Regulatory Public Disclosure


This document sets out the public disclosure under MIFIDPRU 8 for Gen II Operator Services Limited (the “Firm”) as of June 2023, which is the Firm’s accounting reference date.

As a MIFIDPRU investment firm, we must establish and implement disclosure requirements to provide investors, stakeholders, and wider market participants an insight into how the Firm is run.

Remuneration Disclosure

As a MIFIDPRU investment firm, we must establish, implement, and maintain gender-neutral remuneration policies and practices that are appropriate and proportionate to the nature, scale, and complexity of the risks inherent in the business model and the activities of the Firm. Our remuneration policy and practices are gender-neutral and do not discriminate against employees based on gender or other characteristics.

The Firm has adopted a Remuneration Policy that complies with the requirements of Chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook.

1.1 Performance period

The Firm’s performance period is from July 2022 to June 2023.

1.2 Approach to remuneration for employees

The Firm’s remuneration approach is designed to support individual and corporate performance, encourage the sustainable long-term financial health of the business, and promote sound risk management for the success of the Firm and to the benefit of its customers, counterparties, and the wider market. Our remuneration approach promotes long-term value creation through transparent alignment with the corporate strategy.

The Board believes the Firm’s remuneration structure is appropriate for the business and the industry it operates in and is efficient and cost-effective in delivering its long-term strategy.

Undeserved and excessive remuneration sends a negative message to all stakeholders, including the Firm’s workforce, and causes long-term damage to the Firm and its reputation.

1.3 Financial incentives objectives

The objectives of the Firm’s remuneration practices are as follows:

  • The Firm undertakes to reward all employees fairly, regardless of job function, race, religion, colour, national origin, sex, sexual orientation, marital status, pregnancy, disability or age;
  • It is the policy of the Firm to operate competitive remuneration policies to attract, retain and motivate an appropriate workforce for the Firm;
  • The Firm is also committed to ensuring that its remuneration practices encourage high standards of personal and professional conduct, support sound risk management and do not encourage risk-taking that exceeds the level of tolerated risk of the Firm, and are aligned with the Firm’s regulatory requirements;
  • Rewards for all staff will be aligned to financial and non-financial performance criteria and risk profile, and in all cases will be in line with the business strategy, objectives, values, culture, and long-term interests of the Firm;
  • The Firm will not allow any unfair or unjust practices that impact on pay;
  • The Firm undertakes that it will not award remuneration using vehicles or methods the aim of which is to attempt to avoid application of the relevant FCA’s Remuneration Code.

The Firm uses the following financial incentives:

  • Salary and benefits packages;
  • Discretionary bonuses;
  • LTIP; and
  • Professional development opportunities.

Our financial incentives are designed to:

  • raise employee satisfaction;
  • recognize individual performance;
  • attract and retain talent;
  • encourage collaborative teamwork;
  • motivate staff to achieve Firm-wide objectives;
  • encourage quality work and excellent client service; and
  • reinforce behaviors and values.

1.4 Governance

The Gen II Group Remuneration Committee (“Remco”) is responsible for the Firm’s remuneration policy.

As an SNI, the Firm is not required to establish its own Remuneration Committee. Given the size, internal organization, and the nature, scope, and complexity of the activities of the Firm it has not formed a Remuneration Committee.

Remco is responsible for reviewing and approving remuneration, and ensuring remuneration policies across the Firm and the Group are consistent with the promotion of effective risk management. Remco is responsible for reviewing and approving salary amendments and the Firm’s bonus pool arising from the annual compensation review, with reports made to the Board as required.

1.5 Components of Remuneration

The Firm makes a clear distinction between fixed and variable remuneration.

Fixed remuneration primarily reflects a staff member’s professional experience and organizational responsibility as set out in the staff member’s job description and terms of employment; and is permanent, pre-determined, nondiscretionary, non-revocable, and not dependent on performance.

Variable remuneration is based on performance and reflects the long-term performance of the staff member as well as performance over the staff member’s job description and terms of employment.

The Firm will ensure that the fixed and variable components of an individual’s total remuneration are appropriately balanced. In determining this balance, the Firm considers the following factors:

  • The Firm’s business activities and associated prudential and conduct risks;
  • The role of the individual in the Firm;
  • The impact that different categories of staff have on the risk profile of the Firm or of the assets it manages;
  • No individual must be dependent on variable remuneration to an extent likely to encourage them to take risks outside the risk appetite of the Firm;
  • It may be appropriate for an individual to receive only fixed remuneration, but not only variable remuneration; and
  • Variable remuneration must not affect the Firm’s ability to ensure a sound capital base.

When assessing individual performance to determine the amount of variable remuneration to be paid to an individual, the Firm considers financial as well as non-financial criteria. Non-financial criteria should:

  • form a significant part of the performance assessment process;
  • override financial criteria, where appropriate;
  • include metrics on conduct, which should make up a substantial portion of the non-financial criteria; and
  • include how far the individual adheres to effective risk management and complies with relevant regulatory requirements.

1.6 Financial and Non-financial Performance Criteria

The Firm must consider both financial and non-financial criteria when assessing the individual performance of its staff. This aims not only to discourage inappropriate behaviors but also to incentivize and reward behavior that promotes positive non-financial outcomes for the Firm.

The Firm uses the following financial performance criteria:

  • Revenue, gross margin, and contribution performance against budget;
  • Cost recovery; and
  • Billing and debtor collection

The Firm uses the following non-financial performance criteria:

  • measures relating to building and maintaining positive customer relationships and outcomes, such as positive customer feedback;
  • performance in line with firm strategy or values, for example by displaying leadership, teamwork, or creativity;
  • adherence to the firm’s risk management and compliance policies;
  • achieving targets relating to environmental, social, and governance factors; and
  • diversity and inclusion.

Gen II does not separate financial and non-financial performance criteria between the firm, business units, and individuals.

1.7 Awarded Remuneration

Under MIFIDPRU 8.6.8R(2), the Firm must disclose the total amount of remuneration awarded to all staff, split into:

  • fixed remuneration; and
  • variable remuneration.
Remuneration Type £
Fixed remuneration 164,029
Variable remuneration 9,812
Total amount 173,841