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Information About Us
We are a limited liability partnership in England and Wales with our address at 21 Grosvenor Place, London SW1X 7HU. We are authorised and regulated by the Financial Conduct Authority.
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We may revise these terms and conditions from time to time. These changes will be brought to your attention by publishing them on the Site. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it.
This policy describes how Genesis will collect and process your personal information as a result of your use of this Site. Please read it carefully to understand our views and practices regarding your personal data and how we will treat it.
How Do We Collect Your Personal Information?
We may collect your personal information as a result of your use of this Site if you log in to the Site, if you complete an online form or if you otherwise submit any personal data to us via this Site.
How Do We Use Your Personal Information?
Genesis will retain and use your personal information to allow you to access this Site and to provide products and services as requested by you. Genesis may also retain and use your personal information for any additional purposes disclosed to you at the time of collecting your personal information.
You agree that Genesis may use your personal information to contact you, whether in relation to products or services which you have requested, or in relation to new products and services and other related matters which we feel may be of interest to you. You agree and consent to the use by Genesis of electronic mail to communicate with you for this purpose.
Genesis will not intentionally disclose your personal information to any third party without your consent, unless it is necessary to do so in order to deal with any request or inquiry you have made, or in the event of any sale of the business of Genesis, or where we are required to do so by law, save that, we may disclose your personal information to our affiliates, partners and services providers, including, without limitation, brokers, administrators, accounting firms and agents, if such disclosure is necessary to provide products or services requested by you or to facilitate your use of our Services, including your access to this Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent unauthorised access.
Accessing Your Personal Information
Under the UK Data Protection Act 1998, you may have the right to request a copy of any personal information Genesis holds about you. To request this information please write to:
Genesis Investment Management, LLP
21 Grosvenor Place
If you wish to withdraw consent you have previously given to any use of your personal information, or if you believe that we are storing information relating to you that is incorrect, please write to The Data Protection Officer at the above address.
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In addition to the information provided elsewhere, prospective investors in the Genesis Funds should consider the risks involved in investing in the Genesis Funds including, but not limited to, those specifically discussed below.
Investments in the Genesis Funds are subject to the normal market fluctuations and other risks inherent in equity investment. The value of investments and the income from them may go down as well as up and investors may not get back the amount originally invested. The Funds should be considered long term investments. It is important to note that past performance is not necessarily a guide to future performance and there is no guarantee that any stated investment objectives will be achieved.
Illiquidity of Shares
Shares in some of the Genesis Funds are subject to restrictions on redemption, with extensive notice periods being required for voluntary withdrawals by shareholders. In such situations, the redeeming Shareholder will bear the market risk of a decline in the value of the Fund’s assets occurring between the date the notice of redemption is given and the relevant Valuation Day.
Investments in Emerging Markets
Investment in Emerging Markets may involve additional risks not typically associated with investing in more developed markets. These include:
- Economic and political risks
- Reduced liquidity and increased volatility due to smaller securities markets
- Less developed regulatory and reporting regimes, combined with less publicly available information about issuers of stock.
- Investment and repatriation restrictions
- Difficulties in the pursuit of legal remedies
- Less developed settlement mechanisms
Currency Exchange Rates
The Funds will compute their Net Asset Value in US dollars. Currency exchange rate movements may affect the value of an investment favourably or unfavourably, separately from the gains or losses otherwise made by such investments.
Smaller Companies/Limited Operating History
Funds investing in smaller companies invest in securities which may be both more volatile and less liquid than the securities of larger companies, as a result of inadequate trading volume or restrictions on trading. Investments in companies with limited operating histories are more speculative and entail greater risk than do investments in companies with an established operating record.
The Funds could be adversely affected by future changes in the applicable tax laws, including without limitation those relating to foreign withholding.
Aggregation of Orders
In managing the Funds, the Investment Manager may combine orders for the Funds with those of other clients. This procedure may operate on some occasions to the disadvantage of the Funds and on others to the advantage of the Funds.
Compliance with the UK Stewardship Code
The disclosure below describes how Genesis complies with the UK Stewardship Code as published by the Financial Reporting Council.
Principle 1 – How stewardship responsibilities are discharged
The role of stewardship within the investment process
Genesis is a specialist investment manager which focuses purely on investment in emerging market equities for institutional investors. Our goal is to identify and invest in high-quality companies, which we characterise as those with a persistent capacity to generate sustainable excess returns. We recognise that environmental, social and governance (ESG) factors can expose potential investment opportunities and risks, reflect the quality of management and impact a company’s financial performance. We believe the evaluation of ESG factors contributes to our broader and deeper understanding of the strategic direction of a company and allows for a more accurate assessment of the risks and future costs or burdens facing a company.
As a bottom-up investor, our investment approach lends itself naturally to the integration of ESG factors at the company level. Genesis meaningfully integrates ESG factors into our investment process as part of our initial and as part of our ongoing qualitative judgement of a company's sustainable competitive advantage. We formally rank companies based on our qualitative judgement of their sustainable competitive advantage or economic 'moat', and hence the likely persistence of excess returns. Our Investment Team documents the quality rating of a company as part of their investment recommendations and the quality rating covers a range of material factors including the views on ESG and potential ESG issues, where relevant. Our systematic assessment of the quality of a company continues for so long as the holding is in client portfolios; in line with our investment approach, we aim to maintain an investment for several years. Our quality assessment is informed by our ongoing research, monitoring of a company's business and engagement with company management.
Our investment process is founded on proprietary internal research with particular emphasis on adding value at the company analysis level. The distinctive feature of our research process is its independence: views are formed by visiting countries and meeting companies. Every company we cover is assigned a'stock owner' from our Investment Team who takes the lead role on the research and engagement with that company.
We maintain an on-going dialogue with company management through meetings, site visits, calls and correspondence and we use these meetings to discuss the company's strategy, governance and to raise concerns, including concerns on ESG matters, we feel may have an impact on long-term performance and valuation.
When authorised, we aim to vote on all resolutions. Voting decisions are based on our set of corporate governance principles (which are available via the link below) and made in the best interests of clients. We are mindful of the varied market practices across emerging market countries and we recognise that more than one governance model may be effective. Thus we take a pragmatic approach considering the circumstances of each vote and each company. We view voting as an investment function and we provide feedback to boards and management on significant voting matters and this in turn informs our ongoing monitoring strategy and company engagements.
Principle 2 – Managing conflicts of interest in relation to stewardship
Our sole business is to provide investment management and advisory services to institutional clients invested in emerging markets equities. Genesis acts independently of its parent, Affiliated Managers Group, Inc. (AMG) and all of the other affiliates of AMG. Genesis does not invest as a principal nor does it make markets or underwrite. Genesis does not hold client money or assets nor provide investment research to third parties. Genesis does not permit personal trading in companies which are held in client accounts. Genesis' investment process is team based. All material operating decisions are determined by committees and we maintain both a strict segregation of duties between operating areas, and a robust control environment.
We maintain a Conflicts of Interest document that identifies actual and potential conflicts of interest, and outlines how conflicts are monitored, the controls in place to mitigate conflicts and the steps we take to resolve potential conflicts. Our Conflicts of Interest document is available via the link below.
If a conflict of interest should arise and potentially damage the interests of a client and the steps taken to manage the conflict have not achieved, Genesis will consider whether disclosure is appropriate or, bearing in mind the risks involved, refraining from acting. In any event we would expect to inform the client and seek further instructions.
Principle 3 – Monitoring of investee companies
As noted above, our investment process is founded on proprietary internal research with particular emphasis on adding value at the company analysis level. We believe that interviews with company management are the most effective insight into stocks in emerging markets and they make up the core of our research process. We do not make an investment without interviewing a company's management (often several times).
Management quality is assessed by our Investment Team through ongoing dialogue with the board and company management via regular meetings, site visits, calls and correspondence. During these interactions, the stock owners engage on a variety of material issues, including strategy, financial performance, ESG issues, or other matters affecting long-term shareholder value. We look for management's enlightened and long-term commitment to a sustainable business model including their attention to and understanding of ESG risks and opportunities. We carefully review management's track record focusing on relationships with various stakeholders, accountability, past practices and progress. A key issue is the alignment of interests with minority shareholders. We also take into account the quality of a company's reporting.
Our monitoring of investee companies is ongoing and we regularly engage with companies outside of the shareholder meeting/voting cycle. Meeting notes are maintained in a central database available to the full Investment Team to assist and inform the monitoring and engagement process and also to track a company's progress.
In 2015 we conducted over 1,000 interviews with companies (potential and existing investments, competitors and supply chain entities) in order to further develop knowledge of individual companies and allow a comparison with peers and competitors globally, including in developed markets. Our aim is that our communications with investee companies are honest, frank and constructive. As a result we have a strong preference that such engagement activities remain private.
