MIFIDPRU 8 / Public Disclosures

Fortress Investment Group (UK) Ltd
June 2024

  1. Introduction
    1. Fortress Investment Group (UK) Ltd (“FIG UK” or the “Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”) of the United Kingdom and is a “MIFIDPRU investment firm” as defined in the FCA Rules. The Firm is a small and non-interconnected (“SNI”) firm for the purposes of the rules in the Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”).
    2. The Firm’s governing body is its Board (the “Management Body”).
    3. Under the FCA Rules (specifically Chapter 8 of MIFIDPRU), the Firm is required to make specific disclosures relating to its Remuneration Policy and Practices.
    4. The disclosures in this document relate to the Firm’s most recently ended financial year which ended on 31 December 2023.
  2. Significant changes since last disclosure period
    1. There have been no significant changes to the information disclosed since the Firm’s last disclosure period.
  3. Remuneration policy and practices
    Qualitative disclosures
    1. The Firm’s approach to remuneration for staff is outlined in FIG UK’s Remuneration Policy and can be summarised as follows:
      • Philosophy: The Firm’s remuneration policies and practices (collectively, “Remuneration Practices”) are driven by its desire to reward its staff fairly and competitively, whilst simultaneously remaining consistent with, and promoting a culture of principled behaviour and actions (particularly with regards to the areas of risk, compliance, control, conduct and ethics).

        As such, the Firm’s Remuneration Practices have been designed to contribute to the achievement of the Firm’s business strategy, objectives, and long-term interests in a manner which does not encourage excessive risk-taking or the violation of applicable laws, guidelines, and regulations. The award of variable remuneration takes the capital position and economic performance of the Firm over the long term into account.

      • Linkage between variable remuneration and performance: As a general principle, the total amount of an individual’s variable remuneration1 will be determined taking into account the following three criteria:
        • The performance / conduct of the individual throughout the relevant year (including in respect of non-financial performance, especially attitude towards sound risk management, responsible business conduct, fair treatment of clients, and avoiding conflicts of interest);
        • The performance of the relevant business group or department supported by the individual (where applicable); and
        • The performance of the Firm, and other entities in the same group, as a whole (including FIG LLC and its affiliates, to whom the Firm provides investment advisory services).

          When assessing individual performance, financial as well as non-financial criteria are taken into account.

      • Main performance objectives: The Firm’s main performance objectives relating to the variable remuneration of staff is as follows:

        Financial performance objectives:

        • Overall performance of the firm and more specifically, the business line.

        Non-financial performance objectives:

        • Attitude towards sound risk management;
        • Responsible business conduct;
        • Fair treatment of clients; and
        • Avoiding conflicts of interest.
        • Categories of staff eligible to receive variable remuneration: The eligibility of staff to receive variable remuneration is outlined in each individual’s contract of employment.
    2. As indicated above, the Firm’s objective in using financial incentives with its staff is to contribute to its strategic objectives, but in a sufficiently prudent manner that does not encourage excessive risk-taking or the violation of applicable laws, guidelines, and regulations, and which takes into account the capital position and long-term economic performance of the Firm.
    3. The below is a summary of the decision-making procedures and governance surrounding the development of the Firm’s remuneration policies and practices (which the Firm is required to adopt under SYSC 19G (the “MIFIDPRU Remuneration Code”).
      • The Management Body has adopted remuneration policies and practices in line with the rules and guidance laid down by the FCA and the MIFIDRU Remuneration Code, and is responsible for the implementation of such policies and practices.
      • The Management Body periodically reviews the Firm’s policies (at least annually) in accordance with the guidance and rules in SYSC 19G.3.
      • The Management Body ensures that the Firm, at least annually, conducts a central and independent internal review of whether the implementation of its remuneration policies and practices complies with the remuneration policy and practices adopted by the Management Body.
      • Due to the application of MIFIDPRU 7.1.4R, as FIG UK is not a “large SNI-firm” the Firm is not required, and so has not established, a remuneration committee.
      • The Firm engaged Simmons & Simmons LLP in the development of its remuneration policies and practices.

Key Characteristics of the Firm’s Remuneration Policies and Practices

Different components of remuneration (fixed and variable) awarded by the Firm
Component of remuneration Salary Fixed
Pension contributions Fixed
Benefits

(A) private medical, dental and optical insurance cover;
(B) travel insurance cover;
(C) critical illness cover;
(D) income protection cover; and
(E) life insurance.

 Fixed
Discretionary cash bonus Variable
Profit share Variable
Carried interest Variable
Summary of the financial and non-financial performance criteria used across the Firm which impact variable remuneration awarded to staff
Performance Criteria Performance criteria used in relation to the Firm

Financial performance criteria:
- Total revenue generation
- Expense management

Non-financial performance criteria:
- Achievement of strategic goals
Performance criteria used in relation to the Firm’s business units

Financial performance criteria:
- Attributable revenue generation
- Expense management

Non-financial performance criteria:
- Risk mitigation
- Achievement of strategic goals
Performance criteria used in relation to the Individuals

Financial performance criteria:
- Attributable revenue generation
- Business development criteria

Non-financial performance criteria:
- Performance
- Seniority
- Behavioural competencies
- Fitness & Propriety
- Client/counterparty feedback
- Compliance with applicable Firm policies, including Compliance, HR, Risk Management, and ESG / DEI matters (non-exhaustive)
- Talent market for specific role

Quantitative disclosures

Disclosures required under MIFIDPRU 8.6.8R (2)
Remuneration awarded to all staff
Total amount of remuneration awarded to all staff (“Total Rem”):


£32,438,484		 Amount of Total Rem awarded as fixed remuneration

£10,533,377
Amount of Total Rem awarded as variable remuneration

£21,905,107

1The term ‘variable remuneration’ includes (i) a discretionary cash bonus, (ii) profit share, and / or (iii) carried interest.