Public Disclosure
Objectives
This document sets out the public disclosure under MIFIDPRU 8 for the Firm as of December 2022, 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.
to approval and publication.

Remuneration disclosure
As a MIFIDPRU investment firm, we must establish, implement and maintain gender neutral remuneration policies and practices that are appropriate
and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the Firm. Our remuneration policy
and practices are gender neutral and do not discriminate employees on the basis of gender or other characteristics.
The Firm has adopted a Remuneration Policy that complies with the requirements of Chapter 19G of the FCA’s Senior Management Arrangements,
Systems and Controls Sourcebook.

Performance period
The Firm’s performance period is from January 2022 to December 2022.

Approach to remuneration for employees
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 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 indelivering its long-term strategy.
Our remuneration structure includes provisions that in specific circumstances, allow the Firm to:•forfeit or withhold all or part of a bonus or long-term incentive award before it has vested and been awarded (‘performance adjustment’ or ‘malus’);
and/or•recover sums already paid (‘clawback’).

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.

Financial incentives objectives
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 thebusiness 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 therelevant FCA’s Remuneration Code.

The Firm uses the following financial incentives:•

bonuses;•referral programmes;•

extra allowances;•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.

Governance
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 Governing Body. The Governing
Body of the Firm is the parent Firm’s Senior Management and Executive Committee. The Governing Body is responsible for approving and maintaining
this Policy and overseeing the implementation of this Policy which will align the Firm’s remuneration practices with its risk tolerance.
The parent Firm’s Senior Management and Executive Committee is responsible for reviewing and approving remuneration, and to ensure remuneration
policies across the Firm are consistent with the promotion of effective risk management.

Components of remuneration
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; andVariable 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; andinclude how far the individual adheres to effective risk management and complies with relevant regulatory requirements.

Financial and non-financial performance criteria
The Firm must take 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.
The Firm uses the following financial performance criteria:•

Meeting Service line revenue targets.

The Firm uses the following non-financial performance criteria:
•
•
•
•
•

measures relating to building and maintaining positive customer relationships and outcomes, such as positive customer feedback;performance in line with firm strategy or values, for example by displaying leadership, teamwork or creativity;
adherence to the firm’s risk management and compliance policies;
achieving targets relating to environmental, social and governance factors; anddiversity and inclusion.

KSL does not separate financial and non-financial performance criteria between the firm, business units and individuals.

Awarded remuneration
The Firm has awarded the below amounts of remuneration to its senior management, MRTs and other staff
Table [1]Staff category
Senior management

Other MRTs

Remuneration type
Fixed remuneration
Variable remuneration
Total amount
Fixed remuneration
Variable remuneration£
2680900
3540690622159000Other staff

Total amount
Fixed remuneration
Variable remuneration
Total amount01675300
3406102015910

Table [2]Staff category
Seniormanagement

Other MRTs

Remuneration type
Guaranteed variable remuneration
Severance payments
Highest severance awarded to an individual
member of senior management
Guaranteed variable remuneration
Severance payments
Highest severance awarded to an individual
MRT£,’00000Total recipients
0
0

0
0
0

0
0

Material risk takers
The Firm has identified MRTs in accordance with SYSC 19G.5 and the qualitative criteria set out in SYSC
19G.5.3R, 19G.5.4RG and SYSC 19G.5.5G. In addition, as part of this Disclosure Policy, the Firm also draws fromthe Remuneration Policy which requires us to identify our MRTs on an annual basis.
For the performance year 2022, the Firm identified 9 MRTs, broken down as follows:
MRT Type
The staff member is a member of the senior management

Number3

The staff member is a member who has managerial responsibility for business units
that are carrying on at least one of the following activities:• arranging (bringing about) deals in investments;•

4

The staff member is a member who has managerial responsibilities for the preventionof money laundering and terrorist financing
The staff member has authority to take decision approving or vetoing the introductionof new products

