Remuneration policy

The FCA Remuneration Code (“Code”)

CCLA Group Policy

This Policy represents the remuneration arrangements of both CCLA Investment Management Limited (“CCLA IM”) and its wholly owned subsidiary, CCLA Fund Managers Limited (“CCLA FM”) (collectively referred to as “CCLA”). Where arrangements apply to only one firm this is noted.

1.  Overview

This Policy is intended to set out how CCLA promotes sound and effective risk management in accordance with the remuneration codes transposed into the relevant SYSC sections of the Financial Conduct Authority (“FCA”) handbook of rules of guidance.

CCLA is required to apply four elements of remuneration regulation to parts of the business as follows:





Each of the Fund directives (UCITS and AIFMD) have remuneration requirements, and remuneration risk is covered by prudential regulation IFPRU (based on CCLA’s regulatory permissions) and MiFID II.

This Policy has been designed to incorporate all relevant remuneration regulatory obligations for the businesses into a consolidated policy that is applied consistently across the organisation.

CCLA currently manages approximately £12 billion of assets under management (“AUM”) on behalf of its client/investor base of charities, religious organisations and the public sector. Its investment activities do not have a significant influence on the market.

The governing body of CCLA includes the following roles, all of which are FCA Senior Manager Function roles:

•    Chairman of the Board

•    Chief Executive Officer

•    Chief Investment Officer (as an executive board director)

•    Chief Operating Officer (as an executive board director)

•    Director, Market Development (as an executive board director)

The individuals performing these roles are all members of CCLA’s Executive Committee except for the Chairman of the Board. The Chief Risk Officer, Head of Product and the Company Secretary are also members of the Executive Committee.

CCLA’s Board of Directors has delegated responsibility for the development and review of its remuneration policy and remuneration philosophy to the Remuneration and Nominations Committee (the “Committee”), composed of all CCLA’s Non-Executive Directors.

2.  Scope of Policy

This Policy applies to all staff of the company, with additional controls for staff identified as Remuneration Code Staff (“Code Staff”). This Policy is applicable to all aspects of remuneration that could have a bearing on effective risk management, including salaries, bonuses, long-term incentive plans, options, hiring bonuses, severance packages and pension arrangements, where relevant.

References to remuneration include remuneration paid, provided or awarded in connection with employment by CCLA.

3.  Purpose and Objectives of the Policy

The objectives of this Policy are to:

•    set out the principles governing CCLA’s approach to remuneration;

•    ensure that remuneration is in line with applicable regulations on remuneration;

•    ensure that remuneration is properly monitored; and

•    inform management of the applicable rules on remuneration

4.  Annual Review

This Policy, the remuneration approach and its practical operation shall be reviewed by the Committee on a regular basis and at least once a year.

5.  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) ensure that it does not remunerate or assess the performance of its staff in a way that conflicts with its duty to act in the best interests of its clients/investors. In particular, a firm must not make any arrangement by way of remuneration, sales targets or otherwise that could provide an incentive to its staff to recommend a particular product to a retail client over a different product which would better meet that client’s needs;

(2) maintain a record of its Code Staff in accordance with the general record-keeping requirements

(3) take reasonable steps to ensure that its 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; and

(4) notify the FCA of any remuneration matters deemed reportable in the FCA Handbook.

CCLA IM is subject to IFPRU (CRD IV), MiFID II and the UCITS Remuneration Codes.

CCLA FM Limited is subject to the AIFM Remuneration Code.

This Policy incorporates all relevant provisions of these Codes.

CCLA does not trade for its own account and so its principal risks arise from operational risks and a reduction in the management fee income it receives, either as a result of a market downturn or investor redemptions. Code Staff for both entities have been defined as the individuals performing certain of the FCA’s Senior Management Functions, being the Executive Directors, the Chief Risk Officer and the Chairman of the Board. An up to date list of Code Staff is maintained by Compliance and reviewed by the Chief Risk Officer and the Committee on an annual basis (refer to Appendix A). 

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.

6.  Remuneration Principles

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 employment 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.   