During the course of Genesis' business activities, we may be asked by a company if we are willing to become an insider. Generally, we are not willing to do this as we want to retain the ability to trade in companies that are held in client portfolios; however, in limited circumstances (for example to become a cornerstone investor) and typically for a limited period of time, we may decide to become insiders. Our approach to being made insiders is managed by the provisions set out in our Code of Ethics.
Principle 4 – Escalation of activities to protect and enhance shareholder value
As noted, we engage with companies both prior to any initial investment and regularly throughout the period of investment. Engagement with company management is fundamental to our investment process and takes various forms, formal and informal. Each engagement is tailored to the specific company and relevant issues as determine by the stock owner.
We have been fortunate to develop good long-term relationships with our investee companies and feel that our views are considered seriously by management and boards. If there was a particular issue where we felt a company was not managing its risks and or opportunities in a responsible manner, then the stock owner would engage in a more focused dialogue and management's reaction and receptiveness to such discussions is often meaningful. Because of the emphasis we place on the quality of management, the incidence of these types of discussion are, in our experience, infrequent.
If however the normal dialogue with management has failed to achieve the desired outcome (for example, where we have concerns on strategy, remuneration or governance structures), we will consider a range of options, including for example meeting privately with the CEO or Board, speaking directly with one or more independent directors, or formalising our concerns in a letter to the Board.
Where appropriate and where permissible under applicable laws, we may discuss our stewardship concerns with other shareholders or join in a communication to the Board (see Principle 5 below). We may also consider voting against management, reducing or selling the position or more extreme action such as litigation.
Each case is assessed by the stock owner on its merits and in the best interests of our clients but where we decide to escalate our engagement activities, our long-term investment approach is generally an advantage with respect to management's receptiveness to our concerns. Where engagement requires escalation, the stock owner will involve other members of the Investment Team and, where appropriate, additional internal and external resources such as legal, compliance and other specialists.
Principle 5 – Acting collectively with other investors
As outlined above, our stock owners engage with companies on an ongoing and regular basis and we prefer one-on-one meetings with company management and sharing any concerns privately in order to improve the outcome for our clients. Where companies in client portfolios start behaving in a manner detrimental to minority shareholders' interests we may consider collaborating with other investors and engaging collectively with the management of a company regarding particularly serious corporate issues. As long-term investors, we are often aware of other investors and managers which have or represent significant long-term investments in a company and it is with such long-term investors that we are most likely to find common ground. In such instances and subject to applicable laws and regulations, we may share our views with other institutions, or draft or join a collective communication to a company or its Board to effect change. We will also consider joining engagement activities coordinated by corporate governance bodies. For example, we have pooled positions with other shareholders to nominate and elect independent directors. We will also consider publicly supporting a letter drafted by shareholders' rights groups.
Any collective engagement would be undertaken on a case-by-case basis and with due regard to the relevant regulatory provisions concerning acting in concert and insider dealing. Collective engagements are limited to when we believe it will be in our clients' best interests. Parties interested in contacting Genesis regarding any collective engagement activities should in the first instance get in touch with Marguerite Mills, Head of Investment Governance.
Principle 6 – Voting and disclosure of voting activity
Where clients have delegated to us the responsibility to vote proxies, we vote in the best interests of such clients and aim to vote all of their shares in all markets. Our Proxy Voting Guidelines outline our overall approach to voting and ensure that it is conducted in an appropriate manner.
In evaluating specific voting issues, stock owners may engage directly with company management and directors and we may also contact interest groups, other shareholders and research providers. Where appropriate, and particularly where we vote against management, we will contact the company to explain our decision-making process and promote best practice.
Subject to the provisions of individual client mandates, securities lending is undertaken. Where securities are on loan ahead of a general meeting or corporate action and Genesis has proxy voting responsibility, it is our policy to request that such securities be recalled to enable us to vote the shares.
Genesis has contracted with Institutional Shareholder Services, Inc. (ISS), an independent third-party provider of proxy voting and corporate governance services. Specifically, ISS has been retained to provide proxy research and recommendations, execute votes as instructed by Genesis and keep various records necessary for tracking proxy voting materials and proxy voting actions taken for our clients' accounts.
ISS recommendations are one form of external research which is factored into the decision-making process by our Investment Team. We analyse each voting issue independently and do not necessarily vote in line with company management or the ISS recommendations.
Principle 7 – Reporting on stewardship and voting activities
We provide a range of qualitative and quantitative information to our clients, typically on a quarterly basis. Furthermore, we have calls, reviews and meetings with clients and their appointed representatives on a regular basis at which we will discuss specific topics of interest arising from the stewardship process and engagement with investee companies.
