MIFIDPRU Public Disclosure Document
Financial period from 1 October 2023 to 31 March 2025
Katamaran Capital LLP “Katamaran” or “the Firm”) is regulated by the Financial Conduct Authority (“FCA”) as a CPMI Firm with MiFID top-up permissions and is subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook. The Firm is a UK domiciled discretionary investment manager. The provision of these services is documented in the Investment Management Agreement (“IMA”) with the Funds as the Firm’s clients. The Firm conducts agency business and does not operate a trading book or hold client money or assets.
The Firm is classified as a Small and Non-Interconnected (“SNI”) Investment Firm under MIFIDPRU 1.2. Accordingly, these disclosures have been prepared as per the requirements contained within MIFIDPRU 8.6. This Public Disclosure Document has been prepared based on the audited financials as at 31 March 2025.
In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities.
Application of the Requirements
This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model.
Remuneration Policies and Procedures
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”). Katamaran as an alternative investment fund manager, is also classified as a collective portfolio management investment firm, and as such, is also subject to the AIFM Remuneration Code (SYSC 19B).
This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.
Qualitative characteristics of the Firm’s Remuneration Policy and Practices
The Firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote effective risk management and do not encourage excessive risk taking.
The Firm ensures that the remuneration policy and its practical application are consistent with the Firm’s business strategy, objectives and long-term interests.
Given the nature and small size of our business, remuneration for all personnel is set by the Executive Committee of the Firm. The Firm formally reviews the performance of all Partners and employees and based thereon determines for each the overall level of remuneration and the split of that between base salary, bonus and any discretionary additions in compliance with the FCA Rules on remuneration.
Variable remuneration is intended to reflect contribution to the Firm’s overall success. Staff are assessed throughout the year and rated based on Firm and individual performance. The performance assessment considers both financial measures (such as earnings and profit margin) and non-financial measures such as productivity/efficiency and quality, risk management, people and culture, customer focus and growth and innovation.
The Firm’s policy is designed to ensure that it complies with the Remuneration Code and its compensation arrangements:
• Are consistent with and promote effective risk management in the long-term interests of the Firm and its clients
• Ensure alignment between risk and individual reward and not to encourage excess risk taking
• Support positive behaviours and healthy firm cultures whilst ensuring the attraction and retention of staff members
• Discourage behaviours that can lead to misconduct, conflict of interest ensuring client interests are not negatively impacted
• Are on gender neutral basis
Remuneration at Katamaran is made up of fixed and variable components. All members of staff are paid a fixed salary commensurate with their role, experience and qualifications. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff and is benchmarked against industry standards.
Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance as well as the financial and non-financial performance of the individual in contributing to the Firm’s success. The size of the bonus pool is entirely at the discretion of the Chief Investment Officer and Executive Committee and is determined by profits. If there are no profits, then there will be no bonus pool. The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.
All staff members are eligible to receive variable remuneration. Given that the Firm has only one business area, investment management, all remuneration disclosed in our audited financial statements is from this business area.
The key financial performance measures used to determine the total variable pay-out is the Firm’s net profit/loss after all expenses have been paid and this will be supplemented by an assessment of other key performance measures and identified risks outlined within the Firm’s Internal Capital Adequacy Risk Assessment (“ICARA”).
Quantitative characteristics of Remuneration With respect to the period from 1 October 2023 to 31 March 2025, the total amount of remuneration awarded to all staff, as interpreted under SYSC 19G.1.24G, split into fixed and variable remuneration, was as follows:
| Fixed remuneration | Variable remuneration | Total remuneration | |
| All Staff | £963,725 | £105,710 | £1,069,435 |