Atrato Partners Limited – MIFIDPRU 8 Disclosure

1. INTRODUCTION

Atrato Partners Limited (“Atrato” or the “Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”) and is classified as a Small and Non-Interconnected (“SNI”) MIFIDPRU investment firm under MIFIDPRU 1.2.

In accordance with Chapter 8 of the Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU 8”), Atrato is required to publicly disclose information on its remuneration policy and practices. This disclosure has been prepared in line with MIFIDPRU 8.6 and SYSC 19G of the FCA Handbook.

This disclosure was approved by the senior management on 30 September 2025 and is published annually alongside the Firm’s financial statements. Unless otherwise stated, all figures are as at the Firm’s 30 December 2025 financial year-end. It is freely available on the Firm’s website at https://atratogroup.com/.

2. REMUNERATION POLICY AND PRACTICES

2.1 Remuneration Code and Objectives

The Firm’s remuneration policy is designed to ensure it aligns with the FCA’s Remuneration Code (“RemCode”) and that the Firm’s compensation arrangements:

• Promote sound and effective risk management.
• Do not encourage excessive risk-taking.
• Include measures to avoid conflicts of interest.
• Are consistent with the Firm’s business strategy, objectives, values, and long-term interests; and
• Are applied on a gender-neutral basis.

The Firm recognises that remuneration is a key component in attracting, motivating, and retaining high-quality staff and sustaining strong performance. The policy supports a culture of ethical behaviour, teamwork, and client-centric outcomes.

2.2 Governance and Oversight

As an SNI firm, Atrato is not required to establish a standalone Remuneration Committee. However, remuneration oversight is provided by the Atrato Group Limited senior management, which covers all entities within the group, including Atrato Partners Limited and Atrato Capital Limited.

• Investment professionals are assessed through a structured appraisal process led by evaluators, partners, HR, and the senior management.
• Non-investment professionals are overseen by a separate committee.
• Performance criteria include investment generation, investor engagement, firm contribution, and portfolio company interaction.

2.3 Characteristics of Remuneration

Remuneration consists of fixed and variable components:

• Fixed remuneration includes salary, benefits in kind, pension contributions, and guaranteed drawings. It is based on professional experience, responsibility, and market benchmarks.
• Variable remuneration includes:
  • Bonuses: Discretionary, based on firm and individual performance. There is no formal cap, and awards may vary depending on role, contribution, and overall results.
  • Carried Interest: Linked to fund performance hurdles and paid overtime to align long-term interests and retain key staff.

Bonuses are not guaranteed and may be zero in any given year. The Firm does not currently operate malus or clawback arrangements, in line with the proportionality principle under SYSC 19G. However, the Firm reserves the right to review this position in the future in response to regulatory developments or changes in business risk. Severance pay may be awarded on a case-by-case basis.

The Firm’s ability to pay variable remuneration is subject to its overall financial performance, capital and liquidity position, and the achievement of fund-specific performance hurdles.

3. Quantitative Remuneration Disclosure

With respect to the financial year ended 31 December 2024, the total amount of remuneration awarded to all staff employed by the Firm was as follows:

Note: The Firm does not have any staff whose professional activities have a material impact on the risk profile of the Firm (Material Risk Takers), as defined under MIFIDPRU.

Additional financial and governance information is available in the Firm’s annual financial statements, which can be accessed via Companies House or upon request.

4. Diversity and Inclusion

Atrato is committed to fostering a diverse and inclusive workplace. The Firm recognises that diversity of thought, background, and experience enhances decision-making and contributes to a more resilient and innovative organisation.

While Atrato is not required to publish a formal diversity policy under MIFIDPRU 8.3 as an SNI firm, the Firm voluntarily promotes the following principles:

• Recruitment and promotion processes are designed to be fair, inclusive, and free from bias.
• Remuneration decisions are made on a gender-neutral basis and are not influenced by any protected characteristics.
• The Firm encourages a culture of respect, collaboration, and equal opportunity across all levels of the organisation.

Atrato continues to monitor and review its diversity practices and aims to improve representation and inclusivity across its workforce.

5. Performance Assessment and Risk Alignment

The Firm’s approach to performance assessment is designed to ensure that remuneration outcomes are aligned with long-term value creation and effective risk management.

Key features of the performance assessment framework include:

• Balanced Scorecard: Staff performance is evaluated using a combination of financial and non-financial metrics, including client outcomes, risk management, teamwork, and contribution to firm culture.
• Risk Sensitivity: Variable remuneration is adjusted to reflect the level of risk taken and the sustainability of results. Poor risk management or conduct issues may result in reduced or zero variable pay.
• Annual Review Process: All staff undergo a structured annual performance review, which informs bonus decisions and career development planning.
• No Guaranteed Bonuses: The Firm does not offer guaranteed variable remuneration. All awards are discretionary and subject to the Firm’s financial performance and capital position.

This approach ensures that remuneration supports the Firm’s strategic objectives and regulatory obligations while fostering a culture of accountability and integrity.