Furthermore, we provide all clients with a copy of our Proxy Voting Guidelines and regular (typically semi-annual) reports of all proxy voting matters. This proxy voting report includes details of the frequency, matters and reasons why we may have voted against management. In addition, our voting record for the last five years is available at: https://vds.issgovernance.com/vds/#/MTcy/
The holdings in client portfolios are formally reviewed on a regular basis with a focus on transparency to promote robust and constructive challenge from across the Investment Team. A sub-committee of the Investment Team ensures that the investment process has been followed. In addition, Genesis’ internal controls, including those concerning proxy voting arrangements, are subject to independent, external review by PricewaterhouseCoopers LLP through the annual completion of a Report on Internal Controls (ISAE 3402 and AAF 01/06). A copy of the Report on Internal Controls is provided to all clients.
Any queries regarding Genesis' compliance with the UK Stewardship Code should be addressed in the first instance to the Client Services Department (email: ClientRelationshipsTeam@giml.co.uk; Tel: 020 7201 7200).
Pillar 3 Disclosure – Capital
The European Union Capital Requirements Regulation and Directive (“CRR” and “CRD 4”) have created a regulatory capital framework across Europe governing how much capital financial services firms must retain, based upon the risks associated with the firm’s business and the firm’s control environment. In the United Kingdom, these requirements have been implemented by the Financial Conduct Authority (“FCA”) which has created rules and guidance in the General Prudential Sourcebook (“GENPRU”) and the Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”).
The FCA framework consists of three ‘Pillars’:
- Pillar 1 specifies the minimum capital requirements that firms need to retain to meet their credit, market and operational risk;
- Pillar 2 requires each firm, and the FCA, to take a view on whether the firm needs to hold additional capital against firm-specific risks not covered by Pillar 1 (this process is carried out through the Internal Capital Adequacy Assessment Process (“ICAAP”)); and
- Pillar 3 requires public disclosure of information about the firm’s underlying risks, risk management controls and capital position which will allow market participants to assess key information.
The provisions for Pillar 3 disclosure are set out in Rule 11 of BIPRU and this document has been produced in order to meet the disclosure obligations of Genesis Investment Management, LLP (“GIM”).
The rules provide that a firm may omit one or more of the required disclosures if it believes that the information is immaterial, confidential or proprietary in nature. In these instances GIM has outlined the reasons for non-disclosure.
Background Information about the Firm
GIM provides investment management services to institutional investors in Emerging Markets and provides investment advisory and portfolio administration services to fellow entities of the Genesis Group. GIM commenced operations on 17th June 2004 and is authorised and regulated by the FCA and SEC. GIM is classified by the FCA as a limited licence BIPRU firm as it does not hold any client assets or deal on its own account.
GIM is part of the Genesis Group. Given the close operational relationship between the key members of the Group and their financial interdependence, capital adequacy has been assessed on a consolidated basis for the whole group and for each critical subsidiary even though GIM is the only regulated member of the Group operating within the European Economic Area.
There are no current or foreseen material, practical or legal impediments to the prompt transfer of capital resources within the Group or repayment of inter Group liabilities.
|Genesis Group Entity||Abbreviation|
Country of Organisation
|Genesis Asset Managers, LLP||GAM||US||SEC, GFSC|
|Genesis Investment Management, LLP||GIM||UK||FCA, SEC|
|Genesis Asset Managers International Ltd||GAMIL||UK||N/A|
|Genesis Management Australia Ltd||GMAL||Australia||ASIC|
Although Genesis executes its strategy within a volatile asset class, its appetite for risk is low and the business has been structured to minimise risk to clients, owners and employees. This means that:-
- Genesis only provides advice to clients and the arrangement with each client is entered into through a written Investment Management Agreement that has been approved by both Genesis General Counsel and Senior Management;
- A risk management framework has been established in order to minimise the business and operational risk from inadequate or failed internal processes, people and systems; and
- Genesis’ internal control framework is subject to annual review and confirmation by external auditor PricewaterhouseCoopers, LLP (“PwC”).
Risk Management Framework
The GAM Operating Committee acts as the principal strategy and policy setting forum for GAM. It meets quarterly, and receives formal reports on investment, operations, risk and compliance matters. The Operating Committee approves changes to material Firm-wide policies (e.g. conflicts of interest). Given the size of the GAM Operating Committee, all matters are considered by that Committee as a whole with the exception of i) risk management and internal control matters and ii) finance and audit, which are the responsibility of the Group Risk and Group Audit Committees respectively.
