Remuneration Policy

July 2023


This document relates to Thesis Unit Trust Management Limited and TUTMAN LLP. Both companies are authorised and regulated by the Financial Conduct Authority (“FCA”) and has the permission necessary to act as an Authorised Fund Manager of collective investment schemes.

The companies are subject to the FCA rules on remuneration as set out within the FCA’s Senior Management Arrangements, Systems and Controls section of the handbook (SYSC 19B/E).

Decision Making Process

Both Thesis Unit Trust Management and TUTMAN LLP (the “Authorised Fund Managers”) are part of a larger group within which remuneration policies are the responsibility of a Remuneration Committee comprised entirely of non-executive directors. It meets twice a year or more frequently as events dictate.

That committee has designed the remuneration policy so that it meets the remuneration principles set out in SYSC 19B and SYSC 19E. The remuneration policy sets out a framework for determining the level of fixed and variable remuneration of staff, including maintaining an appropriate balance between the two.

Remuneration Policy

The remuneration policy is designed to ensure the business complies with the regulatory principles on sound remuneration, such that it:

  • Promotes sound and effective risk management;
  • Does not encourage behaviours that are inconsistent with the risk profiles of the funds the business operates; and
  • Aligns the interests of staff with those of its clients;

Staff bonus schemes are operated so as to generate rewards which reflect both the performance of the individual and the performance of the business and allow for higher rewards to be paid to staff whose performance merits such recognition. The performance of individuals is assessed primarily by reference to non-financial criteria, such as completion of training requirement, conduct and client service.

The Remuneration committee approves bonus awards each year at the same time as the annual pay review and takes into account the projected performance of the business when approving such awards.

Design Considerations

Employees within control functions are compensated according to the objectives linked to their functions independent of the performance of the business areas that are within their remit. Senior officers in the risk management and compliance functions have their remuneration overseen by the remuneration committee.

Arrangements for variable remuneration within the group are calculated primarily by reference to the performance of each individual and the profitability of the relevant business unit. The performance of individuals working on the business of the Authorised Fund Manager is assessed primarily by reference to non-financial criteria, especially the effectiveness of their oversight monitoring of delegates appointed to perform investment advisory or fund administration services for the Company.

Material Risk Takers

The remuneration committee has identified the staff members whose professional activities are considered to have a material impact on the firm’s risk profile and who are classified as Material Risk Takers (“MRTs”) under the regulatory codes. This classification is reviewed annually and the individuals are notified of their classification.

The regulations specify additional factors to be taken into account when awarding and vesting variable remuneration for MRTs.

Clawback and Malus

Clawback of bonus payments is applied to all bonus schemes and all staff for a period of up to three years after the payment of a bonus. It is designed to be used should evidence emerge of sufficiently serious misbehaviour. Malus is the term used when the bonus is deferred and so applies primarily to MRTs. It allows a bonus award to be cancelled or amended prior to being paid.


All staff at the management company and within the wider group are part of a defined contribution scheme

Anti Avoidance

No employees use personal hedging strategies, remuneration-related insurance or limited liability insurance to undermine the risk alignment effects embedded in the remuneration arrangements