1
1

Risk adjustment
KSL takes risk, including conduct risk, into account both on an ex-ante and ex-post basis when setting the amountand form of variable remuneration for employees. Different lines of business have different risk profiles and these
are taken into account when determining (future) remuneration. These include market, liquidity, operational,
reputational, legal, compliance and conduct risks. Guidelines are provided to assist compensation managers when
applying discretion during the remuneration process to promote consistent consideration of the different riskspresented by the firm’s businesses. Further, to ensure the independence of control function employees,
remuneration for those employees is not determined by individuals in revenue-producing positions but rather by the
management of the relevant control function.
The Firm has implemented a set of procedures which ensures that all variable remuneration payable is subject to(i) in-year adjustments (all staff); (ii) malus, if appropriate (applicable to MRTs); (iii) and/or clawback (applicable to
MRTs). To ensure effective risk adjustment, the Firm requires employees who receive variable remuneration
awards to agree to forfeiture and clawback in the event of fraud, misconduct or actions contributing to the detrimentof business interests. Ex-ante risk adjustment of variable remuneration can occur through the considerable
reduction in total variable performance where subdued or negative financial performance of the Firm occurs, taking
into consideration the Firm’s regulatory capital, liquidity requirements and the current and future risks it has
identified. Furthermore, an individual’s variable remuneration may be reduced, or if malus or clawback is available,utilised, where employment issues have been identified as part of the ongoing performance review process in placeat the Firm.
Performance adjustment events may occur as a result of a deliberate or malicious act, error, accident or
negligence. There may also be grounds for a performance adjustment due to an individual’s failure to act either toprevent a risk event or where timely action would have mitigated the effects of a risk event. Performanceadjustment seeks to take account of matters that were not apparent at the time of the original variable award.
Adjustments or application of malus or clawback will depend upon the severity of the event and will be subject toparental firm senior management and executive committee approval.

Policies and criteria for awarding
remuneration and severance payments

guaranteed

variable

The Firm does not award guaranteed variable remuneration and therefore there are no policies and criteria withrespect to this.
The Firm follows all local statutory severance requirements. Severance payments made will not be disproportionate
but will appropriately compensate the employee in cases of early termination of the contract. Severance payments
do not reward failure and will not be awarded where there is a failure in risk management or conduct.

Risk management objectives and policies
Own funds requirements – MIFIDPRU 4
When assessing the adequacy of the Own Funds Requirement, the Firm has considered the key risks to the Firm’s
operating model. Due to our prudential classification as a Non-SNI, the Firm’s own funds requirement is based on
the higher of the Permanent Minimum Requirement (‘PMR’), the Fixed Overheads Requirement (‘FOR’) or the KFactor Requirement (‘KFR’). The Firm’s FOR as at the Firm’s year-end 31 December 2022 is £158,456

Concentration risk- MIFIDPRU 5
The Firm does not conduct trading on own account and does not have regulatory permissions for dealing as principal.
The Firm therefore does not have any concentration risks on or off-balance sheet and does not operate a tradingbook.]

Liquidity risk - MIFIDPRU 6
The Firm maintains minimum liquidity at all times in compliance with the Basic Liquid Asset Requirement, being atleast 1/3rd of its FOR.
The Firm does not provide any client guarantees and therefore its entire liquidity requirement is driven by its
expenses, as captured by the FOR.
As part of the Internal Capital Adequacy and Risk Assessment (‘ICARA’), the Firm also maintains liquidity to satisfy
its net wind-down costs and any additional liquidity requirements which the ICARA identified for supporting theongoing business activities of the Firm.

Harms associated with business strategy
The Firm has conducted a comprehensive risk identification exercise of potential harms in line with MIFIDPRU 7
Annex 1 across all business lines to ensure that all significant risks are identified. The Firm has developed acomprehensive Risk Register containing all relevant details for each risk that has been identified. All business areasof the Firm have input into the development of the risk register to ensure all areas of potential harm are identified. All
risks recorded in the register are categorised in terms of potential harms to clients, the firm itself or markets. Credit,
Market, Operational, Business and Liquidity are categories of risk mapped to potential harms.

Credit Risk
The Firm’s exposure to credit risk is the risk that the Firm will suffer financial loss should any of the Firm’s clients orcounterparties fail to fulfil their contractual obligations.
Examples of this are as follows:•••that a counterparty to a trade fails;
that a client fails to settle an outstanding purchase on settlement day;that a client fails to pay an invoice for fees; and•a Bank, where the Firm deposits funds, fails to meet its obligations.

Credit risk management techniques currently include the following processes designed to minimise the level of credit
risk:
•
•
•
•

monitoring of large trades;
monitoring of the level of credit risk on a daily basis;
procedures for the granting, and on-going monitoring, of credit limits;
ensuring corporate clients pay fees.

Our appetite for credit risk is low. Credit risk can be a harm to clients, the firm itself or markets.

Market Risk
The Firm does not have a trading book and the Firm’s only exposure to market risk will be in its non-trading book in
respect of foreign currency exposures.
The majority of our principal trading is limited as riskless principal – where trades will only be executed on the Firm’s
trading book where there is a buyer / seller already in place. Occasionally some of these trades may be warehoused.]
Our appetite for market risk is low. Market risk can be a harm to clients, the firm itself or markets.

