Effective Date: 01 July 2025
Introduction
The Investment Firm Prudential Regime (‘IFPR’) is the FCA’s prudential regime for MiFID investment firms which aims to streamline and simplify the prudential requirements for UK investment firms. The IFPR came into effect on 1 January 2022 and its provisions apply to Collington Capital Limited (“CC LTD” or “the Firm”) as an FCA authorised and regulated firm. Under the IFPR, the Firm is categorised as a small and non-interconnected (‘SNI’) MIFIDPRU investment firm.
The Firm is a an impact investment bank which was authorised by the FCA on 18 October 2024 (FRN: 1016276) and is part of the Collington Capital group, which also includes a not-for profit foundation (The Harriet Collington Foundation) and an impact advisory partnership (Collington Capital Partners LLP). The group’s purpose is to enable impact-led enterprises to access impact capital, with a focus on impact goals that address social inequality: poverty alleviation, better health, inclusive education, women’s empowerment, economic development and climate solutions. The aim is to mobilise US$500mn of catalytic philanthropic funding and investment capital over five years. The Firm delivers two service lines:
Capital Placement: Originating impact investment opportunities for investors and raising investment capital for impact fund managers and impact-led enterprises.
Scaling Impact: Building investment readiness, creating compelling investment propositions and raising new impact capital for impact-led enterprises.
The Firm is required to publish disclosures in accordance with the provisions outlined in MIFIDPRU 8 of the FCA Handbook. This disclosure document covers all aspects of the disclosure requirements within the scope of the MIFIDPRU rules applicable to SNIs that have not issued additional tier 1 instruments. Specifically, disclosure relating to the Firm’s remuneration policy and practices (see Schedule 1)
The Firm is not a member of a UK Consolidation Group. The disclosure is prepared annually on an individual basis. The Firm will consider making more frequent public disclosure where particular circumstances demand it, for example, in the event of a major change to its business model or where a merger has taken place.
The disclosure is published on a company website.
The Firm believes that its qualitative disclosures are appropriate to its size and internal organisation, and to the nature, scope and complexity of its activities.
This disclosure has been ratified and approved by the Board of Collington Capital Limited.
The annual audited accounts of Collington Capital Limited set out further information which complements the information in this disclosure. The audited accounts are freely available from UK Companies House.
This document does not constitute any form of financial statement on behalf of Collington Capital Limited. The information contained herein has been subject to internal review but has not been audited by the Firm’s external auditors.
Objectives
This document sets out the public disclosure under MIFIDPRU 8 for the Firm as of 31 March 2025, which is the Firm’s accounting reference date.
As a MIFIDPRU investment firm, the Firm must establish and implement disclosure requirements to provide investors, stakeholders and wider market participants an insight into how the Firm is run. This disclosure sets out the overarching requirements that apply to the Firm.
Policy and Disclosure Validation
Collington Capital Limited is committed to having robust internal controls to ensure the completeness, accuracy, and compliance with the relevant public disclosure regulatory requirements.
This document has been subject to internal governance and verification process, and approval by the Board in line with the Public Disclosure Policy that the Firm has adopted to ensure compliance with the regulatory requirements contained in MIFIDPRU 8.
The Policy requires internal challenge and oversight prior to approval and publication.
Schedule 1: Remuneration Policies and Practices
1. Remuneration Code
1.1 Introduction
The Remuneration Policy (“the Policy”) of Collington Capital Limited (“the Firm”) set out below covers all aspects of remuneration within the scope of the MIFIDPRU Remuneration Code applicable to small and non-interconnected (“SNI”) investment firms and all their staff (“Staff”).
‘Staff’, for the purposes of the Policy, is interpreted broadly, and includes anyone who personally provides services to the Firm (whether under the terms of an employment contract or contract for services, including pro bono), and is subject to the Firm’s supervision, direction, or control. Staff may be contracted to the Firm or other entities in Collington Capital Group and provide services to the Firm under a Services Agreement between the Firm and the relevant Collington Capital Group entity.
This Remuneration Policy provides for Staff to include all Managing Directors, Managing Partners, Executive Directors, Associate Partners, Investment Associates, Chief Operating Officer, Head of Finance, Head of Research and Head of Marketing and Communications providing services to the Firm. Staff does not include non-executive directors, consultants, advisers or other contractors who are not providing services under the Firm’s direct control or supervision, for example, Senior Advisers and Principal Consultants.
As a MIFIDPRU investment firm, the Firm must establish, implement and maintain gender neutral remuneration policies and practices that are appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the Firm.
The Firm’s remuneration policy and practices are gender neutral and do not discriminate staff members on the basis of gender or other characteristics.
This Policy is designed to promote sound and effective risk management by aligning risk and reward. The basic remuneration requirements in the MIFIDPRU remuneration code require that this policy:
- is in line with the strategy, risk appetite, objectives and long-term interests of the Firm;
- considers environmental, social and governance risk factors, the Firm’s culture and values and the long-term effects of the investment decisions taken;
- contains measures to avoid conflicts of interest;
- encourages responsible business conduct within the Firm; and
- does not encourage excessive risk taking as compared to the Firm’s risk appetite.
This Policy sets out the overarching requirements that apply to the Firm and applies these requirements in the Remuneration Framework at Schedule 1. The Firm’s Remuneration Framework sets out the granular approach to how the Firm applies the requirements set out here in practice.
The Firm’s Remuneration Policy is reviewed annually. The Remuneration disclosure under MIFIDPRU 8 will be made either before or on the same day the annual accounts for that year are published on the Companies House website. The Remuneration Policy (without Schedule 1) will be published on the Firm’s website www.collingtoncapital.com in accordance with MIFIDPRU 8.1.1.13R and MIFIDPRU 8.1.16, as set out in the Firm’s Disclosure Policy.
1.2 Risk appetite
The Firm has implemented policies, procedures and practices to identify, manage and monitor risk, including risks created from the way that remuneration arrangements are structured. The Firm’s risk appetite, strategy and management are detailed in the firm’s Internal Capital Adequacy and Risk Assessment (“ICARA”) process and comprise:
- Definition of the Firm’s risk tolerance;
- Risk identification;
- Risk documentation;
- Risk monitoring;
- Risk measurements; and
- Management mitigation
1.3 Conflict of Interest
The Firm has adopted policies and procedures aimed at mitigating any potential conflicts that may arise between staff members and the Firm, staff members and the Firm’s clients and between one client and another/others. The Firm maintains a Conflict of Interests Register which includes potential conflicts relating to remuneration, as well as the procedures the Firm has implemented to mitigate these conflicts. In circumstances where the Firm is unable to mitigate a conflict, the conflict is disclosed to its client and is included in the Firm’s Risk Register and additional capital is assigned to it, where appropriate, to ensure that if such a risk were to materialise, the business would be able to absorb any consequences.
2. Governance and oversight
Given the size, internal organisation and the nature, scope and complexity of the activities of the Firm it does not have a separate supervisory function or Remuneration Committee, therefore the Remuneration Policy’s supervisory function will be undertaken by the Firm’s Governing Body. The Governing Body of the Firm is the Firm’s Board. The Governing Body is responsible for approving and maintaining this Policy and overseeing the implementation of this Policy which will align the Firm’s remuneration practices with its risk tolerance.
The Governing Body is responsible for the total process of risk management, which includes the risks which emanate from the way in which the Firm compensates its staff. The Governing Body, in liaison with senior management, sets the risk profile of the Firm and its related policies and procedures as detailed below.
The Governing Body decides the Firm’s tolerance to risk – those risks it will accept and those it will not accept in the pursuit of its goals and objectives. In addition, the Governing Body ensures that the Firm has implemented an effective, ongoing process to identify risk, to measure its potential impact against a broad set of assumptions and subsequently to ensure that such risks are actively managed. The Governing Body sets the overall Remuneration Policy for the Firm.
