MiFIDPRU 8 Disclosure

For the year ended 31 December 2025

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 audited financial statements as at 31 December 2025, covering the period from 1 January 2025 to 31 December 2025.

This disclosure is made on an individual basis in accordance with MIFIDPRU 8.1.7R. The Firm is a member of a UK investment firm group and, is subject to prudential consolidation under MIFIDPRU 2.5 for the purposes of MIFIDPRU 3, 4, 5, 6 and 9. The disclosure requirements in MIFIDPRU 8 apply to the Firm on an individual basis, and the information in this document is presented on that basis.

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 Firm meets the conditions in MIFIDPRU 7.1.4R and accordingly the investment policy disclosure requirements in MIFIDPRU 8.7 do not apply to it.

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 risk profile and financial resilience. 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 is updated annually.

2. Governance Arrangements and Risk Management

The Board is responsible for defining, overseeing and being accountable for the implementation of governance arrangements that ensure the effective and prudent management of the Firm, including the segregation of duties and the prevention of conflicts of interest, in accordance with SYSC 4.3A.1R. The Board delegates specified oversight responsibilities to committees established at Group level, being the Financial Audit Committee and the Remuneration Committee, and retains ultimate responsibility for the Firm’s governance, risk management and remuneration arrangements notwithstanding that delegation.

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.

The Board of Directors retain 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 Financial Audit Committee, which is responsible for overseeing the development, implementation and maintenance of the firm’s risk management framework, reviewing material risk issues, and monitoring the adequacy and effectiveness of the internal control and compliance environment.

The Committee is required to meet at least annually and may meet more frequently as required. Minutes of Committee meetings are circulated to Committee members and, where the Committee Chairman considers it appropriate, to all members of the Board.

The Financial Audit Committee is supported by the Risk Function, which performs the underlying risk reviews and monitoring activities, and reports regularly to the Committee and to 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 risk management arrangements are structured around clearly defined roles, proportionate to the Firm’s current scale of operations, and are reviewed on an ongoing basis in line with the business growth and regulatory expectations:

• Business Functions: all staff performing activities for the Firm are responsible for managing risk as part of their day-to-day roles. Business teams are expected to identify and respond to risks as they arise, operate controls effectively, and escalate material issues in a timely manner.
• Risk Management and Compliance: these functions operate independently of the business and are responsible for developing and maintaining the risk management framework, facilitating risk assessments, monitoring control effectiveness, and advising on regulatory and operational risk matters.

The Firm does not currently maintain a separate internal audit function. Where additional assurance is required, the Board or the Financial Audit Committee engages independent external advisers on a targeted basis.

Corinthia’s risk appetite statement defines the level and types of risk the Firm is willing to accept in pursuit of its strategic objectives. The appetite is established by the Board of Directors and is reviewed periodically to ensure alignment with market conditions and the business strategy.

A variety of strategies and controls are employed to manage and mitigate risks, including risk avoidance, risk mitigation through operational controls and diversification, risk transfer to third parties including through insurance and outsourcing arrangements, and risk acceptance where the potential benefits outweigh the potential downside and the risk remains within the established risk appetite.

The Firm maintains professional indemnity, directors’ and officers’, cyber and general business insurance cover.

2.2. Potential for harm arising from the business strategy

The Board has considered the potential for harm associated with the Firm’s business strategy. The Firm provides portfolio management and arranging services to professional investors and does not deal on own account, hold client money or custody client assets. Revenues are derived from fee income which Corinthia is contractually entitled to receive in respect of the services it provides to Clients. Such Clients are typically institutional investors.

Due to the nature of its business model and associated controls, Corinthia believes that the overall potential for harm is low.

2.3. Risk management objectives and policies

Own funds risk. The Firm’s objective is to maintain own funds in excess of its own funds requirement and of the own funds threshold requirement determined through its ICARA process. Own funds are monitored against those requirements and reported to the Board, so that the Firm retains the capacity to absorb losses and, if necessary, to wind down its business in an orderly manner.

Concentration risk. The Firm does not deal on own account and does not hold client money or custody client assets, and so has no trading book exposures and no K-CON requirement. The Firm monitors the concentration risks arising from its business in accordance with MIFIDPRU 5, reports them to the FCA quarterly, and reviews them through its ICARA process.

Liquidity risk. The Firm’s objective is to maintain liquid assets in excess of its basic liquid asset requirement and of the liquid assets threshold requirement determined through its ICARA process. Liquid assets are monitored against those requirements and reported to the Board, so that the Firm can meet its obligations as they fall due and fund an orderly wind-down if required.

2.4. Management Body and Directorships

The Board as at 31 December 2025 comprised of the below individuals. Their number of directorships (as defined in MIFIDPRU) as at 31 December 2025 is provided alongside each.

