The Financial Conduct Authority (“FCA” or “regulator”) in the Prudential sourcebook for MiFID
    Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements
    that apply to Nimrod Capital LLP (“Nimrod” or the “Firm”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”)
    sets out public disclosure rules and guidance with which the Firm must comply, further to those
    prudential requirements.

    Nimrod is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm
    (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose
    information regarding its remuneration policy and practices.

    This document has been prepared by Nimrod in accordance with the requirements of MIFIDPRU 8
    and is verified by a Meeting of the Members. Unless otherwise stated, all figures are as at the Firm’s
    31 March 2023 financial year-end.

    Remuneration Policy and Practices


    As an SNI MIFIDPRU Investment Firm, Nimrod is subject to the basic requirements of the
    MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management
    arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of
    the remuneration requirements is to:

    • Promote effective risk management in the long-term interests of the Firm and its clients;
    • Ensure alignment between risk and individual reward;
    • Support positive behaviours and healthy firm cultures; and
    • Discourage behaviours that can lead to misconduct and poor customer outcomes.

    The objective of the Firm’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, the Firm 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 the most important asset and provide its greatest competitive advantage.

    Nimrod is committed to excellence, teamwork, ethical behaviour, and the pursuit of exceptional
    outcomes for its clients. From a remuneration perspective, this means that performance is
    determined through the assessment of various factors that relate to these values, and by making
    considered and informed decisions that reward effort, attitude, and results.

    Characteristics of the Firm’s Remuneration Policy and Practices

    Remuneration at Nimrod 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 discretionary basis and takes into consideration the Firm’s financial performance as well
    as the financial and non-financial performance of the individual in contributing to the Firm’s success.
    All staff members are eligible to receive variable remuneration.

    The fixed and variable components of remuneration are appropriately balanced: the fixed component
    represents a sufficiently high proportion of the total remuneration to enable the operation of a fully
    flexible policy on variable remuneration. This allows for the possibility of paying no variable
    remuneration component, which the Firm would do in certain situations, such as where the Firm’s
    profitability performance is constrained, or where there is a risk that the Firm may not be able to
    meet its capital or liquidity regulatory requirements.

    Governance and Oversight

    A Meeting of the Members (“the Governing Body”) sets remuneration policy and practices of the
    Firm and that body is responsible overseeing implementation of such policy and practice. In order to
    fulfil its responsibilities, the Governing Body.

    • Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital, and liquidity.
    • Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm.
    • Ensures that the Firm’s remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors, and other stakeholders in the Firm.
    • Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of the Firm and of its clients.
    • Nimrod’s remuneration policy and practices are reviewed annually by the Governing Body.

    Quantitative Remuneration Disclosure

    For the financial year ended 31 March 2023, the total amount of remuneration awarded to all staff
    was £1,146,000 of which £860,000 comprised the fixed component of remuneration, and £286,000
    comprised the variable component. For these purposes, ‘staff’ is defined broadly, and includes, for
    example, employees and members of the Firm itself.