The development and review of the Remuneration Policy is supported by the Managing Directors and the Group Chief Operating Officer. The Managing Directors will monitor the Firm’s Remuneration Policy in connection with its liquidity and capital requirements. The Managing Director with SMF 16/17 responsibilities, supported by the Group Chief Operating Officer, has the specific role of identifying, measuring and monitoring the risk profile of the Firm on a day-to-day basis and reporting, to the Governing Body. The Managing Director with SMF 16/17 responsibilities will ensure that the Firm’s Remuneration Policy complies with the relevant legislation and regulations. The Remuneration Policy will then be presented to the Firm’s Governing Body for its review and approval at least annually. The Governing Body is responsible for ensuring the Remuneration Policy is properly implemented.
The Firm is aware that conflicts of interest may arise if other business areas have undue influence over the remuneration of staff in control functions. The Group Chief Operating Officer has appropriate authority to act independently of staff in the Firm. The Group Chief Operating Officer reports directly to the Managing Partner of the related group company and indirectly to a Managing Director of the Firm and is remunerated according to objectives which are independent of the performance of the business areas which the Managing Director controls.
The Firm’s remuneration approach promotes long-term value creation and high standards of professional conduct through transparent alignment with the agreed corporate strategy and the Firm’s vision, mission and purpose. The Board believes the Firm’s remuneration structure is appropriate for the business and the industry it operates in and is efficient and cost-effective in delivering its long-term strategy.
Undeserved and excessive remuneration sends a negative message to all stakeholders, including the Firm’s staff, and causes long-term damage to the Firm and its reputation.
3. Financial Incentives Objectives
The objectives of the Firm’s remuneration practices are as follows:
- The Firm undertakes to reward all members of staff fairly, regardless of job function, race, religion, colour, national origin, sex, sexual orientation, marital status, pregnancy, disability or age;
- It is the policy of the Firm to operate competitive remuneration policies to attract, retain and motivate an appropriate workforce for the Firm. Alignment with the Firm’s purpose, mission, and values, and the opportunity to make a positive impact on the environment and society while achieving professional development objectives, enhances motivation among staff members;
- The Firm is also committed to ensuring that its remuneration practices encourage high standards of personal and professional conduct, support sound risk management and do not encourage risk-taking that exceeds the level of tolerated risk of the Firm, and are aligned with the Firm’s regulatory requirements;
- Rewards for all staff will be aligned to financial and non-financial performance criteria and risk profile, and in all cases will be in line with the business strategy, objectives, values, culture and long-term interests of the Firm; and
- The Firm will not allow any unfair or unjust practices that impact on pay.
The Firm uses the following financial incentives:
- fixed payments (day rates and monthly retainers);
- incentive payments (placement fee shares and quarterly bonuses);
- professional development opportunities.
The Firm’s financial incentives are designed to:
- raise staff satisfaction;
- recognise individual performance;
- attract and retain talent;
- encourage collaborative teamwork; and
- motivate staff to achieve Firm-wide objectives.
4. Remuneration Components: Fixed and Variable Pay
The Firm makes a clear distinction between the fixed and variable remuneration. In the first years of operations, the founding Managing Directors will be primarily compensated through variable remuneration with total compensation expected to be below make rate. This will preserve flexibility to allow staff to be attracted to the business on fixed and variable packages and to allocate profits to capital and build a strong buffer for downside scenarios whilst offering value for money for our clients as the business scales. This will be reviewed annually.
Over time, fixed remuneration (day rates and monthly retainers) will primarily reflect the market rate given a staff member’s professional experience and organisational responsibility as set out in the staff member’s job description and terms of engagement; and is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance. In the near term, while the business is establishing itself, to manage financial risk and maintain regulatory capital in accordance with the Board’s risk appetite, fixed remuneration for all staff will be in the form of modest day rates and / or retainers. The retainers will reflect time commitment and level of knowledge and experience and will be contingent upon the Firm making sufficient gross profit and operating profit to support the payment of day rates and retainers.
