MiFIDPRU 8 Disclosure for year ending 2025
Disclosure Policy
Horizon Asset LLP ("Horizon Asset LLP" or the "Firm"), part of Horizon Asset, is authorised and regulated by the Financial Conduct Authority (the "FCA"). It is a full scope Alternative Investment Fund Manager (AIFM) and is categorised by the FCA, for prudential purposes, as a Collective Portfolio Management Investment ("CPMI") firm that is a small and non-interconnected ("SNI") MIFIDPRU Investment firm.
This disclosure is made in order to fulfil the regulatory disclosure requirements as described in the FCA Prudential Sourcebook for MiFID Investment Firms ("MIFIDPRU") Chapter 8 as applicable to an SNI MIFIDPRU firm.
The Firm does not have in issue additional tier 1 instruments and so is not required to disclose information pertaining to risk management objectives and policies, own funds, or own funds requirements.
The Firm makes MIFIDPRU 8 disclosures annually. The information contained in this disclosure is accurate as at the Accounting Reference Date (ARD), December 2025 and is approved by the Governing Body (i.e., the Management Committee) of the Firm. The disclosure has not been audited by the Firm's external auditors and does not constitute any form of financial statement.
Remuneration Policy and Practices
As a CPMI SNI MIFIDPRU Investment firm, Horizon is subject to the basic requirements of the MIFIDPRU Remuneration Code and the AIFMD Remuneration Code (collectively, the "Codes"). The purpose of the Remuneration Codes is to promote effective risk management in the long-term interests of the Firm and its investors and clients, ensure alignment between risk and individual reward, support positive behaviours and healthy firm cultures, and discourage behaviours that can lead to misconduct and poor customer outcomes.
The objective of the Firm's remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its investors and clients.
The Firm's Remuneration Policy and Practices
Remuneration at Horizon is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff and is such that any variable element is not relied upon. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm's financial performance and the individual's contribution to the overall results achieved for clients and underlying investors.
The pool for variable remuneration is set each year by the Management Committee at its discretion, taking into account the Firm's profit, net revenue and fee income. Awards from the pool reflect the performance of the individual's business unit and the individual's own performance, assessed against financial criteria (contribution to investment results and to revenue) and non-financial criteria (quality of work, client service, teamwork and adherence to the Firm's policies). Individual assessments and final awards are made by the Management Committee. Variable remuneration is not deferred and is not subject to malus or clawback.
The fixed and variable components are appropriately balanced. The fixed component represents a sufficiently high proportion of total remuneration to enable the operation of a fully flexible policy on variable remuneration, including the possibility of paying no variable remuneration component.
Governance and Oversight
Following an assessment of the size, internal organisation and complexity of its activities, the Management Committee has determined that it is not required to appoint a Remuneration Committee. The Management Committee is responsible for setting and overseeing the implementation of the Firm's remuneration policy and ensures its obligations are met proportionate to the size and profile of the Firm. The Firm's remuneration policy and practices are reviewed annually.
Quantitative Remuneration Disclosure
For the financial year ended 31 December 2025, the total remuneration awarded to all staff was £228,652, of which £201,032 was fixed remuneration and £27,620 was variable remuneration.