Remuneration Disclosure

The Firm is subject to the FCA’s rules on remuneration (the Remuneration Code or the Code). The Remuneration Code is set out in section 19B of the FCA’s Senior Management Systems and Controls Sourcebook. The Remuneration Code is intended to ensure that firms establish, implement and maintain appropriate remuneration policies, procedures and practices that are consistent with, and promote, sound and effective risk management and do not encourage risk taking .

The Firm has a Remuneration Policy which appropriately addresses potential conflicts of interest and is designed to ensure that the Firm’s Approved Persons and other Code Staff, where applicable, are not rewarded for taking inappropriate levels of risk. Under the FCA’s Guidance regarding the proportionate application of the Code the Firm is permitted to disapply many of the technical requirements of the Code and proportionately apply the Code’s rules and principles in establishing the Firm’s policy. Proportionate to the small size of the Firm, the Firm has decided that the Board of Directors will undertake the role that would otherwise be undertaken by a remuneration committee. The Board of Directors will be responsible for setting the Firm’s policy on remuneration and will review that policy at least on an annual basis to ensure that it remains consistent with the Remuneration Code and the Firm’s objectives.

The Firm is satisfied that the policies in place are appropriate to its size, internal organisation and the nature, scope and complexity of its activities.