MIFIDPRU 8 Disclosure

Inverewe Capital London Limited (“ICLL”) was incorporated in England and Wales as a limited company on 19 February 2014 under company number 08902964 and is authorised and regulated by the Financial Conduct Authority (“FCA”). ICLL acts as investment manager which includes Inverewe Credit Opportunities Master Fund ICAV and Inverewe Credit Opportunities Fund ICAV (the “ICAVs”), that are both regulated by the Central Bank of Ireland.

ICLL is an owner-managed business with a simple remuneration policy which aims to align the risk and rewards faced by clients with the risks and rewards faced by staff. ICLL senior management is mindful of the need to pay competitively in order to attract appropriately talented and skilled individuals to the firm, but is also concerned to ensure that remuneration decisions do not compromise the long term financial stability of ICLL. As a small firm, ICLL does not have a separate Remuneration Committee as this would be disproportionate – the ICLL Board determines staff and senior management remuneration on an annual basis, receiving feedback from risk and compliance functions about individual performance. Where performance includes inappropriate behaviours, discretionary awards may be scaled back or removed.

ICLL has the right to suspend or claw back discretionary awards where there is evidence that these awards have been achieved through inappropriate behaviours. As a small firm, ICLL bonuses, when paid, have been paid in cash only with no deferral. This arrangement may change as the firm grows and develops.

Consequently, Remuneration Code staff at the firm (as defined by the Rules of the Financial Conduct Authority) receive a fixed salary and may receive variable remuneration based on the profitability of ICLL and not necessarily based on individual investment performance targets. Persons holding “control functions” such as Risk and Compliance may have variable remuneration primarily based upon the achievement of risk and compliance objectives that may not be linked to the profitability of ICLL.

Other staff not in the above categories should receive a fixed salary and may also receive a discretionary bonus based upon a combination of individual performance and profitability of ICLL.

ICLL does not provide guaranteed variable remuneration for any staff unless in the first year of employment to compensate for an end of year bonus at a previous employer that was forfeit by moving to ICLL. ICLL does not provide any other form of guaranteed variable remuneration.