MIFIDPRU Disclosure
MIFIDPRU Disclosure
Introduction
Oxford Investment Opportunity Network Limited (OION), trading as Oxford innovation Finance and incorporated as a Private Limited Company in England and Wales (Companies House number: 02177191), is authorised and regulated (FRN: 564525) by the Financial Conduct Authority (FCA) in the United Kingdom to arrange investments for businesses seeking finance. OION’s registered office and place of business is Oxford Centre for Innovation, Blue Boar Court, 9 Alfred Street, Oxford, OX1 4EH. OION is registered with the Information Commissioner’s Office under number ZA035468.
Regulatory Context
In accordance with MIFIDPRU 8 the regulatory aim of the disclosures is to enable stakeholders and market participants an insight into how OION is run. They also aim to help stakeholders make more informed decisions about their relationship with OION.
Frequency
OION will be making these MIFIDPRU disclosures at least annually. The disclosures will be as at the Accounting Reference Date (“ARD”) and published on the date OION publishes its annual financial statements.
In particular circumstances (e.g. major change to OION’s business model or merger), we will make more frequent public disclosures.
Proportionality
The level of detail provided in the qualitative disclosures is proportionate to OION’s size and internal organisation and the nature, scope and complexity of OION’s business activities.
Media and Location
The disclosure will be published on OION’s website and free to obtain.
Changes to Information disclosed
OION confirms that there are no significant changes to the information disclosed, when compared with the previous disclosure periods.
Verification
The information in this document has not been audited by OION’s external auditors, as this is not a requirement, does not constitute any form of financial statement and must not be relied upon in making any judgement on OION.
Background to OION
Background
OION is incorporated in the UK and is authorised and regulated by the FCA as an SNI MIFIDPRU investment manager and advisory firm and is therefore subject to the FCA’s Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”). OION meets all the criteria for small and non-interconnected (“SNI”) investment firms, detailed in MIFIDPRU 1.2, and is categorised as an ‘SNI investment firm’.
As an ‘SNI investment firm’ authorised and regulated by the FCA, OION is required under Chapter 8 of MIFIDPRU to publish key information to assist users of its accounts and encourage market discipline.
OION’s regulated activities are focused on arranging investments and facilitating connections between businesses seeking capital and potential investors. The principal protections available to OION’s customers arise from the firm’s regulatory obligations as an FCA-authorised firm, including its conduct, governance and systems and controls requirements. OION considers business and operational risks to be its primary material risks. These risks are assessed through the firm’s Internal Capital and Risk Assessment (ICARA) process and are managed through an established framework of governance, policies, procedures and controls designed to support the firm’s ongoing financial and operational resilience.
These disclosures are made by OION on a solo basis as required by MIFIDPRU 8.1.7R.
In accordance with MIFIDPRU 8.1, as an ‘SNI investment firm’, the information which OION is required to publish is limited to information relating to its remuneration policies and practices (per MIFIDPRU 8.6). Given OION is an SNI firm, it can apply proportionality to its remuneration arrangements.
MIFIDPRU 8.6 – Remuneration
Qualitative Disclosure Text
The purpose of OION’s remuneration policy is to set out how our firm will provide remuneration in form and amounts that are consistent with the FCA’s Remuneration Code (SYSC 19G), with the main objective of the financial incentives being to attract, motivate and maintain high-calibre employees.
The remuneration strategy has been designed to ensure consistency with the risk profiles and rules to ensure no conflict of interest between OION’s staff and its clients and compliance with the conduct of business rules.
The decisions of the governing body/ Remuneration Committee on setting remuneration are based on risk management, supporting business strategy, objectives, values and interests and avoiding conflicts of interest, and measurement of performance. The leading rationale of the decision-making is to achieve the main objective of OION, and its clients, while remaining consistent with the risk profile of OION’s business strategy.
OION’s governing body considers remuneration in the context of a broader agenda, including retention, recruitment, motivation and talent development and the external market environment. It also receives updates on regulatory developments, general remuneration issues, and market and benchmarking data.
The various components of total remuneration, which comprise base salary and variable bonus, are considered and balanced appropriately regarding the overall firm performance.
Firm performance and the individual’s input are significant contributors to determining variable bonus awards. The principal objective in determining variable bonus awards is to reward individual contributions to OION whilst ensuring that such payments are warranted given business results. In this context, performance can include non-financial as well as financial measures, examples of which include:
- measures relating to building and maintaining positive customer relationships and outcomes, such as positive customer feedback
- performance in line with firm strategy or values, for example, by displaying leadership, teamwork or creativity
- adherence to the firm’s risk management and compliance policies
- achieving targets relating to environmental, social and governance factors and diversity and inclusion
There is a focus on differentiation so that any rewards are determined according to the contribution of individuals. All staff may be subject to variable remuneration. However, bonus pools and individual awards are subject to the discretion of the Board, and it is possible that in any year, no variable bonus will be awarded, either at all or to particular individuals.