Regulatory Disclosures
Introduction
Sentinel Regulatory Services Ltd (“The Firm” or “Sentinel”) is authorised and regulated by the Financial Conduct Authority. Sentinel operates as a regulatory hosting provider for appointed representatives (“AR”). The Firm does not have retail permissions and its ARs are only permitted to conduct the following activities with professional clients and eligible counterparties:
- advising on investments
- arranging (bringing about) deals in investments
- making arrangements with a view to transactions in investments; and/or
- agreeing to carry on a regulated activity
This disclosure relates to the Firm’s financial year ending 31 March 2025.
Regulatory context
As a UK investment firm within the scope of the UK Markets in Financial Instruments Directive (“MIFID”), Sentinel is subject to the prudential requirements of the Investment Firms Prudential Regime (“IFPR”). These requirements are contained in the MIFIDPRU Prudential sourcebook of the FCA Handbook.
Under MIFIDPRU, Sentinel is categorised as a small and non-interconnected investment firm (“SNI”). As such, and in accordance with MIFIDPRU 8, Sentinel is required to publish information regarding its remuneration policy and practices.
Sentinel is also subject to the basic requirements of the MIFIDPRU Remuneration Code as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook.
Remuneration policy and practices
For the financial year ending 31 March 2025, it is important to note that Sentinel had only been authorised by the Financial Conduct Authority (“FCA”) for approximately 7 months. In any case, Sentinel’s approach to remuneration of its staff is based upon fixed and variable remuneration underpinned by policy and practices that:
- Promote effective risk management and do not encourage excessive risk taking. For example, by not incentivising staff to onboard an AR outside Sentinel’s risk appetite
- Supports positive behaviours and a healthy firm culture
- Discourages financial and non-financial misconduct
- Contains measures to avoid conflicts of interest
- Are gender neutral and proportionate to the Firm’s nature, scale and complexity
Fixed Remuneration
Fixed remuneration is non-discretionary pay that is permanent, predetermined and not dependent on performance. The Firm agrees fixed remuneration with staff on the commencement of contractual employment. Fixed remuneration may increase based on:
- Market value
- Professional experience; and/or
- Change in responsibilities
Variable remuneration
Variable pay is discretionary, usually in the form of an annual bonus, based on performance of staff that reflects positive behaviours. Variable pay does not constitute a significant portion of total remuneration for any staff member, nor is it guaranteed.
Sentinel links variable remuneration and performance in the following ways:
- Considers the financial performance of the Firm and any impact on client interests
- Considers the financial and non-financial performance of the individual in contributing to the Firm’s success including adherence to compliance obligations
- As a means of attracting and retaining staff
- Discourages excessive risk taking
Governance
The Firm has considered that a Remuneration Committee is not currently proportionate to the nature, size and complexity of the business. Instead, the Board is responsible for setting and overseeing the implementation of Sentinel’s remuneration policy and practice. The Firm’s policy and practices are reviewed, at least, annually by the Board.
Quantitative Remuneration Disclosure
For the Firm’s financial year ending 31 March 2025, the Firm’s headcount was 3 staff members. The total amount of fixed remuneration paid to all staff members was £16,757 and the total variable remuneration awarded to all staff members was £0.