The Firm prepares public disclosure and other required external publications to increase confidence and transparency and provide stakeholders and market participants an insight into how these firms are run. We understand that public disclosures are a core part of market discipline, providing important information and transparency to participants to enable markets to work well.

An established internal controls framework is in place to ensure that the disclosure, including other external publications, meet the relevant regulatory requirements and standards. As such, prior to external publication, the documents are subject to internal verification and approval of the Firms Directors.

The Firm is responsible for the production of public disclosures. The draft Disclosure document will be reviewed by the Firms Compliance Officer before its submission for approval to the Board.

The public disclosure requirements applicable to the Firm as an entity authorised to undertake MIFID regulated activities, are contained in MIFIDPRU 8 of the FCA Handbook, which came into force from 1 January 2022. The disclosure containing both qualitative and quantitative data are made annually, on a solo entity basis or more frequently in the event of a material change.

Based on the Firm’s IFPR prudential classification as being a SNI firm, the public disclosure document will be prepared to contain information in relation to remuneration policy and practices

The Firm is required to publicly disclose the information specified in this Policy on an annual basis on the date it publishes its annual financial statements on Companies House, which is in April annually.

The information under MIFIDPRU 8.1 that is required to be disclosed by the Firm, will be published on the Firms Group website; https://www.dragoncapital.com

The Firm did not issue Additional Tier 1 Capital (“AT1 capital”). As a result, the Firm is not subject to the disclosure requirements under MIFIDPRU 8.2, 8.4 and 8.5, relating to the risk management objectives and policies, own funds and own funds disclosure requirements.

This document sets out the public disclosure under MIFIDPRU 8 for the Firm as of Year-End 2023 which is the Firm’s accounting reference date.

As a MIFIDPRU investment firm, we must establish and implement disclosure requirements to provide investors, stakeholders and wider market participants an insight into how the Firm is run. This disclosure sets out the overarching requirements that apply to the Firm.

The Firm is committed to having robust internal controls to ensure the completeness, accuracy, and compliance with the relevant public disclosure regulatory requirements.

This document has been subject to internal governance and verification process, and approval by the Board in line with the Public Disclosure Policy that the Firm has adopted to ensure compliance with the regulatory requirements contained in MIFIDPRU 8.

The Policy requires internal challenge and oversight prior to approval and publication.

Given the size, internal organisation and the nature, scope and complexity of the activities of the Firm it does not have a separate supervisory function or Remuneration Committee. Therefore, the Remuneration policy’s supervisory function will be undertaken by the Firm’s Group HR (“Group”).

The Firm’s performance period is from 1 st January to 31st December.

The Firm understands it needs to comply with the requirements of the FCA’s SYSC Chapter 19G General Application of the Senior Management Arrangements, Systems and Controls Sourcebook.

The Firm’s remuneration approach is designed to support individual and corporate performance, encourage the sustainable long-term financial health of the business and promote sound risk management for the success of the Firm and to the benefit of its customers, counterparties and the wider market. Our remuneration approach promotes long-term value creation through transparent alignment with the agreed corporate strategy.

The Board believes the Firm’s remuneration structure is appropriate for the business and the industry it operates in and is efficient and cost-effective in delivering its long-term strategy.

Undeserved and excessive remuneration sends a negative message to all stakeholders, including the Firm’s workforce, and causes long term damage to the Firm and its reputation.

The objectives of the Firm’s remuneration practices are as follows:

• The Firm undertakes to reward all employees fairly, regardless of job function, race, religion, colour, national origin, sex, sexual orientation, marital status, pregnancy, disability or age;
• It is the policy of the Firm to operate competitive remuneration policies to attract, retain and motivate an appropriate workforce for the Firm;
• The Firm is also committed to ensuring that its remuneration practices encourage high standards of personal and professional conduct, support sound risk management and do not encourage risk taking that exceeds the level of tolerated risk of the Firm, and are aligned with the Firm’s regulatory requirements;
• Rewards for all staff will be aligned to financial and non-financial performance criteria and risk profile, and in all cases will be in line with the business strategy, objectives, values, culture and long-term interests of the Firm;
• The Firm will not allow any unfair or unjust practices that impact on pay;
• The Firm undertakes that it will not award remuneration using vehicles or methods the aim of which is to attempt to avoid application of the relevant FCA’s Remuneration Code.

The Firm uses the following financial incentives:

• bonuses;
• salary raises;
• professional development opportunities;

Our financial incentives are designed to:

• raise employee satisfaction;
• recognise individual performance;
• attract and retain talent;
• encourage collaborative teamwork; and
• motivate staff to achieve Firm-wide objectives.

The Firms Group are responsible for the Firm’s remuneration policy.

As a SNI, the Firm is not required to establish a Remuneration Committee. Given the size, internal organisation and the nature, scope and complexity of the activities of the Firm it has not formed a Remuneration Committee. Therefore, the Remuneration policy’s supervisory function is undertaken by the Firm’s Group HR.

The Group is responsible for reviewing and approving salary amendments and the Firm’s bonus pool arising from the annual compensation review.

The Firm makes a clear distinction between the fixed and variable remuneration.

Fixed remuneration primarily reflects a staff member’s professional experience and organisational responsibility as set out in the staff member’s job description and terms of employment; and is permanent, pre-determined, nondiscretionary, non-revocable and not dependent on performance.

Variable remuneration is based on performance and reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment. In exceptional cases, variable remuneration is based on other conditions. Variable remuneration includes discretionary pension benefits.

The Firm will ensure that the fixed and variable components of an individual’s total remuneration are appropriately balanced. In determining this balance, the Firm considers the following factors:

• The Firm’s business activities and associated prudential and conduct risks;
• The role of the individual in the Firm;
• The impact that different categories of staff have on the risk profile of the Firm or of the assets it manages;
• No individual must be dependent on variable remuneration to an extent likely to encourage them to take risks outside the risk appetite of the Firm;
• It may be appropriate for an individual to receive only fixed remuneration, but not only variable remuneration; and
• Variable remuneration must not affect the Firm’s ability to ensure a sound capital base.

When assessing individual performance to determine the amount of variable remuneration to be paid to an individual, the Firm takes into account financial as well as non-financial criteria. Non-financial criteria should:

• form a significant part of the performance assessment process;
• override financial criteria, where appropriate;
• include metrics on conduct, which should make up a substantial portion of the non-financial criteria; and

The Firm takes into account both financial and non-financial criteria when assessing the individual performance of its staff. This aims not only to discourage inappropriate behaviours but also to incentivise and reward behaviour that promotes positive non-financial outcomes for the Firm.

Under MIFIDPRU 8.6.8R(2), the Firm must disclose the total amount of remuneration awarded to all staff, split into:

• fixed remuneration; and
• variable remuneration.

Below is for period ended 31st December 2023