This disclosure is intended to provide information on the remuneration policies and practices of Silicon Valley Bank (“SVB”) in relation to the UK branch.
In the UK, SVB is required to comply with certain remuneration requirements (the “Codes”) within the Prudential Regulation Authority’s (“PRA”) Rulebook and the Financial Conduct Authority’s (“FCA”) Handbook of Rules and Guidance and in doing so has regard to the European Banking Authority’s guidelines on sound remuneration policies. These requirements and guidelines form part of the implementation in the UK of the EU Capital Requirements Directive along with a limited number of discretionary policies and derogations available to EU member states.
The Codes recognise that not all remuneration principles apply to firms equally and introduce a concept of proportionality, which enables a firm to apply the requirements to the extent that it is appropriate to the its size, internal organisation (including legal structure) and the nature, scope and complexity of its activities. The PRA and the FCA have defined a high level proportionality framework split into three tiers based on a firm’s relevant total assets. SVB applies the proportionality principle in accordance with the general expectations and guidance of the PRA and the FCA for firms of its proportionality level.
SVB endeavours to structure the remuneration of its staff in a way that rewards them fairly and appropriately for their contribution towards the success of the business and the level of service and performance delivered to our clients. The remuneration policy is designed to be consistent with and promote sound and effective risk management and not to encourage risk-taking that exceeds SVB’s risk tolerance. It is designed in line with our business strategy, objectives, values and long-term interests. The policy and procedures incorporate measures to avoid conflicts of interest and are subject to independent internal review by Compliance and Senior Management. The remuneration policy is designed to achieve an appropriate balance of fixed and variable components of total remuneration to enable a fully flexible policy on variable remuneration, including the possibility to pay no variable remuneration. In order to achieve this, the remuneration of staff is, at least annually, reviewed for compliance with our remuneration policies and procedures, taking into account individual performance and market practice for the individual role being undertaken. Senior Management finalise and authorise the annual salary awards for all staff, and specifically the remuneration of senior officers in the risk management and compliance functions.