Operational Risk
The Firm has undertaken a robust risk identification and scoring exercise across the Firm. This Risk Appetitestatement translates into the acceptance of risks that fall within our calibrated Operational Risk Appetite. Any risk
rated above our Operational Risk Appetite is deemed to be unacceptable to the Firm and will be addressed as apriority to ensure that it is, through mitigation, able to fall within our Operational Risk Appetite or that additional Capitalis assigned.
This position has been communicated to all members of staff and is to be reinforced on an annual basis.
Senior Management has determined that any risk emerging and/or rated as above our Operational Risk Appetite
must have a plan for treatment developed within ten working days of identification and implemented within thirty days.
Operational risk can be a harm to clients, the firm itself or market].

Business Risk
We have assessed our business risks and set out appropriate actions to manage them.
Our appetite for business risk is low. Business risk can be a harm to clients, the firm itself or markets.

Liquidity Risk
The Firm seeks to ensure that it has constant access to an appropriate level of cash, liquid securities and committed
funding lines to enable it to finance its on-going operations and reasonable unexpected events on cost-effective
terms. Liquidity risk can be a harm to clients, the firm itself or markets.

Governance arrangements disclosure
Governance Framework
The Board is the Governing Body of the Firm (‘the Board’). It meets regularly and is composed of:
•
•
•
•
•

Julie Pearce
Bob Bartell
Patrick Puzzuoli
Andreas Stoecklin
Ian Manson (left 30th June 2023)

The role of the Board is to provide oversight and take responsibility for the strategic leadership of the Firm within aframework of good corporate governance and prudent and effective controls which enables risk to be assessed andmanaged, including appropriate segregation of duties of the Senior Management Functions in accordance with the
Senior Management and Certification Regime (‘SM&CR’) and management of conflicts of interest. The Board sets
the structure in place for the Firm to meet its objectives and reviews management performance. The Board sets andoversees the Firm’s values and standards and ensures that its obligations to its shareholders, its clients and others
are understood.
A review of the performance of the Board takes place annually and all staff are reviewed annually in respect ofcompetence and fitness and propriety. This review process feeds into the individuals’ remuneration which in turn isgoverned by the Firm’s remuneration policy.
The Board of Directors of the Firm has the daily management and oversight responsibility for the business supported
by other key members of the senior management team within the Firm.
The Firms seeks regulatory approval prior to appointments to the Board under the SMCR. All Board members areregistered and listed on the FCA Register.
Responsibilities are allocated to Senior Managers under the SM&CR regime, and these are reviewed annually toensure consistency with the business of the Firm including responsibility for client assets. As detailed in the Statementof Responsibilities for each Senior Manager.

Overview of the Board Committees
All members of the Board are INEDs and member of the Board of KSL. The purpose of the Committees with theirrespective scopes of duties and responsibilities are formalised in the Committee’s Terms of References.
Risk Committee
The Firm has not formed a Risk [& Compliance] Committee due to its size.
Remuneration Committee
A separate Remuneration Committee has not been formed due the size of the Firm.

Nominations Committee
A separate Nominations Committee has not been formed due the size of the Firm.

Audit Committee
The Firm has not formed an Audit Committee due to its size.

Directorships
The following information relates to the appointments of KSL Directors held in both executive and/or non-executivefunctions, including any external Directorships/Partnership within Kroll held as at 31 December 2022.
SMF Function/Role
SMF3
SMF3
SMF3
SMF3
SMF3, SMF16, SMF17

Name
Bob Bartell
Ian Manson
Patrick Puzzuoli
Andreas Stoecklin
Julie Pearce

External directorships
0
0
0
0
0

As a significant SYSC firm per SYSC 4.3A.6R(1)(a), KSL Board members must not hold more than one external
executive directorship with two non-executive directorships; or four non-executive directorships. To December 2022
the Firm complies with this requirement. Therefore, the Firm did not apply to the FCA for a modification or waiver forthe application of this requirement.

Diversity
The Firm values the innovation and creativity that diversity of thought brings to the organisation and understands thatdiversity, equality and inclusion play a critical role in establishing strong governance and maintaining a healthy culture
from the top as part of delivering higher standards of conduct and success of the Firm. The Firm is committed tobuilding a workforce that reflects all aspects of diversity and intersectionality to bring a range of perspectives, ideas
and insights to everything the Firm does.
One of the company’s objectives is to ensure that the composition of the Board is always suitable for it to be aneffective decision-making body and to provide successful oversight and stewardship. Suitability of members of theBoard is reassessed periodically, in line with the requirements of the SM&CR. The Directors are appointed inaccordance with the following suitability criteria:•

Being of good repute;•

Being able to act with honesty, integrity and independence of mind;•

Overseeing, monitoring and challenging management decision-making effectively;•

Disclosing any financial or non-financial interests that could create potential conflicts of interest;•

Possessing sufficient knowledge, skills and experience to perform their duties;•

Being able to commit sufficient time to perform management body functions in a supervisory context;•Not being restricted from taking up the position by any regulatory requirement.