Senior Executives on invitation by the Committee 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.

Principle 1:  Risk management and risk tolerance

CCLA completes an Internal Capital Adequacy Assessment Process (ICAAP) on an annual basis where the key business risks are identified and modelled to determine the potential financial loss that could arise. This is then reviewed alongside the firm’s Fixed Overhead Requirement and in the context of the available capital of the firm.  The ICAAP is discussed and agreed by the Executive Committee and approved by the Audit Committee of the Board.  The Pillar One and, where relevant, Pillar Two information is provided to the Committee to allow them to assess levels of remuneration against the capital available and required to support the business and against the identified risks.

Principle 2:  Supporting business strategy, objectives, values and long-term interests

When remuneration levels are assessed, the Committee reviews performance indicators about key aspects of the firm to ensure that this Policy is in line with the business strategy, objectives, values and long-term interests of CCLA, the funds and clients/investors.

Principle 3:  Avoiding conflicts of interest

CCLA’s Conflicts of Interests Policy applies to all staff.  It is designed to avoid or manage conflicts arising between customers’ interests and those of CCLA staff or CCLA as a whole. 

Principle 4:  Governance

The Committee has been constituted in a way that enables it to exercise competent and independent judgement on this Policy and practices within CCLA and the incentives created for managing risk, capital and liquidity. Members of the Committee are members of the Board who do not perform any executive function within CCLA. Any decisions relating to remuneration must take into account the long term interests of shareholders, investors and other stakeholders in the firm and the public interest.

Staff remuneration levels are reviewed by the Committee. The Committee also specifically approves individual salary, bonus payments, deferral arrangements and where relevant, LTIP participation, for Code Staff.

The Compliance function conducts an annual review of this Policy for compliance with regulatory requirements, including the relevant Remuneration Codes, prior to it being presented to the Committee for final approval. The Committee is responsible for overseeing its implementation within the organisation. The Policy will be published on CCLA’s website,

Principle 5:  Control Functions

The Chief Risk Officer reports directly to the Chief Executive of CCLA and also has an unfettered reporting line to the Chairman of the Audit Committee of the Board who is a Non-Executive Director. This gives the Chief Risk Officer both independence and authority.

Remuneration for the Chief Risk Officer should be adequate to attract qualified and experienced staff and 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 Chief Risk Officer. The Committee will receive specific market data on remuneration together with an overall performance assessment with a recommendation from the Chief Executive. 

Principle 6:  Remuneration and capital

Levels of variable remuneration are assessed by the Committee taking into consideration the profitability of the firm and the adequacy of its regulatory capital as set out in the ICAAP. This ensures that any variable remuneration does not limit CCLA’s ability to strengthen its capital base.

Principle 7:  Exceptional government intervention

CCLA does not benefit from exceptional government intervention so this principle does not apply.

Principle 8:  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. As set out in Principle 6, any variable remuneration calculation will take into account or not prejudice the adequacy of CCLA’s regulatory capital.

Principle 9:  Pension policy

Pension arrangements have been reviewed to ensure that they are in line with CCLA’s business strategy, objectives, values and long-term interests and that of the funds and client investments it manages. 

Principle 10:  Personal investment strategies

Personal hedging strategies are prohibited.  CCLA place a restriction on its employees that prohibits the use of insurance contracts or other countermeasures that undermine risk alignment within CCLA.

Principle 11:  Non-compliance with the Remuneration Code

CCLA does not reward any staff through any alternative vehicles or methods that could facilitate non-compliance with the relevant FCA Remuneration Codes.

Principle 12:  Remuneration Structures

The following principles relate to the structure of remuneration arrangements. As deemed appropriate by the FCA in its general guidance on proportionality, CCLA currently applies proportionality to the application of these requirements:

(a) General requirement

All staff are required 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 employment 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 Committee and supported by appropriate documentation in each case.

(b) Assessment of performance

CCLA does not have performance-related pay and does not earn a performance fee on the returns of the Funds. The size of the annual bonus pool is, however, related to the overall performance of the organisation.

