The Firm’s remuneration policy is designed to ensure that it complies with the RemCode and that its compensation arrangements:

1. Are consistent with and promote sound and effective risk management;
2. Do not encourage excessive risk taking;
3. Includes measures to avoid conflicts of interest;
4. in line with the Firm's business strategy, objectives, values, and long-term interests; and
5. on a gender-neutral basis.

Proportionality
The Firm’s disclosures are prepared in accordance with the relevant requirements in SYSC 19G in a way which is appropriate to its size, internal organisation and the nature, scope and complexity of its business model and activities.
Application of the Requirements
The Firm completes the remuneration disclosure annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure will be made more frequently if there is a major change to the Firm’s business model.

1. Summary of the Firm’s approach to remuneration for all staff, including the decision-making procedures and governance in adopting the remuneration code:
   • The Firm’s remuneration policy has been developed internally to align with the Remuneration principles laid down by the FCA.
   • Senior management ensures that the remuneration practises are in line with the business strategy, long-term corporate values and aims to avoid conflicts of interest.
   • The Firm believes that its remuneration policies are consistent with and promote sound and effective risk management. Likewise, the policies do not encourage excessive risk-taking that exceeds the level of tolerated risk.
   • The Firm complies with the remuneration principles set out in the policy.
   • Due to the size, nature and complexity of the Firm, the Firm does not have an independent remuneration committee and the Firm’s senior management are responsible for the governance of the remuneration function.
   • The Firm believes in rewarding individual and team performance based on the contributions to the Firm’s success.
   • The Firm’s ability to pay a variable remuneration further takes into account both the capital and liquidity regulatory requirements of the Firm over a rolling three-year period.
   • When assessing individual performance to determine the amount of variable remuneration, the Firm will consider both financial and non-financial criteria.
2. Qualitative characteristics of the remuneration policies and practices:
   • Individuals are rewarded based on their contribution to the overall strategy of the business. Other factors, such as performance, reliability, effectiveness of controls, business development and profitability of the business are taken into account when assessing the performance of the staff.
   • Remuneration is split as follows:
   • Fixed remuneration applies to all staff, including salary, pension, and benefits.
     • Primarily reflects a staff member’s role, responsibility, experience, and comparative market rates. It is pre-determined and non-discretionary. This is not linked to performance.
   • Variable remuneration compromises of discretionary bonuses.
     • Such awards are discretionary in nature.
     • The remuneration amount is based on an assessment of individual/workplace performance and contribution, as well as the profitability of the firm.
     • It is not linked to any specific performance targets or individual investment performance.
     • The payment of bonuses is discretionary and neither the award nor the amount is guaranteed.
   • Senior management ensures that the fixed and variable components of the total remuneration are appropriately balanced and ensuring that the fixed component represents a sufficiently high proportion of the total remuneration. This allows full flexibility in relation to variable remuneration, including the ability to pay no variable remuneration.