Disclosure and Privacy

MIFIDPRU 8 Disclosure Financial Year Ended 31 December 2022

Introduction

HSC is a UK investment firm undertaking activities within the scope of the UK Markets in Financial Instruments Directive (“MIFID”). As such it is subject to the prudential requirements of the Investment Firms Prudential Regime (“IFPR”) contained in the MIFIDPRU Sourcebook of the Financial Conduct Authority (“FCA”) Handbook and the disclosure requirements outlined in MIFIDPRU 8. Under FCA rules HSC is categorised as a small non-interconnected (“SNI”) MIFIDPRU investment firm and such firms have very limited disclosure that they are required to make.

Basis of Disclosure

This disclosure for HSC is prepared at least annually on a solo entity (i.e. individual) basis. The disclosed information is proportionate to HSC’s size and organisation, and to the nature, scope and complexity of its activities.

In accordance with the provisions of MIFIDPRU, HSC is currently required to provide disclosure solely on its Remuneration Policies and Practices in accordance with MIFIDPRU 8.6.

Significant Changes Since Prior Disclosure

In accordance with when the provisions of MIFIDPRU were first applied to HSC, this is HSC’s first such disclosure and therefore there are no significant changes to prior disclosures which require to be set out here.

Disclosures under MIFIDPRU 8.6

  1. Risk profile of the firm: HSC is an investment advisor/manager. Its regulatory permissions do not allow it to risk its own capital in the financial markets. As such the performance of the firm is based on management and performance fees received from clients.
  2. Material risk takers: As an SNI firm HSC does not have any material risk takers as defined by SYSC19G.1.1R.
  3. Link between pay and performance: HSC has a small number of employees who are paid fixed remuneration and bonuses in line with the performance of the firm and their own contributions. The firm is run by the directors. Directors are not currently paid any bonus.
  4. Decision-making process for determining remuneration: Any decision on the distribution of profits is made after assessing the forward-looking capital requirements of the firm which may limit the ability of the firm to distribute all of the profits made. Remuneration is not based on the age, religion, gender, sexual orientation, ethnicity, or disability of any member of staff.
  5. Split Between Fixed and Discretionary Components – total staff costs amount to £45,447 and include a small bonus element which, due to the small number of staff members involved, is not disclosed.
  6. Quantative Remuneration Disclosures
    • Total Staff Remuneration £45,447
    • Of which directors £4,320