The assessment of an individual’s adequate knowledge, skills and experience will consider:•

The role and duties of the position and the required capabilities;•

The knowledge and skills attained through education, training and practice;•

The practical and professional experience gained in previous positions;•

The knowledge and skills acquired and demonstrated by the professional conduct of the member of theBoard.

Own funds disclosure
Composition of Regulatory Own Funds
The Firm’s own funds consist of CET1 capital. As at the Firm’s financial year end on 31 December 2022, the Firm
complied with all capital requirements.
Composition of regulatory own funds
Item

1
2
3
4
5
6
7
8
9
10
11

19

20
21
22
23
24

25

OWN FUNDSTIER 1 CAPITALCOMMON EQUITY TIER 1
CAPITAL
Fully paid-up capital
instruments
Share premium
Retained earnings
Accumulated othercomprehensive income
Other reserves
Adjustments to CET1 due toprudential filters
Other funds(-)TOTAL DEDUCTIONSFROM COMMON EQUITYTIER 1
CET1: Other capitalelements, deductions andadjustments
ADDITIONAL TIER 1
CAPITAL
Fully paid up, directly issued
capital instruments
Share premium(-) TOTAL DEDUCTIONSFROM ADDITIONAL TIER 1
Additional Tier 1: Other
capital elements, deductions
and adjustments
TIER 2 CAPITAL

Amount (GBP
thousands)

Source based onreference
numbers/letters of thebalance sheet in theaudited financial
statements

1,494,549

Capital and reserves

12,753,485

Capital and reserves

1,953,952

Capital and reserves

26
27
28
29

Fully paid up, directly issued
capital instruments
Share premium(-) TOTAL DEDUCTIONSFROM TIER 2Tier 2: Other capitalelements, deductions andadjustments

Reconciliation of regulatory own funds to balance sheet in theaudited financial statements
The table below describes the reconciliation with own funds in the balance sheet as at 31 December, where assets
and liabilities have been identified by their respective classes. The information in the table below reflects thebalance sheet in the audited financial statements.

Own funds: reconciliation of regulatory own funds to balance sheet in the audited financial statements[Flexible template - rows to be reported in line with the balance sheet included in the audited financial statementsof the investment firm. Columns should be kept fixed, unless the investment firm has the same accounting andregulatory scope of consolidation, in which case the volumes should be entered in column (a) only. Figures
should be given in GBP thousands unless noted otherwise.]abC
Balance sheet as
Under regulatory
Crossinscope ofreference topublished/audited
consolidation
template OF1
financialstatements
As at period end
As at period end
Assets – Breakdown by asset classes according to the balance sheet in the audited financial statements
12
3
4

Fixed assets
8
Cash
294
Trade debtors
1,196
Amount owed by group
20,134
undertakings
5
Tax
188
Prepayments and46
accrued income
Total Assets
21,866
Liabilities – Breakdown by liability classes according to the balance sheet in the audited financial statements
12
34

Trade creditors
Amounts owed to group
undertakings
Tax
Other creditors

8
724
2,327
2,463

5

Accruals and deferredincomeTotal Liabilities
Shareholders’ Equity

142

1
2
3
4

1,495
344
1,610
12,753
16,202

Called up share capital
ESOP reserve
Capital contribution
Retained earnings
Total Shareholders’Equity5,664

Main features of own instruments issued by the Firm
The table below provides information on the CET1 instruments issued by the Firm.
Own funds: main features of own instruments issued by the Firm (template OF1)

Called up share capital is alloted, issued and fully paid. There is a single class of ordinary share.
There are no restrictions on the distributions of dividends and the repayment of capital.
Retained earnings represents the historical profits earned by the Firm up to 31 December 2022.
Capital contribution is a reserve that comprised of capital contributed by a related party.
ESOP reserve comprises the value of equity settled share based payments awarded to certain
employees that are granted and settled by the Firm’s parent entity.

