Modern Slavery Act Transparency Statement
Lone Star Europe Acquisitions Limited (“LSEA”) is committed to carrying out its business ethically and prudently, ensuring that the crimes of slavery and human trafficking do not take place in any part of its business or supply chain.
A copy of LSEA’s anti-slavery and human trafficking statement for the financial year ending December 31, 2022 can be obtained by writing to the UK Compliance Department at Lone Star Europe Acquisitions Limited, 12 Queen Anne Street, London W1G 9LF, United Kingdom. Requests will be responded to within 30 days.
Remuneration Disclosure Statement
Lone Star Europe Acquisitions Limited (“LSEA”) is authorized and regulated by the Financial Conduct Authority (“FCA”) as an Exempt CAD firm to conduct the regulated activities of advising and arranging (with a restriction to corporate finance business only). As a small and non-interconnected (“SNI”) MIFIDPRU (as defined below) investment firm, LSEA makes certain qualitative and quantitative disclosures in accordance with the Disclosure chapter of the FCA’s Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”).
Pursuant to these rules, this document summarizes the:
- The Firm’s approach to remuneration;
- objectives of the Firm’s financial incentives;
- The Firm’s remuneration decision-making procedures and governance;
- key characteristics of the Firm’s remuneration policies and practices; and
- total amount of remuneration awarded to all staff split into fixed and variable remuneration.
In developing the qualitative disclosures in points (i) to (iv) above, the Firm has considered its size and internal organization, and the nature, scope and complexity of its activities.
Approach and Objectives
LSEA’s business model and strategy is to provide advisory services to its parent entity Lone Star Global Acquisitions, Ltd. (“LSGA” and, together with its subsidiaries as applicable, “Lone Star”, which is itself an SEC regulated entity). LSGA provides investment advisory and related services to families of closed end private funds (the “Funds”) and certain investment vehicles related to the Lone Star Funds (which LSGA refers to as its “Clients”).
The Firm’s approach to remuneration is designed so that fixed and variable compensation is consistent with and promotes effective risk management, and does not encourage risk-taking that is inconsistent with the risk profile of the Firm or the risk profile of the Clients.
The Firm believes that it is in the best interest of the Funds, the organization and its employees to fairly compensate its workforce for the value of the work provided. Compensation is designed to be consistent with the competitive market range of the position based on the skills, knowledge, and behaviors required. The compensation program must be flexible enough to recruit and retain a highly qualified workforce.
Governance and Decision Making
The Firm’s Board meets periodically and is responsible for reviewing and approving key risk related materials related to the Firm and has input to or reviews Firm policies before referral to Lone Star’s global policy review committee for approval. LSEA senior management is responsible for administering and making recommendations with respect to LSEA employees’ compensation, and for confirming that all recommendations are in line with Lone Star’s remuneration policy.
Key Characteristics of Remuneration Policy and Practices
The remuneration policy and practices are designed so that fixed and variable compensation is consistent with and promotes effective risk management, and does not encourage risk taking that is inconsistent with the risk profile of the Firm or the Clients. The fixed component must represent a sufficiently high proportion of total remuneration to enable the operation of a fully flexible policy on variable remuneration, including the possibility of paying no variable remuneration component.
Fixed remuneration is comprised of salary and benefits (including pension contributions, medical cover and life assurance) and is based on an individual’s role and professional experience and organizational responsibility. Fixed remuneration is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration includes performance bonuses, which are generally based on a pre-determined target as a percentage of base salary. An additional performance bonus may be awarded for exceptional performance. Performance bonuses are designed to reflect the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment. Other variable remuneration includes sign-on bonuses, retention bonuses and severance pay.
Financial and non-financial factors are considered in determining remuneration and include, without limitation, supporting the business strategy, objectives and interests of the Clients, measurement of performance related indicators with respect to the overall performance of Clients, assessments of compliance with governance and control functions and avoidance of conflicts of interests.
Total Remuneration Split Between Fixed and Variable
The table below sets out the total amount of remuneration awarded by LSEA to all staff split into fixed and variable remuneration.
|For the year ended December 31, 2022
|Total Fixed Remuneration
|Total Variable Remuneration
1Separately from their LSEA remuneration as reflected in the chart, certain employees may participate in employee co-investment vehicles that invest in the Lone Star Funds’ investments and/or receive carried interest for Lone Star Fund investments.