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Appian Capital Advisory – MIFIDPRU 8 Disclosure

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INTRODUCTION

The Financial Conduct Authority (“FCA“) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU“) sets out the detailed prudential requirements that apply to Appian Capital Advisory LLP (“Appian“), the sub-adviser to Appian Capital Advisory Limited. Chapter 8 of MIFIDPRU (“MIFIDPRU 8“) sets out public disclosure rules with which Appian must comply in respect of its remuneration policy and practices.

Appian Capital Advisory LLP is classified under MIFIDPRU as a small and non-interconnected investment firm (“SNI MIFIDPRU investment firm”). As such, MIFIDPRU 8 requires Appian to make public disclosures regarding its remuneration policy and practices.

The purpose of these disclosures is to give stakeholders and market participants an insight into Appian’s culture, and to assist stakeholders in making more informed decisions about their relationship with Appian.

This document has been prepared by Appian Capital Advisory LLP in accordance with the requirements of MIFIDPRU 8 and is reviewed and approved by the Designated Senior Manager responsible for prudential matters and approved by the Remuneration Committee. Unless otherwise stated, all figures are as at 31 December 2025.

This disclosure is made on an annual basis and will be updated following each financial year-end. The document is published on Appian’s website at appiancapitaladvisory.com/mifidpru-8-disclosure/.

REMUNERATION POLICY AND PRACTICES

Overview

As an SNI MIFIDPRU investment firm, Appian is subject to the basic requirements of the MIFIDPRU Remuneration Code (as set out in Chapter 19G of SYSC). The purpose of the remuneration requirements is to:

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

The objective of Appian’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 Appian and the services it provides to its clients.

Characteristics of the Remuneration Policy

Remuneration at Appian comprises fixed and variable components.

Fixed Remuneration

The fixed component is set at a level that is competitive with the relevant market and is sufficient to attract and retain skilled staff. Fixed remuneration typically includes base salary (or, for LLP members, fixed drawings), medical cover, pension contributions, leave and other applicable allowances.

The fixed component represents a sufficiently high proportion of total remuneration to enable the operation of a fully flexible variable remuneration policy, including the possibility of paying no variable remuneration in any given year.

Variable Remuneration

Variable remuneration comprises two components:

(a) Bonus
Bonus is paid on a discretionary basis at a varying percentage of fixed remuneration and takes into consideration Appian’s financial performance and the financial and non-financial performance of the individual in contributing to Appian’s success.

All staff are subject to annual performance review before a bonus is awarded. The review covers a range of areas applicable to each individual’s role and responsibilities, including but not limited to contribution to investment or asset management success, team development and risk management. Bonus awards may be subject to deferral and/or clawback provisions where appropriate, in accordance with applicable regulatory requirements and the Firm’s internal policies.

(b) Carried Interest
Carried interest is subject to fund performance hurdles being met and is paid over a period of time. It serves as a long-term incentive to ensure alignment of interests on investment performance and the retention of key staff. Carried interest arrangements are documented in the relevant fund partnership agreements and are subject to clawback provisions consistent with market practice.

The balance between fixed and variable remuneration is reviewed annually by the Remuneration Committee to ensure it remains appropriate having regard to regulatory requirements, market practice and the Firm’s risk profile. This allows for the possibility of paying no variable remuneration component, which the Firm may do in certain situations, such as where Appian’s profitability is constrained, where there is a risk that Appian may not be able to meet its capital or liquidity regulatory requirements, or where the performance hurdles set for relevant funds are not met.

GOVERNANCE AND OVERSIGHT

Appian’s Remuneration Committee is responsible for setting and overseeing the implementation of Appian’s remuneration policy and practices. In order to fulfil its responsibilities, the Remuneration Committee:

  • 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 those which have implications for risk and risk management;
  • Ensures that the remuneration policy and practices take into account the public interest and the long-term interests of partners, investors and other stakeholders; and
  • Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of Appian and its clients.

Appian’s remuneration policy and practices are reviewed at least annually, and in any event following any material change to the Firm’s business model, risk profile or regulatory classification, by the Remuneration Committee.

The results of the annual review, including any proposed changes to the remuneration policy, are documented and retained as part of the Firm’s governance records.

Where any member of the Remuneration Committee has or may have a conflict of interest in relation to a remuneration decision, that member will recuse themselves from the relevant part of the decision-making process.

 

Page last updated: 13 July 2026