Wellington Management International Limited ("WMIL") makes the disclosures required by FSA BIPRU 11.5 in WMIL's Annual Accounts. The 2011 Accounts are not yet available so additional disclosure on remuneration matters are currently being made in this public website.
Remuneration Philosophy
Wellington Management International Limited ("WMIL") believes that its employees should be remunerated in a manner that rewards achievement. It is equally important that remuneration is consistent with, and promotes, sound and effective risk management. WMIL has adopted remuneration practices that are consistent with the firm's low risk appetite and its agency and fiduciary status. The practices also reflect the private partnership structure of Wellington Management (WMIL's parent) and WMIL's business activities which focus on providing investment management services for a fee to institutional clients.
Link between Pay and Performance
The discretionary remuneration of employees reflects the performance of the individual and the performance of the Wellington Management group. In a situation where Wellington Management is not profitable then this will be reflected in the discretionary remuneration of employees.
Remuneration Oversight
WMIL's remuneration arrangements encompass fixed and discretionary elements including discretionary bonuses and incentive payments calculated in accordance with agreed arrangements. All remuneration structures and remuneration awards are reviewed by senior management, including senior employees who are independent of the functions that decide the payments or whose employees benefit from the awards / structures. WMIL has its own Compensation Committee that is involved in these processes.
Proportionality
In line with the FSA General Guidance on Proportionality, WMIL is regarded as a Tier 4 firm for the purposes of remuneration disclosure. As permitted for firms in Tier 4, a number of provisions of the Code have been disapplied these include the requirement to restrict the ratio of discretionary payments to base salary/bonuses, to defer remuneration and/or bonuses over a period of time or to pay a portion of remuneration and bonuses in shares.
Aggregate remuneration of Code Staff
In the year to 31 December 2011 all Code Staff were senior management involved in fund management activities. The aggregate remuneration of Code Staff during the financial year to 31 December 2011 will be disclosed in the Annual Accounts.
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