(c) Guaranteed variable remuneration, buy-outs and retention awards.

It is not CCLA’s practice to award guaranteed variable remuneration or to buy-out employees from their previous employment contracts. If exceptional circumstances require it, any arrangement would be subject to the same retention, deferral, performance and clawback provisions as other remuneration payments.

(d) Ratios between fixed and variable components of total remuneration

CCLA has assessed this principle against the remuneration principles proportionality rule and has determined that it can be dis-applied. The ratio between the fixed and variable components of remuneration are reviewed by the Committee to ensure that they are appropriate, taking into consideration all relevant factors..

(e) 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 or misconduct. 

(f) Retained shares or other instruments

CCLA has assessed this principle against the remuneration principles proportionality rule and has determined that it can be dis-applied. CCLA is a private company with a limited shareholder base. It has therefore made the decision not to require a portion of its variable remuneration to be in the form of shares with the exception of Executive Directors. However, employees who are subject to the deferral of a portion of their variable remuneration may elect to have the deferred remuneration awarded in the form of a share arrangement. The share arrangement will be retained for a period of three years plus one month before the award vests.

(g) Deferral

CCLA has assessed this principle against the remuneration principles proportionality rule and has determined that it can be dis-applied. However, certain employees, including Code Staff, may be awarded variable remuneration that exceeds the firm’s deferral threshold. In these instances, a pre-defined percentage of the remuneration award exceeding the deferral threshold will be deferred for a period of three years. There is a pre-defined minimum deferral amount. All pre-defined factors are agreed and approved by the Committee. As set out in (f) above, the deferred remuneration award can be in the form of a share arrangement or aligned to the value of certain of the COIF Charity Funds managed by CCLA.     

(h)      Performance adjustment

See Principle 8.

7.  Remuneration and performance management of sales staff

Upon reviewing the remuneration and performance management of sales staff, the Committee ensures that remuneration and similar incentives are not solely or predominantly based on quantitative commercial criteria, taking into account appropriate qualitative criteria reflecting compliance with the applicable regulations, the fair treatment of clients/investors and the quality of services provided.

The Committee ensures that a balance between fixed and variable components of remuneration is maintained at all times so that the remuneration structure does not favour the interests of the firm or its employees against the interests of any client/investor.

8.  Senior Executive Long-Term Incentive Plan

CCLA is keen to ensure that its Senior Executives have a common interest with its shareholders and are tied to the company in a way that ensures a long-term financial commitment and an alignment of the impact of gains and losses. A Long-Term Incentive Plan (“LTIP”) has been implemented to achieve this, with all Senior Executives eligible to participate in the scheme.

Under the terms of the LTIP, upon leaving the company, through retirement or resignation, Senior Executives will be assessed by the Committee to determine if they meet the criteria to be classified as a good leaver. Should a Senior Executive be deemed to be a good leaver, they will be allowed to hold their CCLA shares for a maximum period of 5 years after leaving the company.  A Senior Executive who has not been classified as a good leaver will be required to sell their shareholding immediately upon termination of employment. 

As the value of the Senior Executives shareholdings is directly impacted by the share price, good leavers who decide to hold on to their shares for a period post-employment may receive significantly greater value than had they sold their shares at the point of departure. This is consistent with the FCA’s remuneration principles, which expect that the remuneration of senior management is retained for a period of time and aligned with the longer-term interests of the firm. 

Deferred remuneration awards for Senior Executives are in the form of shares in CCLA Investment Management Limited. These shares will be deferred for a period of three years one month before vesting.

Senior Executives must obtain permission from the Board to be granted approval to sell any CCLA shareholdings.

9. Record Keeping

CCLA’s remuneration policies, practices and procedures must be clear and documented, including CCLA’s Remuneration Philosophy document, performance appraisal processes and decisions. Records will be kept for seven years in line with CCLA’s Document Retention and Records Management Policy.

