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MIFIDPRU Public Disclosure Document

For the period 1 April 2022 – 31 March 2023

Overview and summary

Broad Reach Investment Management, LLP (“Broad Reach”) is regulated by the Financial Conduct Authority (“FCA”) as a Collective Portfolio Management Investment Firm (“CPMI”) and therefore subject to both the Alternative Investment Fund Managers Directive (“AIFMD”) and the Markets in Financial Instruments Directive (“MiFID”). The Firm is also therefore subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook.

For the purposes of MIFIDPRU, the Firm has been classified as a small non-interconnected (“SNI”) firm.

The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.

This Public Disclosure Document has been prepared based on the audited financials, covering the financial period 1 April 2022 – 31 March 2023.

The Firm’s main business activity is asset management and the team operates a global macro investment programme focused on the extraordinarily diverse opportunity set in emerging markets. The Firm focuses on securities and related derivatives across the complete universe of FX, rates, credit, and equity as well as commodities.

Remuneration arrangements

The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).

In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:

Broad Reach does not benefit from exceptional government intervention.

Broad Reach’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categories as either fixed or variable remuneration.

Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.

Variable remuneration is based upon staff members performance or, in exceptional cases, other conditions.

Performance reflects the long-term performance of the staff member as well as performance in relation to the staff member’s job description and terms of employment, and

Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit.

The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.

The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.

Quantitative Remuneration

All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded.

As an SNI firm and in accordance with MIFIDPRU 8.6.8, Broad Reach is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.

For the performance year ending 31 December 2022:
Total fixed remuneration awarded £2,047,250
Total variable remuneration awarded £1,799,166
Total remuneration awarded £3,846,416


General enquiries

Investor enquiries

Broad Reach UK

50 Great Marlborough Street
+44 20 7531 2460

Broad Reach US

1185 Avenue of the Americas
New York
NY 10036