The Group Risk Committee, which is composed of three Independent Members of the GAM Operating Committee (attended by the CRO and Enterprise Risk Officer), is responsible for:
- oversight of risk management;
- monitoring and reviewing the internal control and risk management systems.
The Group Audit Committee is composed of two Independent Members of the GAM Operating Committee and is responsible for:
- reviewing the Partnership’s accounting policies;
- making recommendations to the Operating Committee in relation to the appointment of external auditors;
- monitoring the independence and objectivity of auditors; and
- reviewing the Annual Financial Statements.
Day-to-day business is overseen by a number of formal committees of GIM, the most important of which are:
- GIM Operating Board – the senior executive committee for Genesis, with overall responsibility for managing the Firm, including all financial aspects of Genesis’ operations and proposing the risk appetite for the Firm;
- Risk Management Committee – responsible for overall risk management, the review of the internal control and assurance framework, including compliance monitoring, assessing regulatory developments and oversight of the Valuations Committee;
- Portfolio Coordination Team (Investment) – receive stock recommendations from the Investment Team, responsible for assessing correlated risks and optimising the portfolio in terms of risk and return;
- Operations Executive Committee – responsible for day-to-day management and long-term planning of the Firm’s operations;
- Valuations Committee – responsible for fair valuation of securities for which market prices are not readily available or for which prices from standard sources are deemed inappropriate; and
- Client Services Group – coordinates Client Services activity.
GIM’s internal control framework is also subject to annual independent audit. A Report on Internal Controls (ISAE 3402 and AAF 01/06) is produced annually for clients and is audited by PwC.
The principal risks faced by Genesis and GIM are business and operational.
Business risks are mainly reputational as investment under performance or loss of key personnel may result in clients choosing to withdraw the funds that Genesis manage and hence reduce revenues. Other business risks include volatility in emerging markets and emerging markets becoming unattractive as an asset class. These risks are mitigated by Genesis’ experienced Investment Team through their disciplined investment approach, aligned long term incentives and the business’ strong cost controls.
Operational risk is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events, including legal risk. As the majority of risks faced are classified as either operational or business risks, most of GIM’s risk management efforts are focussed on these risks, where they can be mitigated, as outlined above under the Risk Management Framework section.
Other risks considered in the ICAAP include the following:
- Credit risk
- Market risk
- Interest rate risk
- Liquidity risk
- Remuneration risk
- Insurance risk
- Other risks
Credit risk is the risk of financial loss arising from a counterparty failing to meet its obligations to repay outstanding amounts as they fall due. GIM is not exposed to high levels of credit risk, as it does not undertake any principal trading in relation to its own account, only places cash on deposit with a select list of highly rated counterparties and non-payment of management fees has historically been negligible.
The market risk due to adverse changes in market prices and/or exchange rates reducing the value of client portfolios and impacting revenues is treated as a business risk rather than a market risk. GIM is subject to a small amount of foreign exchange market risk as some management fees and assets are denominated in euros. At the Group level, foreign exchange risk is carefully monitored as management fees are earned in US dollars and most costs are paid in £ sterling.
Interest rate risk is negligible as GIM and the Group do not have any borrowings. Cash balances are subject to changes in interest rates, although interest income is only a small element of total revenues.
Liquidity risk is the risk that the firm does not have sufficient financial resources to enable it to meet its obligations as they fall due. Group policy is to hold minimum liquidity levels at all times. Liquidity risk is however not considered a key risk due to the monitoring of management fee receipts, strong control over costs and the timing of remuneration payments.
Remuneration risk is addressed by the policies and practices described in the separate Pillar 3 Disclosure – Remuneration, below.
Insurance risk is considered annually by the Risk Management Committee and Group Risk Management Committee.
Other risks are considered as part of the Risk Management Framework but are not considered necessary for disclosure due to their perceived lower significance.
With respect to stress testing, the anticipated worst case for each of the business and operational risks identified was estimated through the impact on fees earned and significant one-off losses. It was determined that the impact of these worst risk outcomes do not pose a strategic risk to GIM’s business. The results of the reverse stress testing reflect those from the stress testing and did not identify any need for changes to either the controls currently in place or the Firm’s overall strategy.
Capital Requirements and Resources
Pillar 1 Capital Requirement
GIM’s Pillar 1 Minimum Capital Requirement is the greater of:
- Base capital requirement of €50,000
- The sum of its market and credit risk requirements; or
- The fixed overhead requirement
The Minimum Capital Requirement was determined as being the fixed overhead requirement and calculated as £2,470,000 for 2015.
