts, instructions, suggestions and/or opinions given on the website before entering into any commitment based upon them. We do not accept any liability arising from any inaccuracy or omission in the information.

CCLA is not responsible for the accuracy of information contained within websites provided by third parties, which may have links to or from our pages.

The information on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Under no circumstances should this information or any part of it be copied, reproduced or redistributed.

Due to the inherent nature of the Internet, errors, interruptions and delays may occur in the service at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. CCLA shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between CCLA and you, regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

CCLA shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this website or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. CCLA makes no warranty whatsoever to you, express or implied, regarding the security of the website.

This service may provide links to certain websites sponsored and maintained by third parties. CCLA makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. Your use of the products and services on this website may be monitored by CCLA.

6. Copyright and trade marks

CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

No use of CCLA's name, logos and/or other trade marks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

7. Data protection

We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with the Data Protection Act 1998. CCLA is the data controller of any such information for these purposes. CCLA will use any such information for the administration and servicing of your investments and all other related activities. We may disclose your information to our agents and service providers. Where a financial adviser acts on your behalf, we may disclose such information to that financial adviser.

By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you upon payment of a fee and to require us to correct any inaccuracies in your personal data.

If you supply such information to us via this website, CCLA may use your personal data to contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you. You may inform CCLA at any time if you do not want to receive such communications.

Full details of CCLA’s Data Protection Policy, including its Privacy Notice are available on request.

8. Cookies

This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

Please note that when you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

Please note that you can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

For more information about cookies, including how to set your Internet browser to reject cookies, please visit www.allaboutcookies.org.

9. General

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information (including personal data), we cannot guarantee the security of your data transmitted to this website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. However, CCLA accepts no liability in the unlikely event of a breach of our secure computer servers.

We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website and regularly check for the presence of viruses and other malicious code. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim arising under these Terms of Use.

September 2015