Sterling Investment Management Limited (“SIM”)
Remuneration Disclosures
November 2023

Remuneration policy is set by the board of SIM and is reviewed and approved at least annually.

SIM aims to set remuneration levels for its staff that enable it to recruit employees of the right calibre and to reward them appropriately.  In particular, SIM considers that employees who contribute towards the long-term financial success of the firm they work for should share in that success.

The board of SIM considers that SIM’s business is not subject to cyclical fluctuations and that the payment of bonuses out of the profits for one year would be appropriate to the risk profile of its business.  However, at present, SIM has does not operate any bonus arrangements.

When assessing the risks facing SIM, its board considers the risks that can arise from its remuneration policy.  The board of SIM believes that the current policy constitutes an appropriate means of mitigating those risks.  In particular, the board believes that the structuring of fee arrangements with clients is an effective way of reducing the scope for conflicts between the interests of the clients and those of the investment managers.  Where any conflict of interest does arise, this will be discussed and resolved with the manager of the client fund.

The remuneration policy of SIM enables it to maintain and enhance its capital adequacy since all remuneration is fixed and predictable and SIM is profitable after charging remuneration.

Remuneration levels within SIM are set to be competitive without attempting to match the highest levels in the industry.  Basic remuneration is set at such a level that no bonus need be paid unless the financial circumstances of the Firm warrant it.