Updated 01 December 2025
In accordance with the FCA’s UCITS Remuneration Code, Octopus Money Unit Trust Managers Limited (“OMUTM”)* is required to establish and apply a remuneration policy for staff whose activities have a material impact on the risk profile of OMUTM or the UK UCITS funds (“UCITS”) that it manages (UCITS Remuneration Code Staff or “Code Staff”).
OMUTM’s remuneration policy is to ensure that remuneration for its Code Staff:
• is consistent with and promote sound and effective risk management;
• does not encourage risk taking that exceeds the level of tolerated risk of OMUTM or that is inconsistent with the risk profiles of the funds it manages;
• encourages behaviours that are aligned with the business strategy, objectives, values and interests of the Manager, the Funds, and the investors in the Funds, and seeks to avoid conflicts of interest;
• does not impair OMUTM’s ability to comply with its duty to act in the best interest of its customers and the funds it manages;
• recognises that remuneration should be competitive and reflect both the financial performance of company and personal performance. Accordingly, remuneration for Code Staff is made up of fixed pay (salary and benefits, including pension) and variable (performance-related) pay**;
• recognises that fixed and variable components should be appropriately balanced and that the variable component should be flexible enough so that in some circumstances no variable component may be paid at all. Variable pay may also have an element paid in shares and be subject to deferral and clawback requirements and can be made up of both short term and long-term awards (reflecting performance over shorter and longer periods);
• ensures that the remuneration of the senior officers in the risk management and compliance functions is based on the achievement of objectives linked to their functions, independent of the performance of the business areas that are within their remit;
• ensures that payments for early termination reflect performance achieved over time and are designed not to reward failure;
• will not include guaranteed variable remuneration other than in exceptional circumstances and only then in the context of hiring new staff and limited to the first year of engagement;
• does not allow personal investment strategies to be used by individuals to undermine the risk alignment effects embedded in their remuneration arrangements;
• is not paid through vehicles or methods that facilitate avoidance of the UCITS remuneration code;
• is aligned with relevant regulatory obligations, remuneration principles and proportionality provisions of the FCA guidance; and
• is governed by a policy that is subject to annual independent review by the Compliance function and the OMUTM Board.
*Octopus Money Direct is a trading name of Octopus Money Unit Trust Managers Limited.
** Note that the external independent directors receive fixed fees and no variable remuneration