MIFIDPRU 8 Disclosure

Overview

GSA Capital Partners LLP ("GSA" or "the Firm") is authorised and regulated for investment management activities in the UK by the Financial Conduct Authority ("FCA") and is classed as a Collective Portfolio Management Investment Firm ("CPMI") Alternative Investment Fund Manager ("AIFM") under the UK Alternative Investment Fund Management Directive ("AIFMD"), with permissions to undertake activities within the scope of the UK Markets in Financial Instruments Directive ("MIFID").

The FCA's Investment Firm Prudential Regime ("IFPR") is a new framework governing prudential requirements for investment firms. The IFPR comprises of revised rules on capital requirements, internal capital and risk assessment, liquidity requirements, governance, remuneration, and reporting and disclosure requirements. As a UK CPMI, GSA is subject to the prudential requirements of IFPR contained in the MIFIDPRU Prudential sourcebook for MIFID investment firms of the FCA Handbook.

This document has been prepared by GSA in accordance with the requirements of MIFIDPRU 8. All figures are for the year ending 31st March 2023.

Scope

MIFIDPRU broadly categorises firms as Small and Non-Interconnected firms ("SNI"), or non-SNI firms. The SNI designation is based upon quantitative thresholds. Non-SNI firms are deemed higher risk from an insolvency perspective by the FCA and subject to more intensive requirements under the regime.

GSA has considered the nine tests and their respective thresholds stipulated in MIFIDPRU 1.2 and has concluded it is an SNI firm. As an SNI firm, GSA is exempted from various requirements in MIFIDPRU, most notably the K-Factor requirements under MIFIDPRU 4.6, specific remuneration requirements and enhanced governance disclosures.

Risk Management

GSA's Management Committee has ultimate responsibility for the development of appropriate strategies, systems and controls for the management of risks within the business.

GSA has established and maintains documented risk management policies and procedures which identify the risks relating to its activities, processes and systems. GSA has adopted effective arrangements, processes and mechanisms to manage the risks relating to its activities, processes and systems.

GSA monitors the following:

1. the adequacy and effectiveness of its risk management policies and procedures;
2. the level of compliance by GSA and its relevant persons with the arrangements, processes and mechanisms adopted in accordance with its risk management policies;
3. the adequacy and effectiveness of measures taken to address any deficiencies in those policies, procedures, arrangements, processes and mechanisms, including failures by the relevant persons to comply with such arrangements, processes and mechanisms or follow such policies and procedures.

Remuneration Policy and Practices

As an SNI MIFIDPRU Investment Firm, GSA is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid out in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook ("SYSC")). GSA, as a CPMI, is also subject to the AIFMD Remuneration Code (SYSC 19B).

The objective of GSA's remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.

In addition, GSA recognises that remuneration is a key component in how the Firm attracts, motivates, and retains quality staff and sustains consistently high levels of performance, productivity and results. As such, the Firm's remuneration philosophy is also grounded in the belief that its people are its most important asset and provide its greatest competitive advantage.

Remuneration Framework

Remuneration at GSA is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a mostly discretionary basis and takes into consideration the Firm's financial performance, as well as the performance of each business area, and the overall performance of the individual in contributing to the Firm's success.

The ultimate decision on variable remuneration to be awarded to staff members is made by the Management Committee, considering the Firm's current profits and any future capital required to be put aside for business plans or for regulatory capital purposes based on forecasts. The outcome of these considerations will then be used to determine a bonus pool to be distributed to staff members. Any discretionary bonus pool will be based on the profit of the Firm and not future income.

The objective of GSA's Remuneration Policy is to ensure that the way GSA remunerates its staff:

• is consistent with and promotes sound and effective risk management;
• avoids conflicts of interests, encourages responsible business conduct, promotes risk awareness and does not encourage excessive risk taking;
• is in line with GSA's business strategy, objectives, values and long-term interests; and
• is gender neutral and respects the principle of equal pay for male and female workers for equal work or work of equal value.

Quantitative Remuneration Disclosure

Aggregated quantitative information on remuneration paid to all staff: