DISCLAIMER: This website is for informational purposes only and it should not be regarded as an offer or the solicitation of an offer to buy or sell the instruments mentioned in it. The financial instruments described herein may not be eligible for sale in all jurisdictions or to certain categories of counterparties. The risk of trading futures and options and other derivatives involves a substantial risk of loss and is not suitable for all persons. Each person must consider whether a particular trade, combination of trades or strategy is suitable for that person's financial means and objectives. Any content included herein may include discussions of seasonal patterns, however seasonal patterns are no indication of future market trends and past performance is not indicative of future results. LCMC does not make markets in any of the commodities mentioned in this report; likewise, neither LCMC, nor its officers, partners and employees have ownership in any of the commodities mentioned herein. No part of this website may be reproduced without full attribution and the approval of LCMC.
MIFIDPRU Disclosures — 2024
LCM Commodities, UK LLP ("LCMC UK") is Limited Liability Partnership (OC330545) whose principal activity is that of a matched principal commodities derivatives broker. LCMC UK is independent and provides a service to Professional Clients and Eligible Counterparties.
LCMC UK was founded as a private partnership in 2007 and is based in London. LCMC UK is owned by Edge Commodities Limited.
LCMC UK was authorised by the original Financial Services Authority (No. 587454), in June 2013, and currently holds the following permissions:
LCMC UK currently calculates its capital requirements applying the rules which apply to MIFIDPRU £75k SNI firm.
LCMC UK is a small non-interconnected (“SNI”) firm and therefore is required to apply general requirements within its remuneration policies and practices. SYSC 19G.2.4 explains that a firms’ policies and procedures must be appropriate and proportionate to the nature, scale and complexity of the risks associated with the firm’s business model and activities.
The LCMC UK remuneration policy is based on the following principles that guide the compensation programs and consequent actions:
LCMC UK’s main policy is to offer competitive remuneration packages to all its employees. Market research (benchmarking) is conducted to enable the practices to be parallel in quality and value with the general conditions present within the market. No individual will be dependent on variable remuneration to an extent that makes up their majority of their total remuneration.
The remuneration policy and related practices are determined with regards to common interests of partners, employees, and clients. LCMC UK’s remuneration policy consists of base salaries, as well as performance-based bonuses and benefits. This policy is designed to attract, retain, and motivate staff at all levels, and is consistent with the objectives outlined in the business strategy through:
Fixed remuneration is determined by experience and aptitude for the role and reflects the staff members professional experience and organisational responsibilities as set out in their contract of employment with LCMC UK. This will be permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration is determined by contribution and performance within the last calendar year. It reflects the long-term performance of the staff member as well as performance against the staff member’s terms of employment. LCMC UK's ratio between variable and fixed components of the total remuneration, has been established to ensure that the components are appropriately balanced and that the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the firm would do in certain situations, such as where the firm’s profitability performance is particularly constrained, or where there is a risk that the firm may not be able to meet its capital or liquidity regulatory requirements.
The below table summarises the financial and non-financial criteria of performance used across the firm in assessing the level of variable remuneration to be paid:
| FINANCIAL PERFORMANCE CRITERIA | NON-FINANCIAL PERFORMANCE CRITERIA | |
|---|---|---|
| FIRM | Firm-wide performance targets |
|
| BUSINESS UNIT |
New business growth Business maintained Performance targets |
Process efficiencies Introduction of new process/products |
| INDIVIDUAL | KPIS achieved |
Training completed No conduct breaches No discipline issues |
LCMC UK’s senior management fully acknowledges its responsibilities with respect to this remuneration policy, including its overriding responsibility to ensure that this policy complies with the requirements of the MIFIDPRU Remuneration Code. Senior Management along with Compliance will review this policy on an annual basis, this being sufficiently frequent given the risks faced by the firm.
LCMC UK considers the current arrangements to be proportionate, given:
This policy will be reviewed by the Compliance Officer and an external consultancy Compliance Officer on an annual basis to determine whether it has been implemented correctly and in line with the firm’s business strategy, reflects the risk profile, long-term objectives other relevant goals of the firm and compliance with all relevant legal requirements. Following this internal review, the results will be documented including findings and remediation actions.
As LCMC UK is classified as a SNI-firm then they are not required to determine their MRT’s. If LCMC UK’s position changes, then this will be reviewed.
The below table quantifies the remuneration paid to staff in the financial year 1 January 2024 to 31 December 2024. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the firm itself, partners or members, employees of other entities in the group, employees of joint service companies, and secondees:
| PERIOD: 2024 FINANCIAL YEAR | ||
|---|---|---|
| REMUNERATION AWARDED |
Fixed £ | 718,349 |
| Variable £ | 1,063,193 | |
| Total £ | 1,781,542 | |
We are committed to providing the highest level of service to our clients. We value feedback and take any expression of dissatisfaction seriously. Our Complaints Policy outlines how we handle and resolve any concerns you may raise.
If you are dissatisfied with any aspect of our service, you may
contact LCMC UK's Compliance Officer.
Compliance Officer: Rebecca Wong
Email:
rwong@lcmcommodities.com
Please provide the following information to help us investigate
your complaint efficiently: