MiFIDPRU 8 Disclosure

1. Introduction

This disclosure has been prepared by Corinthia UK Management Limited (“Corinthia” or the “Firm”) to fulfil the regulatory disclosure requirements set out by the Financial Conduct Authority (“FCA”) in the Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”).

Corinthia is an investment manager providing portfolio management services and arranging (bringing about) deals in investments for investment vehicles and separately managed accounts for professional investors on both a discretionary and a non-discretionary basis. This report is applicable to the following entity:

• Corinthia UK Management Limited (FRN: 1018170).

This report has been prepared using the unaudited financial statements as at 31 December 2024, covering the period 23 December 2023 to 31 December 2024.

For the purposes of MIFIDPRU, the Firm has been classified as a “non-SNI” firm and is subject to the standard disclosure requirements of MIFIDPRU 8. As a non-SNI firm, Corinthia is required to disclose the following information:

• Risk management objectives and policies;
• Governance arrangements;
• Own Funds;
• Own Funds Requirements; and
• Remuneration policy and practices.

The regulatory capital a firm must hold under MiFIDPRU to meet prudential requirements and absorb losses (“Own Funds Requirement”) is disclosed to give stakeholders and market participants an insight into the Firm’s culture, and data on the Firm’s Own Funds Requirement allows potential investors to assess the Firm’s financial strength.

This document has been prepared by Corinthia in accordance with the requirements of MiFIDPRU 8 and has been reviewed by the Firm’s governing body (“the Board”). The document will be updated annually. While the Firm’s financial period end was 31 December 2024, Corinthia UK Management Limited was authorised to conduct business by the Financial Conduct Authority on 31 January 2025. The information within this document with respect to remuneration was prepared using the financial data for the year ending 31 December 2024 and aligns with the unaudited financial statements submitted to Companies House on behalf of Corinthia UK Management Limited. Remuneration refers to any form of pay or benefit, including salaries, discretionary pension benefits and benefits of any kind, split into fixed and variable components. As Own Funds Requirement only applies from the authorisation, the information related to the Own Funds and Own Funds Requirement in this disclosure was prepared using the data as at the date of authorisation.

2. Governance Arrangements and Risk Management

2.1 Risk Management

Risk management is an integral part of the Firm’s corporate governance framework and organisational culture. Corinthia’s risk management philosophy centres on the proactive identification, assessment and mitigation of risks across all business areas.

2.2 Governing Body Composition and Responsibility

Corinthia’s Board retains ultimate responsibility for setting Corinthia’s risk appetite and overseeing the effectiveness of the Firm’s risk management framework. Risk governance responsibilities are delegated to the Audit Committee, which provides oversight of the framework and reviews material risk issues. In practice, the Audit Committee is supported by the risk function, which performs the underlying risk reviews and monitoring activities, reporting regularly to both senior management and the Board.

The senior leadership team is responsible for embedding risk management within their respective areas and ensuring material risks are addressed at the operational level.

The Firm’s approach is consistent with the “three lines of defence” model outlined below and is proportionate to the Firm’s current scale of operations. It is reviewed on an ongoing basis in line with the business growth and regulatory expectations.

The Board comprises of the below individuals. Their number of directorships (as defined in MiFIDPRU) as at 31 December 2024 is provided alongside each.

NAME	DIRECTORSHIPS
Paul Weightman	37
Adam Wheeler	3
Volker Samonigg	1
Elizabeth Ball	0
Mark Wilton	0
Alice Foucault	0

2.3 Diversity

Corinthia is committed to fostering a diverse, equitable and inclusive culture that reflects the global markets being served. By embracing different perspectives, backgrounds and experiences, the Firm has created a culture of excellence, integrity and accountability, empowering our team to deliver innovative solutions and long-term value for our partners.

Corinthia’s management has a responsibility to lead by example and act in accordance with the Firm’s commitment to diversity. The Firm does not set targets in this regard; however, it does actively monitor and support inclusive hiring practices.

3. Own Funds

The Firm’s composition of Own Funds as at the date of the authorisation is as follows:

COMPOSITION OF REGULATORY OWN FUNDS AS AT 31 JANUARY 2025
	Item	Amount (£)	Source based on reference numbers / letters of the balance sheet in the Audited Financial Statements
1	OWN FUNDS	3,000,000
2	Tier 1 Capital	3,000,000
3	Common Equity Tier 1 Capital	3,000,000
4	Fully Paid-up Capital Instruments
5	Share Premium	3,000,000
6	Retained Earnings
7	Accumulated Other Comprehensive Income
8	Other Reserves
9	Adjustments to CET1 Due to Prudential Filters
10	Other Funds
11	(-) TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 1
19	CET1: Other Capital Elements, Deductions and Adjustments
20	Additional Tier 1 Capital	0
21	Fully Paid-up, Directly Issued Capital Instruments
22	Share Premium
23	(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 1	0
24	Additional Tier 1: Other Capital Elements, Deductions and Adjustments
25	Tier 2 Capital	0
26	Fully Paid-up, Directly Issued Capital Instruments
27	Share Premium
28	(-) TOTAL DEDUCTIONS FROM TIER 2	0
29	Tier 2: Other Capital Elements, Deductions and Adjustments

OWN FUNDS: RECONCILIATION OF REGULATORY OWN FUNDS TO BALANCE SHEET AS AT 31 JANUARY 2025
		Balance Sheet (£)	Under Regulatory Scope of Consolidation	Cross Reference
Assets – Breakdown by Asset Class
1	Cash and Cash Equivalents	3,000,000
	Total Assets	3,000,000
Liabilities – Breakdown by Liability Class
1	Creditors: Amounts Falling Due Within One Year	0
	Total Liabilities	0
Shareholders’ Equity
1	Share Capital	3,000,000
	Total Shareholders’ Equity	3,000,000

4. Own Funds Requirements

As a non-SNI firm, Corinthia is required to maintain an amount of Own Funds that is the higher of:

• Permanent Minimum Capital Requirement (“PMR”);
• K-factor Requirement (“KFR”); and
• Fixed Overheads Requirement (“FOR”).

REQUIREMENT AS AT 31 JANUARY 2025	(£)
Permanent Minimum Requirement	75,000
Fixed Overhead Requirement	1,897,401
Total K-Factor Requirement	416,760
K-AUM – Risk Arising from Managing and Advising on Investments	416,760
Own Funds Requirement	1,897,401

4.1 Overall Financial Adequacy

Corinthia must also comply with the Overall Financial Adequacy Rule (“OFAR”). This means that Corinthia must hold Own Funds and liquid assets that are adequate, both as to their amount and quality, to ensure that:

• The Firm remains financially viable throughout the economic cycle and can address material potential harm that may result from its activities; and
• The Firm’s business can be wound down in an orderly manner while minimising harm to consumers or other market participants.

5. Remuneration

The Board is directly responsible for the Firm’s Remuneration & Benefits Policy. Remuneration is governed by the Remuneration & Benefits Policy and it is typically reviewed annually by the Remuneration Committee. Bonus levels are set based on the individual’s performance during the relevant period with reference to overall corporate performance.

The disclosures below are made in accordance with the requirements in MiFIDPRU. They provide information regarding Corinthia’s remuneration policies and governance as well as quantitative information on the remuneration of those categories of staff whose professional activities are considered by the Firm to have a material impact on its risk profile or on the assets that it manages.

NUMBER OF MRTs AS AT 31 DECEMBER 2024	TOTAL
Number of MRTs Identified for 2024 in Accordance with Requirements	0

FOR FINANCIAL YEAR 2024	FIXED (£m)	VARIABLE (£m)	TOTAL (£m)
Senior Management and Other MRTs	0	0	0
Other Staff	0	0	0
Total Remuneration			0

The total amount of severance payments awarded to Material Risk Takers during the last financial year was £0 (highest: £0).