Regulatory Disclosure

Other regulatory updates as at 31st March 2023

Introduction

Regulatory Context

The aim of these disclosures, required under MIFIDPRU 8, is to enable stakeholders and market participants to have an insight into how SilverStreet Capital LLP (“SilverStreet” or the “Firm”) is run. These disclosures should assist stakeholders to make better and more informed decisions about their relationship with the Firm.

Frequency

These MIFIDPRU disclosures, as at the Firm’s Accounting Reference Date (“ARD”) – currently 31 March - will be made at least annually. These will be published on the Firm’s website on the same date that the annual financial statements are published and filed with the Registrar of Companies. More frequent updates (and hence public disclosure) will be made if this is deemed to be required, for example, should there be a major change to the Firm’s business model.

Proportionality

The level of detail provided in the qualitative disclosures is proportionate to the size and internal organisation of the Firm. It is also proportionate to the nature, scope and complexity of the Firm’s business activities. This disclosure has been made in line with the requirements which apply to SilverStreet as a MIFIDPRU investment firm, which is also classed as Small and Non-Interconnected (“SNI”) with no Additional Tier 1 Capital in issue.

Media and Location

This information is published on the Firm’s website and is free to obtain.

Changes to Information disclosed

This is the Firm’s first MIFIDPRU 8 disclosure and therefore, there are no changes to be highlighted.

Verification

The information contained in this document has not been audited by the Firm’s external auditors, as this is not a requirement, and does not constitute any form of financial statement and must not be relied upon in making any judgement on the Firm.

Background

SilverStreet is incorporated in the UK and is authorised and regulated by the Financial Conduct Authority (“FCA”). The Firm is an SNI MIFIDPRU investment firm, that has no additional tier 1 instruments in issue. As such, the Firm is only required to disclose its remuneration policies and practices, as per MIFIDPRU 8.1. These disclosures are made by the Firm on solo basis as required by MIFIDPRU 8.1.7R.

MIFIDPRU 8.6 – Remuneration

SilverStreet is subject to the ‘MIFIDPRU Remuneration Code’.

Distributions to Senior Management and Owners

In accordance with the guidance in SYSC 19G.4.4, at the end of each year, the residual profits of the Limited Liability Partnership is formally distributed among the members through the payment of drawings. This is not considered to be remuneration for the purpose of the Firm’s Remuneration Policy. Salaried Members are paid a fixed salary, by way of fixed remuneration, which is not repayable. Discretionary shares of profits received by members based on performance of the individual are considered to constitute variable remuneration. All other distributions received by Senior Managers, are considered to be fixed or variable, depending on whether they are discretionary and based on the performance of the individual or the business.

Qualitative Disclosures

The Firm has in place a remuneration policy which is approved by the governing body at least annually. The remuneration policy’s overarching aim is the promotion of sound and effective risk management, while reducing conflicts of interests and encouraging good conduct. The purpose of the remuneration policy is to set out how the Firm will provide remuneration in a manner that is consistent with the MIFIDPRU remuneration code as outlined above, with the main objective of the financial incentives being to attract, motivate and maintain high-calibre employees. The remuneration strategy has been designed to ensure consistency with the risk profiles, rules and instruments of incorporation of the funds advised and with the objectives set out in the Firm’s business plan and to ensure no conflict of interest between staff (including members) and investors, and compliance with conduct of business rules. The Firm does not believe it is proportionate to have a remuneration committee, based on its current activities.

As an SNI MIFIDPRU investment firm, SilverStreet is not required to identify material risk takers.

The Firm’s approach to remuneration for all staff includes:

• The Firm’s approach, including overall principles, and how the Firm links variable remuneration and performance, the main performance objectives and the categories of staff eligible to receive variable remuneration;

• Information on different components of remuneration and if they are categorised as fixed or variable; and

• Summarises financial and non-financial performance criteria and how these are broken down into the criteria for assessing performance of the Firm, business units and individuals.

All remuneration payments are made as cash transfers, though in principle certain proportions of Other regulatory updates as at 31ˢᵗ March 2023

Quantitative Disclosures

The Firm considers that it has a single business area (investment management), and the total remuneration paid to staff as required under MIFIDPRU 8.6.8R (4) can be found below. The variable remuneration reflects such remuneration paid with respect to performance over the financial year (even if paid following the end of the year). There were no guaranteed variable remuneration or severance payments awarded during the financial year ending 31st March 2023.