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

2.5. 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 seeks to support effective decision-making and governance arrangements.

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 formal diversity targets in respect of the management body; however, it does actively monitor and support inclusive hiring practices. As no formal targets have been established, there were no applicable targets to assess during the reporting period.

3. Own Funds

The Firm’s composition of Own Funds as at 31 December 2025 is as follows:

COMPOSITION OF REGULATORY OWN FUNDS AS AT 31 DECEMBER 2025
	Item	Amount (£)	Source based on reference numbers / letters of the balance sheet in the audited financial statements
1	OWN FUNDS	3,053,329	SoFP, p.12
2	Tier 1 Capital	3,053,329	SoFP, p.12
3	Common Equity Tier 1 Capital	3,053,329	SoFP, p.12
4	Fully Paid-up Capital Instruments	3,750,000	Note 11
5	Share Premium	0	SoCE, p.13
6	Retained Earnings	(696,671)	SoFP, p.12; SoCE, p.13
7	Accumulated Other Comprehensive Income	0	N/A
8	Other Reserves	0	SoCE, p.13
9	Adjustments to CET1 Due to Prudential Filters	0	N/A
10	Other Funds	0	N/A
11	(-) TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 1	0	N/A
12	(-) Losses for the Current Financial Year	0	See item 6
13	(-) Intangible Assets	0	SoFP, p.12
14	(-) Deferred Tax Assets that Rely on Future Profitability	0	Note 5
15	(-) Defined Benefit Pension Fund Assets	0	N/A
16	(-) Holdings of Own CET1 Instruments	0	N/A
17	(-) Qualifying Holdings Outside the Financial Sector	0	N/A
18	(-) Other CET1 Deductions	0	N/A
19	CET1: Other Capital Elements, Deductions and Adjustments	0	N/A
20	Additional Tier 1 Capital	0	N/A
21	Fully Paid-up, Directly Issued Capital Instruments	0	N/A
22	Share Premium	0	N/A
23	(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 1	0	N/A
24	Additional Tier 1: Other Capital Elements, Deductions and Adjustments	0	N/A
25	Tier 2 Capital	0	N/A
26	Fully Paid-up, Directly Issued Capital Instruments	0	N/A
27	Share Premium	0	N/A
28	(-) TOTAL DEDUCTIONS FROM TIER 2	0	N/A
29	Tier 2: Other Capital Elements, Deductions and Adjustments	0	N/A

The Firm’s Common Equity Tier 1 capital comprises 3,750,000 fully paid ordinary shares of £1 each and retained losses. All ordinary shares rank equally for voting purposes, dividends and distributions on a winding up and are not redeemable. The Firm has issued no Additional Tier 1 or Tier 2 capital instruments.

OWN FUNDS: RECONCILIATION OF REGULATORY OWN FUNDS TO BALANCE SHEET AS AT 31 DECEMBER 2025
		Balance Sheet (£)	Under Regulatory Scope of Consolidation	Cross Reference
Assets – Breakdown by Asset Class
1	Trade and Other Receivables	804,705	804,705	Note 6
2	Cash and Cash Equivalents	3,024,432	3,024,432	Note 7
	Total Assets	3,829,137	3,829,137
Liabilities – Breakdown by Liability Class
1	Trade and Other Payables	621,838	621,838	Note 8
2	Borrowings	153,970	153,970	Note 9
	Total Liabilities	775,808	775,808
Shareholders’ Equity
1	Share Capital	3,750,000	3,750,000	Note 11
2	Retained Losses	(696,671)	(696,671)	SoCE, p.13
	Total Shareholders’ Equity	3,053,329	3,053,329

The Firm’s Common Equity Tier 1 capital comprises 3,750,000 fully paid ordinary shares of £1 each and retained losses. All ordinary shares rank equally for voting purposes, dividends and distributions on a winding up and are not redeemable. The Firm has issued no Additional Tier 1 or Tier 2 capital instruments.

OWN FUNDS: RECONCILIATION OF REGULATORY OWN FUNDS TO BALANCE SHEET AS AT 31 DECEMBER 2025
Balance Sheet(£)	Under Regulatory Scope of Consolidation	Cross Reference
Assets – Breakdown by Asset Class
1	Trade and Other Receivables	804,705	804,705	Note 6
2	Cash and Cash Equivalents	3,024,432	3,024,432	Note 7
Total Assets	3,829,137	3,829,137
Liabilities – Breakdown by Liability Class
1	Trade and Other Payables	621,838	621,838	Note 8
2	Borrowings	153,970	153,970	Note 9
Total Liabilities	775,808	775,808
Shareholders’ Equity
1	Share Capital	3,750,000	3,750,000	Note 11
2	Retained Losses	(696,671)	(696,671)	SoCE, p.13
Total Shareholders’ Equity	3,053,329	3,053,329

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”).

