MIFIDPRU Remuneration Disclosure
Cyrus Capital Partners Europe, LLP (‘CCPE’ or the ‘Firm’) is authorised and regulated by the Financial Conduct Authority (‘the FCA’). CCPE is a London based Limited Liability Partnership. The Firm is majority owned by Cyrus Capital Partners, L.P. (‘CCP’) a SEC registered investment advisor, headquartered in New York. The Firm acts as a sub-advisor to CCP in CCP’s capacity as the investment advisor to certain private investment funds and management accounts; CCP is the Firm’s only client. CCPE is classified as a ‘small and non-interconnected MIFIDPRU investment firm’ (SNI firm) under the MIFIDPRU Handbook. Accordingly, these disclosures have been prepared as per the requirements contained within MIFIDPRU 8.6. The relevant rules and guidance for the Firm’s remuneration code is contained within the FCA’s SYSC 19G Sourcebook of the FCA’s Handbook.
The Remuneration Code (the “RemCode”) covers an individual’s total remuneration – fixed and variable. The
Firm incentivises staff through a combination of the two.
CCPE’s remuneration policy is designed to ensure that it complies with the RemCode and that its compensation arrangements:
1. Are consistent with and promote sound and effective risk management;
2. Do not encourage excessive risk taking;
3. Includes measures to avoid conflicts of interest;
4. Are in line with the Firm’s business strategy, objectives, values, and long-term interests; and
5. Are on a gender-neutral basis.
Proportionality
The FCA has sought to apply proportionality with respects to the Firm’s disclosures. CCPE’s disclosure is made in accordance with its size, internal organisation, nature, scope, and complexity of its activities and business model.
Application of the Requirements
The Firm completes the remuneration disclosure annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure will be made more frequently if there is a significant change to the Firm’s business model.
A summary of the Firm’s approach to remuneration for staff, including the decision-making procedures and governance in adopting the remuneration code:
• CCPE’s remuneration policy has been developed internally and agreed by the Firm’s Management Body and by CCP, in line with the remuneration principles laid down by the FCA.
• The policy is be reviewed at least annually or at any time the Firm’s management body or CCP considers it appropriate or necessary.
• Due to the size, nature, and complexity of the Firm, CCPE is not required to appoint an independent remuneration committee.
• The policy is gender neutral and quality objectives are considered when awarding variable remuneration.
• Remuneration awards are determined jointly by the Firm’s chief investment officer, and the chief investment officer of CCP. No individual has the ability to set their own remuneration.
• CCPE’s partner remuneration is determined under the relevant partnership arrangements.
• The Firm maintains a Conflict of Interests Log to document CCPE’s assessment of, and response to any conflicts of interest, which may include conflicts of interest relating to remuneration.
• When assessing individual performance, both financial and non-financial criteria must be taken into account.
• CCPE’s ability to pay a variable remuneration is based on the performance of CCP and the Firm overall, which, among other factors, will determine the total pool available for discretionary awards of variable remuneration.
Qualitative characteristics of the remuneration policies and practices:
• Effective risk management is core to the business and is considered as part of any remuneration awards.
• The Firm’s evaluation and remuneration criteria are based on staff’s individual professional experience, technical skills, role and responsibilities, contribution to business strategy and their performance during the relevant period.
• The policy makes a clear distinction between the criteria applied to determine fixed and variable remuneration.
• Basic fixed remuneration is payable in any event and represents a market rate for the duties undertaken, taking into account professional experience, technical skills, and role and responsibilities.
• Variable remuneration is only paid if it does not create any risk either for the regulatory capital position of the Firm, or any identifiable liquidity or capital needs.
• The various components of remuneration are as follows:
Fixed remuneration, including base salary, insurance, pension and healthcare schemes.
Variable remuneration, including cash awards and incentive fee allocations.
Quantitative information on remuneration:
With respect to the financial year ended 31 December 2022, the total amount of remuneration awarded to all staff interpreted under SYSC 19G.1.24G was as follows:
All Staff
Fixed Remuneration: 715,503
Variable Remuneration: 2,034,691