Whistleblowing Complaint Form and Remuneration Code Principles | Mortgage Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

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Whistleblowing Complaint Form

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7.18 Remuneration    

Remuneration is defined as a benefit or reward of employment and includes payments such as salary, benefits (company car, health plan etc.), bonuses, commissions and overtime wages.

Such remunerations must be paid in a way that does not expose the firm to any additional risks or acts of bribery and the company has a strict Remuneration Policy & Procedures in place to ensure that we comply with all legal and regulatory requirements in this area.

Where any performance related salary or commission is applicable to a job role, the company has ensured that it meets the regulatory requirements and that risk assessments have been carried out to mitigate against any known or unknown risks and acts of unintentional bribery.

Any documents that related to performance related pay – such as appraisals or employee performance reviews, are retained for audit purposes and are recorded appropriate to comply with the regulating requirement.

[Mortgage/Home Finance Activities] We confirm that were the firm or any staff working on behalf of the firm are paid by commission, this is always disclosed in writing (and verbally where applicable) to consumers. Relevant written materials have a disclosure statement advising that they have the right to ask for information on the commissions paid by different lenders. They are also provided with ways to access relevant market data to allow them to respond to such a request.

We also ensure that in compliance with the Mortgage Credit Directive (MCD), the remuneration of our advisers is not contingent on any of their sales targets.

7.18.1 FCA Remuneration Code Principles  

  • Principle 1: Risk management and risk tolerance
  • Principle 2: Supporting business strategy, objectives, values and long-term interests of the firm
  • Principle 3: Avoiding conflicts of interest
  • Principle 4: Governance
  • Principle 5: Control functions
  • Principle 6: Remuneration and capital
  • Principle 7: Exceptional government intervention
  • Principle 8: Profit-based measurement and risk adjustment
  • Principle 9: Pension policy
  • Principle 10: Personal investment strategies
  • Principle 11: Non-compliance with the Remuneration Code
  • Principle 12: Remuneration structures – introduction
    • Principle 12(a): Remuneration structures – general requirement
    • Principle 12(b): Remuneration structures – assessment of performance
    • Principle 12(c): Remuneration structures – guaranteed variable remuneration
    • Principle 12(d): Remuneration structures – ratios between fixed and variable components of total remuneration
    • Principle 12(e): Remuneration structures – payments related to early termination
    • Principle 12(f): Remuneration structures – retained shares or other instruments
    • Principle 12(g): Remuneration structures – deferral
    • Principle 12(h): Remuneration structures – performance adjustment, etc.
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