MIFIDPRU 8 Disclosure

1 Overview
This document has been prepared in accordance with the disclosure requirements set out in Chapter 8 of the Financial Services Authority (“FCA”) Sourcebook for MiFID Investment Firms (“MIFIDPRU 8”), as defined in the UK Investment Firms Prudential Regulation (“IFPR”) legislation.

Under the MIFIDPRU regulation, Absolute Return Investment Advisors Limited (herein the “Firm”) is categorised as a “SNI” (Small and Non-interconnected) investment firm.

1.1 Scope
The purpose of the Disclosure within this document is to provide sufficient information to enable market participants and / or clients to assess the potential risks within the Firm.. Where appropriate, this document reflects the information which is contained within the Annual Report & Financial Statements of the Firm.

2 Frequency of the Disclosure
After due consideration of the nature, size and complexity of the business activities and services of the Firm, the Directors have concluded that this disclosure document will be formally updated on an annual basis to take into consideration the financial results stated in the audited financial statements.

3 Disclosures
As required under MIFIDPRU sourcebook 8.3 rule - “Governance Arrangements”, being classified as “SNI”, the Firm can apply the proportionality rules relating to the Prudential disclosures.

Hence, the Firm does not have to disclose the following:
- MIFIDPRU 8.2 rule- “Risk management objectives and policies”
- MIFIDPRU 8.3 rule- “Governance arrangements”
- MIFIDPRU 8.4 rule- “Own funds”
- MIFIDPRU 8.5 rule- “Own funds requirements”

However, the Firm must comply with MIFIDPRU 8.6 rule- “Remuneration policy and practices”

4 Remuneration Policy and Practices
4.1 Qualitative Disclosure
In accordance with MIFIDPRU rule 8.6.2- “Qualitative Disclosures” the Firm discloses the following:
- The Remuneration policy and practices are reviewed annually to ensure they are appropriate and proportionate to the nature, scale, and complexity of the risks inherent in the business activities of the Firm.
- The Board of Directors are responsible for the overall Remuneration policy.
- The Firm ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all staff.

The Firm has a Remuneration Policy which is approved by the Board of Directors on an annual basis and the decisions for setting remuneration are based on:
- Risk management;
- Supporting business strategies and objectives;
- Avoiding conflicts of interest with clients.

The Remuneration policy states:
- Fixed remuneration is based on the staff professional experiences, skills, qualifications and seniority within the Firm. The Fixed remuneration includes fixed salary, employer pension contribution, medical cover and holiday pay.
- Variable remuneration (also known as Discretionary bonus) is based on a combination of staff performance based on an annual appraisal reviews and the profit or loss of the Firm.

4.2 Quantitative Information
As the Firm has the category of SNI, in accordance with MIFIDPRU 8.6.8- “Quantitative disclosures”, the Firm is required to disclose the total amount of remuneration awarded to all staff and split into fixed and variable remuneration.

The total remuneration for the financial year 01/04/2023 to 31/03/2024 was: