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

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for the CCLA Funds; 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 CCLA FM is a wholly owned subsidiary of CCLA IM.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 clientservices@ccla.co.uk.

1.5 These Terms apply to the websites for the CCLA Funds.The CCLA Funds are the CBF Funds, the COIF Funds and the Local Authority Funds.

2. The CBF Funds

2.1 The CBF Funds are:

  • CBF Church of England Deposit Fund.
  • CBF Church of England Fixed Interest Securities Fund;
  • CBF Church of England Global Equity Income Fund;
  • CBF Church of England Investment Fund;
  • CBF Church of England Property Fund and;
  • CBF Church of England UK Equity Fund;

2.2 The CBF Funds are established under the Church Funds Investment Measure 1958 and the Trustee Act 2000.The CBF Funds are neither a collective investment scheme (CIS) nor an unregulated CIS for the purposes of FSMA.

2.3 The trustee and operator of the CBF Funds is CBF Funds Trustee Limited (CBFFT), a company limited by guarantee registered in England and Wales with company number 5957490.CBFFT is a charity registered with the Charity Commission of England and Wales under charity number 1116932.

2.4 CBFFT has delegated the investment management, administration, registrar and secretarial functions of the CBF Funds to CCLA IM.

2.5 CBFFT has appointed HSBC Bank plc to oversees its activities in relation to the management and administration of the CBF Funds and to act as custodian in respect of the CBF Funds.HSBC Bank plc is a company incorporated in England and Wales with company number 14259.

The COIF Funds

3.1 The COIF Funds are:

  • COIF Charities Deposit Fund.
  • COIF Charities Ethical Investment Fund;
  • COIF Charities Fixed Interest Fund;
  • COIF Charities Global Equity Income Fund;
  • COIF Charities Investment Fund and;
  • COIF Charities Property Fund;

3.2 The COIF Funds are established under the Charities Act 1993 (now Charities Act 2011).Each COIF Fund is an unregulated CIS for the purposes of FSMA and an alternative investment fund (AIF) for the purposes of the Alternative Investment Fund Managers Directive (Directive 2011/61/EU) (AIFMD).The COIF Funds are also charities registered with the Charity Commission of England and Wales.

3.3 The Manager of the COIF Funds is CCLA FM.CCLA FM has delegated the investment management of the COIF Funds to the Investment Manager, CCLA IM.

3.4 The corporate trustee of the COIF Funds is HSBC Bank plc (company number 14259), which also acts as custodian.HSBC Bank plc is the depositary for the purposes of AIFMD.

4. The Local Authority Funds

4.1 The Local Authority Funds are:

  • The Diversified Income Fund (DIF).
  • The Local Authorities' Property Fund (LAPF and);
  • The Public Sector Deposit Fund (PSDF);

4.2 DIF is a sub-fund of the CCLA Authorised Contractual Scheme, an umbrella non-UCITS retail scheme and authorised contractual scheme (ACS) entered on the Financial Services Register under product reference number 757825. The ACS Manager is CCLA FM which has delegated the investment management function to CCLA IM. The depositary and custodian is HSBC Bank plc (company number 14259).

4.3 LAPF is established under the Trustee Investments Act 1961, and is an unregulated CIS and an AIF for the purposes of AIFMD.The Manager of the LAPF is CCLA FM, which has delegated the investment management function to CCLA IM.The trustee of LAPF is The Local Authorities' Mutual Investment Trust (company number 700132). Investment in the Fund is for Eligible Local Authorities who are Professional Investors only.

4.4 PSDF is a sub-fund of the CCLA Public Sector Investment Fund (PSIF), an umbrella UCITS fund incorporated under the Open-Ended Investment Company Regulations 2001 (SI 2001/1228) in England and Wales and registered with company number IC000839. PSIF is entered on the Financial Services Register under product reference number 527266.PSIF is an umbrella type investment company and a qualifying money market fund (QMMF) (see Term 7.3 below).The authorised corporate director of PSIF is CCLA IM and the depositary is HSBC Bank plc (company number 14259).

5. Who may use this website

5.1 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 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.

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

6. The purpose of this website

6.1 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.

6.2 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.

6.3 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.

7. Risk warning

7.1 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.

7.2 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.

7.3 In particular, investors and potential investors should be aware that PSDF is a QMMF.PSDF only invests with high quality issuers at a high level of diversification while maintaining a low weight average maturity.These factors mean that PSDF maintains a low level of overall risk.However, a purchase of shares in the PSDF is not the same as making a deposit with a bank or other deposit taking body.The value of the share is not insured or guaranteed and there can be no assurance that a stable net asset value per share is guaranteed.Please refer to the PSIF prospectus for full risk warnings.

7.4 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.

8. Complaints and compensation

8.1 We are covered by the Financial Ombudsman Service (FOS) which is an independent service for settling disputes between financial services firms and their clients.The FOS is available to consider complaints from most clients if they cannot be settled through our own complaints procedures.There are certain rules as to eligibility and timing requirements laid down by the FOS which must be complied with.

8.2 PSDF and DIF are authorised funds as set out at Term 4 above.Investments and deposits in PSDF and DIF are therefore covered by the Financial Services Compensation Scheme (FSCS).There are limits on who can claim and the amount of compensation available.Further information about FSCS is available at www.fscs.org.uk.

8.3 The COIF Funds, the CBF Funds and LAPF are not authorised funds and therefore investments and deposits in these Funds are not covered by FSCS.However, unitholders and/or shareholders may be eligible for compensation under the 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.

9. CCLA's liability

9.1 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.

9.2 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.

9.3 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.

9.4 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.

10. Third party websites

10.1 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.

11. Copyright and trade marks

11.1 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.

11.2 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.

11.3 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.

12. Data protection

12.1 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.

12.2 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.

12.3 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.

12.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK and EEA 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.

12.5 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.

12.6 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 upon payment of a fee 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 Officer at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

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

13. Cookies

13.1 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.

13.2 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.

13.3 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.

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

14. General

14.1 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.

14.2 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.

14.3 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.

[MAY 2017]

Public sector funds

Public sector funds

I confirm that I have read and accepted the terms of this website and that I am a local authority/public sector client as defined in section 23 of the Local Government Act 2003.