Remuneration Policy

Introduction

MilltechFX Europe SAS (“MTE”) is authorised by the Autorité de Controle Prudentiel et de Résolution (the”ACPR”), and regulated by the ACPR and the Autorité des Marchés Financiers (the”AMF”), number 16 783 (CIB) to provide the investment services of the reception and transmission of orders and execution of orders on behalf of professional clients, as well as dealing on own account.

In accordance with the regulation resulting from Directive 2014/65/(EU) on markets in financial instruments of 15 May 2014, (“MIFID II”), MillTechFX Europe established this remuneration policy.

It is a key corporate strategy of the Company to attract, retain, motivate and reward talented individuals committed to serving the long-term interests of the Company. We remain committed to promoting a gender-neutral approach to all roles across the Company. We understand that our most valuable asset is our employees and through a fair and objective recruitment process, we can attract a diverse range of talent to the Company and retain professional and experienced staff.

The purpose of this document is to summarise the remuneration practices of the Company.

Applicability

The Remuneration Policy of the Company applies to all employees.

Remuneration Structure

The remuneration package consists of the following components:

  • Fixed salary: targeted to be in line with industry benchmarks.
  • Variable component: designed to reward performance whilst encouraging behaviors in line with MTE’s strategy, objectives, corporate culture and values, and long-term business interests.

MTE operates a fully flexible variable remuneration policy and in doing so ensures fixed remuneration is set at an appropriate level such that it is possible to reduce variable remuneration to zero if deemed appropriate.

Remuneration Principles

The key principles of governing a sound and effective remuneration framework can be summarized as follows:

  • the Remuneration Policy is consistent and aligned with the Company’s risk management policy and strategy

  • conflicts of interest with regards to the remuneration policy and the award of remuneration are identified and appropriately mitigated.

  • the total remuneration (including the fixed and variable components) payable by the Company to its employees:

    • is in line with the business strategy, objectives and long-term interests of the Company
    • does not encourage risk-taking that exceeds the risk appetite of the Company
    • is based on objective quantitative and qualitative criteria and parameters, that take into account the current and future risks that the Company may incur
    • allows for the maintenance by the Company of an adequate capital base.

  • The remuneration of employees engaged in control functions is determined independently of the performance of the business areas for which they are responsible.

  • Specific functions may be subject to deferred compensation arrangements with regards to variable compensation.

  • The Policy should be consistent with the rules, laws and regulations related to the protection of clients and provision of investment services.

Governance

MTE recognises that an effective governance framework for remuneration is an essential prerequisite in aligning its Remuneration Policy with regulatory requirements and the overall business strategy and long-term interests of the Company.

The implementation and oversight of the Company’s remuneration practices is performed through the Company’s supervisory function (Conseil de Surveillance).

The Company’s supervisory board (Conseil de Surveillance) is responsible for approving, adopting, and maintaining the Company’s Remuneration Policy and overseeing that it is operating as intended.

The Internal Control Functions are responsible for ensuring that the Remuneration Policy and process are established, implemented, and maintained in accordance with the relevant remuneration principles applicable to MTE.

Communication of the Remuneration Policy

Within the company, the full Remuneration Policy is provided to all employees.