Haverstock Capital LLP
For the financial year ended 31st March 2026
Date of publication: 9 September 2026
1. Introduction
The Financial Conduct Authority (“FCA” or the
“regulator”), in its Prudential sourcebook for MiFID Investment
Firms (“MIFIDPRU”), sets out the prudential requirements that
apply to Haverstock Capital LLP (“Haverstock” or the
“Firm”) Chapter 8 of MIFIDPRU (“MIFIDPRU
8”) sets out the public disclosure obligations with which the Firm must
comply.
The Firm is authorised and regulated by the FCA (Firm Reference Number 1039711). The Firm
is an independent investment management boutique that provides discretionary investment
management services, specialising in European mid-cap equities, to professional clients
and institutional investors.
The Firm is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment
firm (“SNI MIFIDPRU investment firm”).
As an SNI MIFIDPRU investment firm (that has no additional tier 1 instruments in issue), the
Firm is required to disclose information relating only to its remuneration policy and
practices. Accordingly, the Firm is not required to make disclosures in respect of risk
management objectives and policies, governance arrangements, own funds, own funds
requirements, or investment policy.
This disclosure has been prepared by Haverstock in accordance with the requirements of
MIFIDIPRU 8 and is verified by the Executive Committee of the Firm. Unless stated otherwise,
all figures relate to the financial year ended 31st March 2026.
2. Remuneration Policy and Practices
2.1 Purpose and Regulatory Framework
As an SNI MIFIDPRU investment firm, the Firm is subject to the basic requirements of the
MIFIDPRU Remuneration Code, set out in Chapter 19G of the FCA’s Senior Management
Arrangements, Systems and Controls sourcebook (“SYSC 19G”). The
purpose of the remuneration requirements is to promote effective risk management in the
long-term interests of the Firm and its clients, to align risk and reward, to support
positive behaviours and a healthy culture, and to discourage conduct that could lead to poor
client outcomes. The Firm is also classified as a collective portfolio management investment
firm (“CPMI firm”), and as such, is also subject to the AIFM
Remuneration Code, SYSC 19B.
2.2 Objectives of the Firm’s Remuneration Policy
The objective of the Firm’s remuneration policy and practices is to establish,
implement and maintain a culture that is consistent with, and promotes, sound and effective
risk management, and that does not encourage risk-taking inconsistent with the risk profile
of the Firm or the interests of its clients. The Firm’s remuneration policies and
practices are gender neutral and do not discriminate on the basis of the protected
characteristics of an individual in accordance with the Equality Act 2010. It is the
Firm’s policy to treat all job applicants and staff fairly and equally, regardless of
sex, pregnancy, trans-gender status, sexual orientation, religion or belief, marital status,
civil partnership status, age or perceived age, race, colour, nationality, national or
ethnic origins or disability. These characteristics form no part of any salary
considerations – as at the point of job offer – or performance reviews
thereafter.
2.3 Governance and Oversight
Given the size, nature, and complexity of the Firm, it does not have a separate
Remuneration Committee. Oversight of remuneration is undertaken by the Firm’s
Executive Committee, which is responsible for setting, reviewing, and approving the
Firm’s remuneration policy and for determining the remuneration of the Firm’s
members and employees. The Firm applies the remuneration requirements in a manner
proportionate to its size and internal organisation and to the nature, scope, and complexity
of its activities. To fulfil its responsibilities, the Executive Committee:
- Is appropriately staffed to enable it to exercise competent and independent judgement on
remuneration policies and practices and the incentives created for managing risk, capital,
and liquidity.
- Ensures that the Firm’s remuneration policy and practices consider the long-term
interests of shareholders, investors, and other stakeholders in the Firm.
- Ensures that the overall remuneration policy is consistent with the business strategy,
objectives, values, and interests of the Firm and of its clients.
2.4 Components of Remuneration
The Firm’s remuneration is made up of fixed and variable components and covers both
the members of the LLP and its employees.
As a limited liability partnership, the Firm’s members are remunerated through their
share of the Firm’s profits. In accordance with SYSC 19G, members’ drawings and
profit allocations are treated as remuneration for the purposes of this disclosure. During
the financial year the members received fixed drawings, which are treated as fixed
remuneration; no variable, profit-related allocation was made in respect of the year.
In addition, Haverstock recognises that remuneration is a key component in how the Firm
attracts, motivates, and retains high-quality staff. For employees, fixed remuneration
reflects the individual’s role, responsibilities, experience, and seniority, and is set
at a level sufficient to reflect the professional services they provide. Variable
remuneration, where awarded, is discretionary and reflects a combination of Firm and
individual performance.
2.5 Determining Fixed and Variable Remuneration
Fixed remuneration is predetermined, non-discretionary, and not linked to performance.
Variable remuneration, where awarded, considers the overall performance of the Firm, the
relevant business area, and the individual, assessed against both financial and
non-financial criteria — including compliance with the Firm’s policies, its risk
management framework, and applicable regulatory requirements.
The Firm operates a fully flexible policy on variable remuneration, which includes the
possibility of paying no variable remuneration in any given year. The Firm would expect to
exercise this discretion where, for example, its profitability is constrained or where
paying variable remuneration would put at risk its ability to meet its regulatory capital or
liquidity requirements. No variable remuneration was awarded in respect of the financial
year ended 31st March 2026.
3. Quantitative Remuneration Disclosure
As an SNI MIFIDPRU investment firm, the Firm is required to disclose the total amount of
remuneration awarded to all staff in respect of the financial year, split between fixed and
variable components. For this purpose, “staff” includes the members of the LLP
as well as its employees.
For the financial year ended 31 March 2026, the total amount of remuneration awarded was as
follows:
| Remuneration component | Amount (£) |
|---|
| Total fixed remuneration | 109,087 |
| Total variable remuneration | Nil |
| Total remuneration awarded to all staff | 109,087 |
Figures are aggregated only — an SNI firm does not break remuneration down by
individual or staff category, so no anonymity exemption is engaged. Fixed remuneration
comprises members’ drawings (£75,000) plus employee wages (£34,087).
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