Own funds requirements disclosure
Own funds requirement
The Firm is required to disclose the K-factor requirement (‘KFR’) and the fixed overheads requirement (‘FOR’)amounts in relation to its compliance with the own funds requirements set out in MIFIDPRU 4.3, based on theaudited financial statements for the year ended 31 December 2022.
K-factor

Sum of K-AUM, K-CMH and K-ASA
Sum of K-COH and K-DTF
SUM of K-NPR, K-CMG and K-CON
Total KFR

FOR£,’00032,9930032,993
158,456

Compliance with Overall Financial Adequacy Rule
In line with the provisions relating to the Overall Financial Adequacy Rule (‘OFAR’) set out in MIFIDPRU 7.4.7R, KSL
is also required to disclose its approach to assessing the adequacy of the Firm’s own funds.
ICARA process
Within the annual ICARA process, the Firm is required to identify and assess the following:•••

any material/key risks that arise from its activities;
any material harms that may be caused to the clients, the market or the Firm itself as a result of its activities;
andwhether, at all times, the Firm has sufficient own funds and liquid resources to meet the Overall Financial
OFAR.

The OFAR requires that the Firm holds own funds and liquid assets which are adequate (both in amount and quality)
to ensure that:•

the Firm can remain financially viable throughout the economic cycle and be able to address any material
potential harm; and•the Firm’s business can be wound down in an orderly manner with minimal impact on consumers and othermarket participants

The process of embedding the ICARA process within the Firm has been completed and the adequacy of the ICARA
process will be reviewed on an annual basis thereafter, or more frequently, should there be any material change tothe business risk profile or business model.
The ICARA process encompasses various aspects of internal governance with a particular focus on:•

identification, monitoring and mitigation of harms;•

business model planning and forecasting;•recovery and wind-down planning; and•

assessing the adequacy of financial resources; and•assessing the overall effectiveness of the risk management of the Firm.

As part of the ICARA process, the Firm establishes its own funds threshold requirement and its liquid assets thresholdrequirement to comply with the OFAR and to ensure the Firm can remain viable, addressing any potential harm fromongoing activities, and can wind-down in an orderly way. For harms not adequately mitigated through existing
systems and controls, the Firm assesses whether additional own funds and/or liquid assets are required.
The recovery action planning contains appropriate recovery actions to restore own funds and/or liquid resources toavoid breaching threshold requirements and early-warning-indicators (‘EWIs’) to assist the Firm when approaching
trigger levels and set out credible actions to help reverse or repair any adverse trends.
The wind-down planning includes triggers (own funds and liquid assets) and timelines. The Firm considers different
scenarios that could cause a need to wind-down the business. These underlying drivers could result in the need for
different resources (financial and non-financial) during the wind-down period. The Firms sets resources aside so thatsufficient own funds and liquid assets are available at all times to enable an orderly wind-down.
Risk management
The Firm maintains a documented Risk Register that is established based upon the Firm’s business plan andapproved by the Board. It also includes a description of the controls put in place to mitigate the risk.
The Board defines the Firm’s risk appetite, which reflects KSLs appetite and/or tolerance in relation to all identified
material risks. The Firm’s overall risk appetite must be such that its own fund and liquidity requirements as captured
in the ICARA process are maintained within its risk bearing capacity or capital resources. All material risks identified
in the Risk Register are assessed to determine appropriate own funds and liquidity reserves. Regular stress testingand scenario analysis is undertaken to ensure these reserves are sufficient to meet current and future obligations
under a variety of stressed conditions.
Own funds adequacy
KSL assesses the adequacy of its own funds on a regular basis against a variety of own funds requirement
assessments. In maintaining the Firm’s own funds requirements within the risk appetite, EWIs have been established.
These are agreed as part of the annual own funds planning process and reviewed annually.
Levels of own funds usage against limit are monitored monthly.
Liquid assets adequacy
The Firm has an established liquidity risk management framework based on the Firm’s approved liquidity risk appetite
in order to ensure that:•the basic liquid asset requirement (‘BLAR’) is met; and•the liquid assets threshold requirement is determined.

The Firm further assesses its compliance with liquid asset threshold requirement which is based on the sum of BLAR
and an additional liquid asset requirement determined during the ICARA process, to ensure liquidity adequacy instressed conditions and during an orderly wind-down as part of its OFAR compliance from a liquidity perspective.
Liquidity risks are identified through ongoing liquidity management and monitoring, which contribute to thedevelopment of the Firm’s liquidity risk management framework and formulating stress testing scenario design and
key assumptions.
The Firm’s monitoring and reporting of its liquidity position is undertaken through established reporting against the
key liquidity metrics. Any triggers or breaches would be escalated in line with the escalation framework.