REGULATORY DISCLOSURE

UK Stewardship Code
Under Rule 2.2.3R of the Financial Conduct Authority’s Conduct of Business Sourcebook, Cadwyn Capital LLP (“Cadwyn Capital” or the “Firm”) is required to include a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (“Code”) or, where it does not commit to the Code, explain its considered choice based on the Firm’s investment approach. The Code is a voluntary code and sets out a number of principles in relation to engagement by investors in UK-listed companies.

Cadwyn Capital invests in a variety of asset classes and security types in a variety of jurisdictions globally and exposure to UK-listed companies is very limited. Therefore, whilst Cadwyn Capital generally supports the objectives that underlie the Code, the nature of its investment strategy results in limited applicability of the Code to the firm’s activities.

The Firm has chosen not to formally commit to the Code given its investment approach.

This statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice.  Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time.

For further details on any of the above information please contact the Firm’s Compliance Officer using details on the Contact page of this website.

MIFIDPRU 8 Disclosure

1. MIFIDPRU 8 DISCLOSURE

Cadwyn Capital LLP (“the Firm”) is authorised and regulated by the Financial Conduct Authority (the “FCA”).

The Firm is categorised as a ‘SNI MIFIDPRU Investment Firm’ by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s MIFIDPRU 8 disclosure fulfils the Firm’s obligation to disclose to market participants’ key information on a firm’s remuneration policies and practices.

In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities.

This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model.

2. REMUNERATION POLICIES AND PRACTICES

The Firm is subject to the Remuneration Code (the “Code”) for MIFIDPRU Firms as codified in Section 19G of the SYSC sourcebook of the FCA handbook.

This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.

A. Qualitative Information

The Firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote effective risk management and do not encourage excessive risk taking.

The Firm ensures that the remuneration policy and its practical application are consistent with the Firm’s business strategy, objectives and long-term interests.

Given the nature and small size of our business, remuneration for all employees is set by the Firm’s senior managers.

Staff receive a salary which reflects their market value, responsibilities and experience.

Staff may also receive variable remuneration, such as an annual bonus, where the individual operates within the risk appetite of the company and has demonstrated appropriate behaviour.

Variable remuneration is intended to reflect contribution to the Firm’s overall success. Staff are assessed throughout the year and rated based on company and individual performance. The performance assessment considers both financial measures – such as earnings and profit margin – and non-financial measures – such as productivity/efficiency and quality, risk management, people and culture, client focus, growth, and innovation.

The Firm’s linkage between variable remuneration and performance is based upon the following tenets:

1. Discourage excessive risk-taking

2. Ensure client interests are not negatively impacted

3. Attraction and retention of staff members

4. Aligning the interest of senior staff members via long-term incentive awards

5. Link a proportion of a staff member’s total compensation to the Firm’s performance

6. Ensuring an appropriate balance of financial results between staff and shareholders

B. Quantitative Information

The Firm may omit required quantitative disclosures in relation to remuneration where it believes that the information could be regarded as prejudicial to its adherence to the UK General Data Protection Regulations (which was adopted from the EU equivalent Regulation on 1 January 2021) and the Data Protection Act 2018 on the protection on natural persons with regard to the processing of personal data and on the free movement of such data.

Due to the size of the Firm and limited number of staff, quantitative disclosures in relation to remuneration have not been included.

Anti-Slavery Notice

INTRODUCTION
This statement is made by Cadwyn Capital LLP (“Cadwyn Capital” or the “Firm”) pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”) and in respect of the financial year ending 31 March 2022.

The purpose of this statement is to set out the steps that Cadwyn Capital has taken and continues to take to ensure that modern slavery or human trafficking does not take place in our business or our supply chain. Cadwyn Capital is committed to acting ethically and with integrity.

OUR BUSINESS STRUCTURE
Cadwyn Capital is a UK-based investment manager specialising in listed securities. The Firm is a UK limited liability partnership that is authorised and regulated by the UK

Financial Conduct Authority to carry on investment management activities.

OUR SUPPLY CHAIN
Cadwyn Capital does not tolerate modern slavery or human trafficking and takes a risk-based approach to its supply chain, including making inquiries where it is considered necessary to do so. The Firm’s business is a service business operated by a small skilled skilled workforce and has a limited supply chain. Accordingly, Cadwyn Capital considers that there is a low risk of slavery and human trafficking within its business when compared, for example, to a business that manufactures or sells goods.

However, parts of our supply chain could pose potential risk, namely third-party providers of services such as catering, security and cleaning.

The firm believes that it undertakes appropriate due diligence in relation to new suppliers and expects our suppliers, and their supply chains, to comply with all relevant legislation and regulations in the countries in which they operate. The firm has an escalation policy that allows employees to report issues and concerns without reprisals for doing so. The Firm’s policies are periodically reviewed and, where necessary, updated to ensure the Firm’s continuing commitment to the Act.

STAFF TRAINING
The Firm’s Compliance Manual and Code of Ethics require staff to act with integrity and abide by the Firm’s policies and procedures. All staff are required to attest to this on a regular basis and are provided with appropriate ongoing training to ensure they are aware of their obligations to comply with the Firm’s policies and procedures, including with respect to the risk of modern slavery.

This statement will be reviewed annually and updated as required.