Variable remuneration (placement fee shares and quarterly bonuses) is based on performance and reflects the achievement of personal objectives as well as the broader contribution to the Firm and, in some but not all cases, the long-term potential performance of the staff member. In exceptional cases, variable remuneration may be based on other factors.
Monthly retainers and quarterly bonuses will be paid only when the Firm’s earnings before interest, tax, depreciation and amortisation is positive after retention to maintain regulatory capital within risk appetite over at least the next quarter to ensure the Firm maintains a sound capital base. The amount to be retained will be determined as a function of annual budgeting and forecasting of capital and liquidity
Over time, the Firm will ensure that the fixed and variable components of an individual’s total remuneration are appropriately balanced. In determining this balance, the Firm considers the following factors:
- The Firm’s business activities and associated prudential and conduct risks;
- The role of the individual in the Firm;
- The impact that different categories of staff have on the risk profile of the Firm;
- No individual must be dependent on variable remuneration to an extent likely to encourage them to take risks outside the risk appetite of the Firm;
- It may be appropriate for an individual to receive only fixed remuneration, but it will not be appropriate for them to receive only variable remuneration;
- Variable remuneration must not affect the Firm’s ability to ensure a sound capital base; and
- The variable component of a staff member’s remuneration will not exceed 20x the fixed component.
5. Financial and Non-Financial Performance Criteria
The Firm values Commitment, Learning, Generosity, Trustworthiness and Excellence and aspires for its staff to experience:
- deep commitment to organisational purpose
- encouragement and opportunities to learn and to develop
- generous sharing of knowledge and resources
- sense of belonging to a diverse, talented, trustworthy team
- pride in the excellent work the team delivers
The Firm’s staff are expected to commit to building long term trustworthy relationships based on shared values with colleagues and partners across the impact eco-system.
When assessing individual performance to determine the amount of variable remuneration to be paid to an individual, the Firm takes into account financial as well as non-financial criteria. Non-financial criteria should:
- form a significant part of the performance assessment process;
- override financial criteria, where appropriate;
- include metrics on conduct, which should make up a substantial portion of the non-financial criteria;
- include how far the individual adheres to effective risk management and complies with relevant regulatory requirements, and
- include the extent to which the individual’s behaviour supports Collington Capital’s values.
The criteria outlined below are used for the assessment of the financial and non-financial performance of:
The Firm / Service Lines
| Financial performance criteria |
| Revenue by Service Line |
| Gross Margin |
| Operating Margin |
| Net Income |
| Non-financial performance criteria |
| Full compliance with the FCA regulations |
| No customer complaints or GDPR breaches |
| Adherence to Firm’s accepted risk appetite |
Individuals
| Financial performance criteria |
| Revenue on mandates won/led |
| Revenue on investors managed |
| Non-financial performance criteria |
| Achievement of personal objectives |
| Commitment of time and effort to building the Firm’s business, extent to which individual has gone the extra mile |
| Positive customer relationships and outcomes, such as positive customer feedback and expansion of the relationship |
| Adherence to the firm’s risk management and compliance policies and procedures |
| Behaviour which promotes the Firm’s values of Commitment, Learning, Generosity, Trustworthiness and Excellence |
6. Total Amount Of Remuneration Awarded: 2024/2025
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.
In the financial year 2024/2025, CC LTD awarded the following amounts to staff (both contracted to CC LTD, or to another entitiy in CC LTD group and providing services to CC LTD under a services agreement between CC LTD and the relevant entity; in the latter case, only the portion of remuneration directly attributable to CC LTD business is included in the total remuneration disclosure below):
| Remuneration type | £ |
| Fixed remuneration | 3,382 |
| Variable remuneration | 0 |
| Total amount | 3,382 |