Pillar 2 Capital Requirement
GIM’s Pillar 2 Capital Requirement is assessed as part of the Internal Capital Adequacy Assessment Process (“ICAAP”). This involves detailed assessment of all relevant risks, scenario analysis and stress testing, reverse stress testing and wind down analysis. The fixed overhead requirement under Pillar 1 is deemed by GIM to be sufficient capital to meet its current needs. As no additional capital is currently required under Pillar 2, GIM’s Pillar 1 requirement is the minimum regulatory Capital Requirement to be held.
Capital Resources as at 30th November 2015
|Core Tier 1 Capital||
|Deductions from Tier 1 Capital||
|Total Tier 2 and Tier 3 Capital||
|Total Capital Resources, Net of Deductions||
|Pillar 1 Capital Requirement||
|Additional Requirement under Pillar 2||
|Total Pillar 1 and Pillar 2 Capital Requirement||
Frequency of review of disclosures
The disclosures within this document will be updated at least annually. They will be updated every year following the annual production of the GIM ICAAP and will also be updated in response to any significant occurrence which will adversely affect the Genesis Group’s capital and risk position.
As part of the annual review, the Pillar 3 Disclosure Document will be reviewed by the GIM Operating Board and approved by the GAM Operating Committee.
Pillar 3 Disclosure – Remuneration
Under the UK Financial Conduct Authority BIPRU Remuneration Code (“Code”), Genesis Investment Management, LLP (“GIM”) must disclose certain information regarding its remuneration policies and practices for individuals whose professional activities have a material impact on its risk profile (“Code Staff”).
The disclosure provided below for GIM is appropriate given the firm’s size, internal organisation and the nature, scope and complexity of its activities.
Remuneration arrangements at GIM aim to promote effective risk management and are consistent with Genesis’ risk profile, risk appetite and risk strategy. GIM adopts a prudent approach when determining the total amount of variable remuneration distributable. The disclosure includes profit for the financial year available for discretionary division among members.
GIM’s remuneration policy has evolved over the life of the Firm. The key requirements of the Code were already reflected in GIM’s remuneration arrangements before the Firm became subject to the Code, only enhancements to documentation related to remuneration have been undertaken in response to the Code.
The decision-making process
The following arrangements are in place:
- The Operating Board of GIM acts as a remuneration committee and confirms remuneration recommendations in respect of GIM Staff Members.
- The Governing Board of GAM fulfils the function of a remuneration committee with regard to oversight of the income of Partners and members of the Pre-Partnership Scheme.
- The GAM Audit Committee acts as the remuneration committee for the GAM Non-Executive Directors, who are only relevant to GIM through their role in managing the Genesis Group.
The link between pay and performance
Remuneration arrangements for the four categories of individuals identified as meeting the FCA’s criteria for Code Staff are described below.
Individual partners have each contributed capital to Genesis and entered into a commitment to remain in Genesis for a minimum fixed period. Genesis’ compensation culture is focused upon performance rather than entitlement, and long-term business viability rather than short-term personal gain. All Partners are assessed on a four-year rolling basis and rewarded on their contribution and long-term impact on the business. Partners’ remuneration from GIM is comprised of share of net profits on a discretionary basis, determined by the overall profitability of the Firm in a given year, together with recognition of individual contribution. Although GIM, as a BIPRU firm, is not required to operate a deferral scheme, 25% of all Partner remuneration from GIM is deferred for three years. Genesis Partners can choose to receive their remuneration in cash or units in Genesis-managed funds with at least 50% of the deferred amount in Genesis-managed funds.
Members of the Pre-Partnership Scheme ("PPS")
Staff who are members of the PPS receive a fixed salary and an annual discretionary payment under the PPS long term incentive scheme determined using similar criteria to that for Investment Partners.
Investment Team Staff Members
Investment Team Staff members receive a salary (capped at the level of Partners’ drawings) and a discretionary bonus based on their investment performance. Guarantees for bonuses may only be offered in the initial year of joining.
Non-Executive Directors on the GAM Operating Committee ("NEDs")
Remuneration arrangements are recorded in relevant letters of engagement. NEDs receive a fixed fee.
Aggregate quantitative information on remuneration
The aggregate remuneration of Code Staff from GIM in 2014 was £65,082,000.
All Code Staff were senior managers, risk takers or non-executive directors.
GIM has only one business line: the provision of investment management and advisory services to institutional clients investing in equity securities in emerging markets.
23rd December 2015