MIFIDPRU Disclosures

1 Firm introduction

The FCA introduced the Investment Firms Prudential Regime (“IFPR”), a new regime for UK firms authorised under the Markets in Financial Instruments Directive (“MiFID”). The rulebook that formalises this regime is called MIFIDPRU; it seeks to address the potential harm posed by investment firms to their clients and the markets they operate in. These rules are publicly available and can be found at handbook.fca.org.uk/handbook/MIFIDPRU. 

Puma Capital Group comprises four businesses, including Puma Investment Management Limited (“Puma Investments”), focused on delivering long-term sustainable growth for its investors and partners. Together, they manage more than £850 million in assets from private and institutional investors, have lent more than £2.5 billion of development funding, and have assisted dozens of businesses across the UK elevate and build to deliver on their brilliant ideas.

Puma Investments is a private limited company that was incorporated in 2012 under Companies House number 08210180 with headquarters in London.  It is authorised and regulated by the Financial Conduct Authority (“FCA”) under FRN 590919.  It has regulatory permissions which enable it to carry out regulated activities in relation to its investment management business for the firm and its clients. As such, Puma Investments is within the scope of the MIFIDPRU rulebook and is categorised as a small and non-interconnected MIFIDPRU Investment Firm (“SNI Firm”).  

Under the provisions outlined in MIFIDPRU 8 of the FCA Handbook, Puma Investments is required to publish disclosures on its remuneration policy and practices. Puma Investments is a member of a UK Consolidation Group and prepares this disclosure annually in accordance with the requirements of MIFIDPRU 8.  Unless otherwise stated, all figures are as at the financial year-end, 31 December 2024.  This disclosure has been ratified by the Puma Investments Board and is published on its website.

2 Qualitative remuneration disclosures

In accordance with MIFIDPRU 8.6.2R, Puma Investments must make the following summary qualitative remuneration disclosures: a summary of its remuneration policy, including its approach to the remuneration of all staff, the objectives of the incentives, and a description of its governance arrangements.

Puma Investments believes that its qualitative disclosures below are proportionate to its size and internal organisation, and to the nature, scope and complexity of its activities as an SNI firm.

2.1  Remuneration objective and approach

Puma Investments has a Remuneration Policy which aims to ensure that its remuneration arrangements reward employees appropriately for their skills, knowledge and attributes that continue to the success of the business, but also promote effective risk management in the long-term interests of the firm and its clients. In particular, the remuneration arrangements aim to limit excessive risk-taking and avoid conflict of interests.

Puma Investments aims to deliver total remuneration at a level that is aligned to the market for each individual role, whilst also rewarding the overall performance of the Puma Investment business and the individual’s performance.  The Puma Investments remuneration policy contains fixed and variable components, with a clear distinction between the criteria for setting each type of remuneration.  

Fixed remuneration must reflect the individuals’ professional experience and role within the Firm. The fixed component is decided by considering factors such as market information in order to attract and retain skilled staff.  It is permanent, pre-determined and not dependent on performance. It makes up base salary paid to an individual plus any allowances.  

Variable remuneration must reflect performance and may be subject to performance adjustment.  It reflects both the performance of Puma Investments and the performance of the staff member as tested against the individual’s role profile. Variable remuneration may take the form of discretionary bonuses, formula-based commission or share of performance fees. 

Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Puma Investments and the staff member’s business unit.

Puma Investments ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.

2.2 Governance

The Puma Investments Board of Directors is responsible for reviewing and approving the remuneration policy, ensuring that remuneration practices are consistent with the promotion of effective risk management and balances the fixed and variable remuneration components made available to all staff.
 
The Chief Executive Officer, Chief People Officer and Chief Financial Officer are collectively responsible for remuneration decisions.  This includes reviewing and approving salary amendments and the bonus pool arising from the annual compensation review, noting that variable remuneration is adjusted in line with capital and liquidity requirements as well as the firm’s performance, with reports made to the Board as required.  Given the size, internal organisation and the nature, scope and complexity of its activities, Puma Investments does not have a separate supervisory function or Remuneration Committee.

3 Quantitative remuneration disclosures

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.  The figures provided below are for the financial year 1 January 2024 to 31 December 2024.