The Firm’s Own Funds Requirement as at 31 December 2025 was £1,897,401, determined by reference to the Fixed Overheads Requirement, which exceeded both the Permanent Minimum Capital Requirement and the K-Factor Requirement.

REQUIREMENT AS AT 31 DECEMBER 2025	(£)
Permanent Minimum Requirement	75,000
Fixed Overhead Requirement	1,897,401
K-Factor Requirement	21,638
Sum of the K-AUM, K-CMH and K-ASA requirements	21,638
Sum of the K-COH and K-DTF requirements	0
Sum of the K-NPR, K-CMG, K-TCD and K-CON requirements	0
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.

The Firm assesses compliance with the overall financial adequacy rule through its Internal Capital and Risk Assessment (“ICARA”) process. The ICARA is the Firm’s assessment of the harms its activities may cause, the own funds and liquid assets required to address those harms on an ongoing basis, and the own funds and liquid assets required to wind down the business in an orderly manner. It is documented, reviewed at least annually and on any material change to the business, and approved by the Board.

Through the ICARA the Board determines the Firm’s own funds threshold requirement and liquid assets threshold requirement. The Firm monitors its own funds and liquid assets against those requirements and reports the results to the Board. At 31 December 2025 the Firm held own funds and liquid assets in excess of both.

5. Remuneration

5.1. Governance and decision-making

Remuneration of individuals is governed by the Remuneration & Benefits Policy and it is typically reviewed annually by the Remuneration Committee. The Committee comprises of senior Group executives with remuneration and governance expertise and is chaired by the Group Chairman. No external remuneration consultants were engaged in respect of the financial year. The Board is responsible for satisfying itself that the Policy, as applied to individuals performing activities for the Firm, is consistent with the MIFIDPRU Remuneration Code in SYSC 19G, with the Firm’s risk appetite and business strategy, and with the Firm’s obligation to act in the best interests of its clients. The objective of the Firm’s approach to remuneration is to attract and retain individuals of the calibre required to manage client assets responsibly, to reward sustained performance, and to avoid creating incentives to take risk beyond the Firm’s risk appetite.

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.

5.2. Employment and cost allocation

The Firm has no direct employees. Individuals performing activities for the Firm are employed by other entities within the Group, and the cost of their services is recharged to the Firm in accordance with the Group’s transfer pricing methodology.

The Firm’s financial statements report administrative expenses, which comprises the fixed remuneration costs recharged by other Group entities. The remuneration disclosed below includes both the fixed costs reflected in the Firm’s accounts and variable remuneration attributable to activities for the Firm, which is not recharged and therefore does not appear in the financial statements. Accordingly, the total remuneration disclosed below differs from the presentation in the Firm’s accounts.

5.3. Material risk takers

The Firm has identified its material risk takers in accordance with SYSC 19G.5. The categories identified comprise members of the Board, holders of senior management functions, individuals with managerial responsibility for the Firm’s investment activities, and the heads of control functions. The Firm has not applied criteria additional to those in SYSC 19G.5.

NUMBER OF MRTs AS AT 31 DECEMBER 2025	TOTAL
Number of material risk takers identified for the year ended 31 December 2025	11

5.4. Fixed and variable remuneration

Fixed remuneration comprises base salary and standard benefits and reflects the individual’s role, responsibilities and experience. It is not linked to performance. Variable remuneration comprises discretionary annual bonus awarded in cash. Variable remuneration is not guaranteed and may be reduced to nil.

Awards are determined by reference to overall corporate performance and to the individual’s performance during the relevant period. Financial criteria include revenue, profitability and assets under management. Non-financial criteria include adherence to the Firm’s risk appetite, regulatory and policy compliance, and conduct and the treatment of clients. Poor conduct, or a failure of risk management or compliance, may reduce or eliminate an award irrespective of financial performance.

REMUNERATION FOR FINANCIAL YEAR 2025	FIXED (£)	VARIABLE (£)	TOTAL (£)
Senior Management	1,019,188	922,879	1,942,067
Other MRTs	150,333	59,583	209,916
Other Staff	215,417	105,188	320,605
Total Remuneration	1,384,938	1,087,650	2,472,588

5.5. Risk adjustment, guaranteed variable remuneration and severance

No guaranteed variable remuneration was awarded to material risk takers during the financial year and no material risk taker received such an award. No severance payments were awarded to material risk takers during the financial year; the total amount was £nil, no material risk taker received such a payment, and the highest award to a single individual was £nil.