Realty Corporation Limited
is a private company, limited by shares, incorporated in England & Wales, registered number
10757555
. The registered office is 159 High Street, Barnet, Hertfordshire, EN5 5SU.
Introduction
Realty Corporation Limited (Realty, the "Firm") is a MIFID Investment Manager authorised and regulated by the Financial Conduct Authority (FCA). The Firm is required to comply with the disclosure requirements under the Investment Firms Prudential Regime (IFPR), which is set out in the FCA Handbook MIFIDPRU 8.
This disclosure has been prepared in accordance with MIFIDPRU 8.6 (Remuneration) of the FCA Handbook. As the Firm qualifies as a Small and Non-Interconnected (SNI) firm, the other sections of MIFIDPRU 8 do not apply. The disclosure therefore focuses solely on the Firm's remuneration policies and practices, proportionate to its size, internal organisation, and the nature, scope and complexity of its activities.
For the purpose of prudential regulations, the Firm is classified as a SNI (small and non-interconnected) firm and is subject to the basic requirements. The Firm is required to provide a level of detail in its disclosures that is appropriate to its size and internal organisation, and to the nature, scope, and complexity of our activities.
The Firm confirms that it remains classified as a Small and Non-Interconnected (SNI) firm under MIFIDPRU 1.2.3R. This classification is based on meeting all relevant thresholds, including total balance sheet assets below £100 million and total client assets under management below £1.2 billion. The Firm applies the principle of proportionality in determining the scope and depth of this disclosure.
Remuneration
The Firm is required to comply with the MIFIDPRU Remuneration Code under IFPR, which aims to ensure that the Firm has risk-focused remuneration policies that are consistent with and promote sound and effective risk management in the long-term interests of the Firm and its clients, and does not expose the Firm or its clients to excessive risk.
Our approach and objectives
The Firm has formulated its approach in remuneration policy and practices with reference to the guidance set out by the FCA. The policy is applied in line with SYSC 19G (MIFIDPRU Remuneration Code), which applies proportionately to SNI firms. The Firm considers the appropriate balance between fixed and variable remuneration as well as the constraints in place to avoid a conflict of interest between staff incentives and the best interests of clients.
The objectives of the Firm's remuneration policy are to:
- promote sound and effective risk management in the long-term interests of the Firm and its clients
- limit risk-taking and avoid conflicts of interest
- ensure alignment between risk and individual reward
- supporting positive behaviours and healthy firm culture
- encourage responsible business conduct
- discourage behaviours that can lead to misconduct and poor client outcomes
- align employees' interests with the Firm's long-term strategy and objectives
- be gender neutral, in line with the Equality Act 2010.
Governance and decision-making procedures
The Board of Directors of Realty Corporation Ltd (the "Board") is responsible for overseeing the implementation of our remuneration policy and ensuring our compliance with the MIFIDPRU Remuneration Code.
The Board of the Firm consists of the three most-senior professionals, all of whom are directors of the Firm or of affiliate entities.
One role of the Board of the Firm is to ensure the extent of the variable remuneration at the Firm cannot affect the Firm's ability to ensure a sound capital base. The Board of the Firm is responsible for overseeing the performance management process: reviewing and approving the remuneration policy, variable remuneration pool and caps, eligibility for participation in variable remuneration schemes, as well as the approval of variable remuneration awarded to individuals.
The Firm assesses its staff members under its performance management process on an ongoing basis with an annual performance assessment outcome being used as a contributing factor in the determination of remuneration.
The remuneration of senior staff in risk management and compliance functions is directly overseen by the Board of the Firm. Any remuneration to staff with control functions is awarded according to objectives linked to their functions and remains independent from the business units they oversee. No variable remuneration is awarded to members of the Board who do not perform any executive function in the Firm.
The Firm's remuneration policies and practices are developed in consultation with our external consultants, Bovill, and are reviewed regularly for best practice.
Key characteristics of remuneration policies and practices
All staff receive fixed remuneration in form of base salary; and are considered for discretionary variable remuneration in form of bonus, where eligible.
Fixed remuneration
Base Salary
The Firm reviews the base salary of its staff members on an annual basis by considering factors such as market information and individual performance.
Variable remuneration
Bonus
The Firm's bonus scheme is a discretionary reward scheme based on the performance of the Firm as a whole. All bonuses are dependent on the Firm's overall financial result to ensure a sound capital base. The bonus pool will take into consideration all types of current and future financial and nonfinancial risks and be determined on a sliding scale, using a monthly salary multiplier as a guide.
On an individual level, the scheme is designed and linked to both financial and non-financial criteria, rewarding behaviours that promote positive non-financial outcomes for the Firm and limiting potential behaviours contrary to the Firm's values.
The bonus pool and individual bonuses will be adjusted as deemed necessary by the Board of the Firm in consideration of the following:
- Any compliance or regulatory issues that have occurred or are under investigations internally or externally
- Any persistent or significant deviations in either financial or non-financial KPIs
- Any conduct related matters that have occurred or are under investigation internally or externally
- Any matters that adversely impact client outcomes
- Any other factors that may publicly impact the Firm's brand or reputation
Variable remuneration is not guaranteed, except in very limited circumstances such as sign-on, buyout, or retention awards as described below, and always subject to the Firm maintaining a sound capital base.
Control function staff are independent from the business units they oversee and are remunerated in line with the achievement of the objectives of their functions. The determination of the level of remuneration of such staff is independent of the performance of the business areas they oversee.
Dividends
The Firm has discretion to distribute dividends from time to time to the Firm's shareholders and the extent of which is dependent on the Firm's financial results to assure the Firm's capital base. Any decision to declare dividends is made in accordance with the Companies Act 2006 and the Firm's duties to maintain solvency and adequate capital resources.
Guarantees
The Firm is aware that non-performance-related variable remuneration, such as sign-on bonus, buyout award, retention award and severance pay, may weaken the alignment of risk and award.
From time to time, as circumstances warrant, the Firm will award the following remuneration:
- Sign-on bonus: only in the first year of service for newly hired material risk takers where the Firm has a strong capital base
- Buy-out award: involves the Firm compensating a new employee for reduced, revoked, or cancelled variable remuneration by the previous employer
- Retention award: dependent on a material risk taker remaining in role until the end of a restructuring or a wind-down of the Firm
- Severance pay: in case of early termination of the employment contract, the Firm retains the ability to make severance payments as long as they reflect the individual's performance over time and do not reward failure or misconduct.
Guaranteed variable remuneration is not part of the Firm's usual practice and is awarded only in exceptional cases consistent with regulatory expectations.
Quantitative disclosures
For the financial year ended 31 MAY 2026, the amount of remuneration awarded is as follows:
Total remuneration 248,700
(a) Fixed remuneration 187,200
(b) Variable remuneration 61,500