Regulatory Disclosure

1. Objectives of the Firm’s Financial Incentives

The Firm’s financial incentives aim to create a direct link between reward and performance and to incentivise staff in alignment with the Firm’s risk profile, including potential conflicts of interest. The Firm’s remuneration structure is evaluated regularly to ensure continued alignment with relevant regulatory requirements. The objective is to align individual and team contributions with performance objectives in a manner that:

• is consistent with and promotes sound and effective risk management;
• does not encourage excessive risk taking;
• includes measures to avoid conflicts of interest in accordance with the Firm’s policies, including the Integrity Policy; and
• is in line with the Firm’s business strategy, regulatory obligations, objectives, values, and long-term interests.

2. Fixed and Variable Remuneration

Total remuneration is determined considering multiple dimensions. The assessment of performance to determine variable remuneration considers financial as well as non-financial criteria.

Total remuneration is determined considering:

• individual performance both commercially and with reference to the appraisal methods detailed in the Firm’s Remuneration Policy;
• the performance of the relevant business unit; and
• the results of the Firm as a whole.

Non-financial criteria:

• form a significant part of the performance assessment process;
• where appropriate, override financial criteria;
• consider the individual’s conduct and make up a substantial portion of the non-financial criteria; and
• evaluate the individual’s performance in relation to effective risk management and compliance with the Firm’s policies, including the Integrity Policy.

All staff are eligible to receive variable remuneration.

3. Remuneration Governance and Decision-making Procedures

4. Key Characteristics of Remuneration Policies and Practices

The Firm has adopted a Remuneration Policy designed to ensure sound, prudent and compliant remuneration practices.

• Prepared in line with the Firm’s business strategy, objectives, values and interests, including consideration of risk appetite and strategy, culture and values, and long-term effects;
• Designed to ensure the Firm maintains and applies a sound and prudent remuneration process which does not impair compliance with any obligations; and
• Intended to identify and manage any conflicts of interest and promote sound and effective risk management and prudent risk taking.

CATEGORIES OF REMUNERATION:

• Base salary (fixed)
• Discretionary bonuses (variable)

REMUNERATION CRITERIA

Criteria Pertaining to the Firm:

• the performance and profitability of the Firm;
• the Firm’s risk appetite and strategy;
• the Firm’s desire to identify and manage any conflicts of interest; and
• the Firm’s culture and values.

Criteria Pertaining to Individual Business Units:

• the performance and profitability of the relevant business unit;
• the objectives set for the relevant business unit;
• where applicable, the long-term effects of the investment recommendations made by the business unit;
• control function personnel will be compensated, amongst other factors, by reference to objectives linked to those functions (independent of the performance of the business areas they control).

Criteria Pertaining to Individuals:

• the individual’s responsibilities and history with the Firm;
• performance in relation to the individual’s job description and terms of employment;
• the individual’s compliance with the Firm’s policies; and
• the individual’s adherence to the Firm’s culture and values.