March 2021

Appendix A

CCLA FCA Remuneration Code Staff



Role Title

Performed By




Chief Executive Officer

Peter Hugh Smith



Chief Investment Officer

James Bevan



Director, Market Development

Andrew Robinson



Chief Operating Officer

Elizabeth Sheldon



Chairman of the Board

Richard Horlick




Chief Risk Officer

Jean-Paul Lim



Terms and conditions

Website terms of use policy

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for  CCLA Funds (details of and documentation relating to all CCLA Funds is available on CCLA’s website); and
  • 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 or Terms) 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 you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time 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. About us (CCLA)

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

1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281.

1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707.

1.4  The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing

2. Who may use this website

2.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the CCLA Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors).

  • Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland.
  • Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003.

2.2 Please ensure that you understand whether or not you are an eligible investor in respect of the CCLA Funds, investments and investment services referred to on this website.

3. The purpose of this website

3.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice.

3.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. 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.

3.3 In using this website you may navigate between different pages which relate to different Funds. Each webpage will clearly identify the Fund to which it relates and bespoke information presented on each webpage will relate to the identified Fund.

4. Risk warning

4.1 The value of the CCLA 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.

4.2 Please refer to the Funds’ individual scheme particulars or prospectus 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.

4.3 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.

5. Complaints and compensation

8.1  All complaints will be handled in accordance with CCLA’s Complaints Policy  which can be found at

 If either CCLA IM or CCLA FM cannot meet its obligations (for example, where it has stopped trading and there are insufficient assets to meet its obligations), investors may be eligible to claim compensation up to a maximum of £85,000 from the Financial Services Compensation Scheme. There are limits on who is eligible to claim and which funds are covered. For further information about the Financial Services Compensation Scheme please refer to or phone 0800 678 1100.

6. CCLA's liability

6.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA.

6.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

6.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access and we will do our best to protect your information (including personal data). However, we accept no liability in the unlikely event of a breach of our secure computer servers.

6.4 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. We will not be liable for any viruses, code, files or programs designed to interrupt, restrict, destroy or otherwise compromise the integrity of the website or any hardware on which it is hosted. 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.

7. Third party websites

7.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and 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. You will be responsible for complying with the terms and conditions of use for any linked website.

8. Copyright and trade marks

8.1 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.

8.2 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.

8.3 No use of CCLA's name, logos and/or other trademarks (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.

9. Data protection

9.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes.

9.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) 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); and (vii) as otherwise agreed by you. Failure to provide the personal data requested (or to agree to the above or below uses) may mean that CCLA is unable to provide the services requested.

9.3 CCLA may pass your personal data to any other firm within CCLA but will not pass on any personal data to any other third party except: (i) where, in relation to the performance of its services to you, CCLA sub-contracts part of the services or any support services; (ii) as agreed by you; or (iii) where required to do so for regulatory purposes as set out above.

9.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK  in countries that do not provide the same level of data protection as the UK. In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner.

9.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years.

9.6 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 and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

9.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request.

10. Cookies

10.1 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.

10.2 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.

10.3 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.

10.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit

11. Recording of communications

 Your telephone calls and electronic communications with CCLA may be recorded. You agree that CCLA may deliver copies or transcripts of such recording to any court or competent regulatory authority.  Such records of conversation and/or communications with you will be available on request for a period of five years (or, where requested by the FCA, for a period of up to seven years) from the date when a record is made.

12. General

12.1 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.

12.2 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.

12.3 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 (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use.

18 August 2021             




Public sector funds

Public sector funds

The Local Authorities Property Fund (“LAPF” or “the fund”) is an unregulated collective investment scheme. As such, only persons who have been assessed as elective professional clients by CCLA in respect of the fund (or are already investors in the fund) are able to access details of the fund on this website.

If you have not been assessed as an elective professional client by CCLA or are not an existing investor in the fund, please contact us to discuss this fund:

Client Services

0800 022 3505

I confirm that I am a local authority/public sector body as defined in section 23 of the Local Government Act 2003. I also confirm that I have been assessed as an elective professional client by CCLA and/or I am an existing investor in the LAPF.