The Remuneration Code covers all aspects of remuneration that could have a bearing on effective risk management including salaries, bonuses, long-term incentive plans, options, hiring bonuses, severance packages and pension arrangements.2
As with other aspects of a firm's systems and controls, in accordance with SYSC 4.1.2 R remuneration policies, procedures and practices must be comprehensive and proportionate to the nature, scale and complexity of the common platform firm's activities. What a firm must do in order to comply with the Remuneration Code will therefore vary. For example, while the Remuneration Code refers to a firm's remuneration committee and risk management function, it may be appropriate for the governing body of a smaller firm to act as the remuneration committee, and for the firm not to have a separate risk management function.
The FCA2 may also ask remuneration committees to provide2 evidence of how well the firm's remuneration policies meet the Remuneration Code's principles, together with plans for improvement where there is a shortfall. The FCA2 also expects relevant firms to use the principles in assessing their exposure to risks arising from their remuneration policies as part of the internal capital adequacy assessment process (ICAAP).
risk management and risk tolerance (Remuneration Principle 1);2
supporting business strategy, objectives, values and long-term interests of the firm (Remuneration Principle 2);2
conflicts of interest (Remuneration Principle 3);2
governance (Remuneration Principle 4);2
risk adjustment (Remuneration Principle 8);2
pension policy (Remuneration Principle 9);2
personal investment strategies (Remuneration Principle 10);2
payments related to early termination (Remuneration Principle 12(e)); and2
deferral (Remuneration Principle 12(g))2