Purpose of Disclosure

The disclosure is designed to provide information on Sapphire Capital Partners LLP’s (herein referred to as “Sapphire”) remuneration policies and practices.  Sapphire, as a MiFID investment firm that is prudentially regulated by the FCA in the UK, is required to comply with the Remuneration Code requirements within the scope of the MIFIDPRU Remuneration Code in the FCA Handbook at SYSC 19G.

The disclosures have been reviewed and approved by the partners of Sapphire and are published on the Sapphire website.  They have not been subject to audit.

As a private partnership, each of the partners of Sapphire is jointly and severally liable for the obligations of the firm, and this liability is unlimited.  

General

Sapphire seeks to reward staff fairly and appropriately for their contribution towards the success of the business and the level of service and performance delivered to its clients.  The remuneration policy is designed to be consistent with and promote sound and effective risk management and should not encourage excessive risk-taking that exceeds Sapphire’s risk tolerance.  It is designed to be in line with Sapphire’s strategy, risk management policy, culture and values.  The policy is intended to avoid conflicts of interest.  In order to achieve this, the remuneration of staff is reviewed annually upon the completion of the performance review and the setting of next year’s goals and objectives.  Bonus arrangements are also reviewed annually to ensure they are appropriate fair, and consistent.

Remuneration Code Material Risk Takers

The FCA requires Sapphire to identify individuals whose professional activities have a material impact on its risk profile (known as Material Risk Takers) and the remuneration rules and disclosures apply to those individuals.  The partners on the Management Committee represent that there are no employees identified as Material Risk Takers of Sapphire.

Remuneration Governance Framework

The partners of Sapphire, on behalf of the partnership, are responsible for the operational management of the firm.  They are responsible for the approval of all policies relating to staff remuneration with the firm, and they authorise salary increases and bonus awards made during the firm’s annual performance review process.  The partners take into consideration the general risks and market conditions that affect the business, ensuring that the remuneration awards do not conflict with the firm’s long-term goals and objectives.

Salary and Bonus Review Process

The salary levels awarded are mainly influenced by the individual’s performance in conjunction with Sapphire’s financial performance as well as economic conditions such as inflationary pressures on the cost of living.  The partners authorise the annual salary awards for all employees.

In terms of variable remuneration, the arrangements include a base salary, bonus and, where applicable, an employee share carry.  The latter is restricted to full-time employees upon completion of their probationary six-month period.  Award composition is based on a base salary, bonus, as well as the employee share carry agreement.  The fixed remuneration is comprised of the following components:

(1) Length of service

(2) Consumer Price Index (inflation)

(3) Performance-based, dependent on accreditations gained, conduct, as well as clear and measurable impact made towards Sapphire’s core values and objectives.

Bonus is awarded on a discretionary basis.  Risk-adjusted techniques and measures are applied when calculating the bonus pool, which mainly depends upon Sapphire’s trading results and cash position at year-end, and analysed in light of current and future economic market conditions.

Sapphire partners do not receive salaries during the year.  Rather they are paid via the distribution of profits and are therefore not classified as remuneration.

Sapphire maintains remuneration policies and practices per the UK’s implementation of AIFMD that are consistent with and promote sound and effective risk management and do not encourage risk-taking, which is inconsistent with the risk profiles or instruments constituting the AIFs it manages and does not impair compliance with its duty to act in the best interests of the AIFs it manages.  Remuneration includes both fixed and variable components.

Sapphire’s partners adopted a remuneration policy that aligns with the business strategy, objectives, values and interests of Sapphire, the AIFs it manages, and the investors in the funds Sapphire manages and includes measures to avoid conflicts of interest.

Disclosure in accordance with the Alternative Investment Fund Managers Directive (AIFMD)

The board of Sapphire maintains remuneration policies and practices per the UK’s AIFMD that are consistent with and which promote appropriate risk management, discouraging risk-taking that is inconsistent with the risk profiles or instruments constituting the AIFs it manages and does not impair Sapphire’s compliance with its duty to act in the best interests of the AIFs it manages.  The remuneration includes fixed and variable components.

Sapphire’s board adopts a remuneration policy which is in line with the business strategy, objectives, values and interest of the firm, the AIFs it manages and the investors in such AIFs and applies measures to avoid conflicts of interest.

The remuneration policy is reviewed annually by members of Sapphire’s board.

This disclosure has been updated as of February 2024.

Per AIFMD, Sapphire is required to provide the following quantitative information for its employees for work related to Sapphire’s role as AIFM during the 2023 financial year.

Fixed remuneration ________________________________ £213,330

Variable remuneration _____________________________   £16,525

Total remuneration ________________________________   £229,855

Number of staff____________________________________             8

Number of Material Risk Takers______________________           0

The remuneration is the overall remuneration for full time, part time, and intern staff that are involved with AIF related work.

The remuneration policy is reviewed annually by members of Sapphire’s Board. The last review was on 15 December 2023.