Remuneration Code

The aim of the Remuneration Code (the “Code”) is to ensure that firms have risk focused remuneration policies which promote and are consistent with effective risk management, and do not expose firms to excessive risk.

Under the Code, Oxford University Endowment Management Limited (the “Firm”) is classified as a Tier Four firm, the lowest risk category as it does not manage or trade proprietary positions. This means that the Firm can dis-apply many of the technical requirements of the Code and proportionately apply the Code’s rules and principles.

Under the FSA’s Prudential Sourcebook for Banks, Building Societies and Investment Firms (BIPRU), firms are required to disclosure their remuneration policy and practices, as well as aggregate quantitative disclosure for staff assessed as having a material impact on its risk profile, including senior management (“Code Staff”).

The disclosure obligations applicable to remuneration which is subject to the Code includes all forms of fixed remuneration and variable remuneration.

Remuneration Policies

The Firm has adopted policies in relation to the Firm’s remuneration arrangements which address potential conflicts of interest arising from such arrangements by taking into account the controls in place to guard against the Firm’s authorised persons being rewarded for taking inappropriate levels of risk.

The Firm is satisfied that the policies in place are appropriate to its size, internal organization and the nature, scope and complexity of its activities.

The Decision Making Process

The Firm’s Policy is determined by the Remuneration Committee of the Firm, consisting of the three non-executive directors of the Firm and Bernard Taylor and Sir John Vickers. The Remuneration Committee is chaired by Richard Oldfield.

Link between Pay and Performance

Remuneration subject to the Code is based on an assessment of the profitability of the Firm, an individual’s performance and their contribution to the business carried on by the Firm.

In addition to salary, staff are incentivised with the opportunity of receiving a discretionary bonus based on performance subject to the discretion of the Remuneration Committee.

Quantitative Remuneration Data

Disclosure of the aggregate remuneration for staff permits firms to take account of the provisions of the Data Protection Directive (Directive 95/46/EC) regarding the protection of individuals in relation to the processing of personal data. Due to the low number of staff assessed as Code Staff for the Firm, the Board has relied upon BIPRU 11.5.20R(2) and determined that aggregate quantitative disclosure for Code Staff is inappropriate.