REMUNERATION DISCLOSURE

(for the year ending 31^st March 2023)

 Introduction:

OPULENZE CAPITAL LIMITED (“OCL”) is subject to the FCA Rules on remuneration as they apply to a small and non-interconnected (SNI) MIFIDPRU investment firm. These are contained in the FCA’s MIFIDPRU Remuneration Code located in SYSC19G of the FCA’s Handbook.

Approach to Remuneration for all staff:

Employees have the opportunity to share in the success of the Company in years of good performance and also accept reduced levels of variable (bonus) pay in times of poor performance or losses.

OCL does not remunerate or assess the performance of its staff in a way that conflicts with its duty to act in the best interests of its clients.

OCL is mindful of ensuring that its remuneration policy and practices do not lead to a conflict of interest or incentivise its staff to act in a manner that favours their own interests or the firm’s interests to the potential detriment of any client or potential client. A balance between fixed and variable components of renumeration will always be maintained so that OCL will ensure renumeration structure does not favour the interests of the firm or its relevant persons against the interests of the firm’s clients.

Objectives of financial incentives:

OCL’s Remuneration Policy provides a framework to ensure all staff are fairly and competitively rewarded in return for a high level of service to the firm and is clients. In setting remuneration levels OCL recognises the importance of attracting and retaining experienced staff. The amount of fixed remuneration paid to an employee will be based on market rates relevant to the employee’s role and their knowledge, experience, and competencies. Discretionary bonuses are made to employees to reward them for the overall performance of the business alongside ensuring compliance adherence and attendance of required staff training.

Decision Making:

Senior management is responsible for the implementation of this policy as well as the monitoring of compliance risks associated with it. This policy will be reviewed and approved by the management body periodically to ensure it continues to remain fit for purpose.

Characteristics of Remuneration Policy and Practices:

Remuneration comprises of fixed and variable elements.

OCL has defined variable pay as a discretionary bonus, which is awarded based on company performance and individual performance and long-term incentives. The total bonus pool amount is determined by reference to both quantitative and qualitative measures.

The firm will ensure that the above will not be solely or primarily based on quantitative commercial criteria. Consequently, the firm will take into account appropriate qualitative criteria such as customer feedback, adherence with relevant regulations, fair treatment of clients, as well as meeting internally set behavioural standards. Furthermore, OCL will always ensure it maintains a balance between fixed and variable components of remuneration, so as to mitigate any conflicts of interest between the firm, its staff, and its clients.  At present, due to the size of the firm, there is no variable element and only a minimum amount allocated to the executive officer. The above principles will be implemented as the staff numbers grow.

Remuneration for year ending 31^ST March 2023: