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MKP Capital Europe LLP Limited FRN: 536892

IFPR REMUNERATION DISCLOSURE

Remuneration Policy Statement

From 1 January 2022, MKP Capital Europe LLP (the Firm or MKP Europe) became subject to the UK Investment Firms Prudential Regime (the IFPR). Under the IFPR, MKP Europe, as a Small Non- Interconnected (SNI) MIFIDPRU investment firm is required (among other things) to publish a summary disclosure covering its remuneration arrangements under the Financial Conduct Authority (FCA) MIFIDPRU 8.6 Rules.

The performance reference date is from 1 January 2022 to 31 December 2022 and this Remuneration Policy Statement disclosure is in respect to the performance period to 31 December 2022.

MKP Europe pays all its staff remuneration, which comprises a fixed element and can also include a variable discretionary element. All remuneration is overseen by MKP Europe's management body, its Board of Directors (the Board), in its supervisory function. It is also overseen and directed by the Remuneration Committee of its US parent entity, MKP Capital Management, L.L.C. (the "US Parent").

An employee's fixed remuneration element is based on pre-determined criteria. It is non-discretionary, transparent, permanent for the year and subject to an annual review, whereby any possible increase is assessed. The fixed remuneration reflects a staff member's professional knowledge and experience, their skills, the requirements of the particular role for which they are employed, their qualifications, and his/her organisational responsibilities as set out in the staff member's job description and terms and conditions of employment.

All staff can receive variable remuneration in the form of an annual discretionary bonus. An employee's variable element of their remuneration is also based on pre-determined criteria. The variable element aims to motivate and reward high performers who strengthen long-term client relations, generate income and increase customer value. The performance will be assessed on the basis of the fulfilment of various business targets or the attainment of certain financial and non-financial objectives. Such targets will be set by the Firm's senior management together with the Remuneration Committee of the US parent.

There are no staff members paid only variable discretionary remuneration, and fixed remuneration levels are set at levels sufficient to ensure there should be no dependency by employees on their receiving variable discretionary remuneration in order to be able to live. Variable discretionary remuneration is only paid from risk adjusted profits based upon the performance of the business as a whole, and that of the individual, and only after the Firm's liquidity and capital requirements and its risk appetite and strategy have been considered on a 12-month rolling period.

Annual reviews are in place to assess whether an individual: has achieved their goals and objectives; met the core competencies required in their particular role; and undertaken all required training (particularly regulatory training). It also includes an assessment of any future development needs. The annual reviews are in compliance with the Financial Conduct Authority (FCA) requirements and include an assessment of competence and fitness and propriety for roles that fall under the Senior Managers & Certification Regime (SMCR).

MKP Europe deems the following non-financial qualitative metrics to be relevant to its strategic objectives and therefore includes them in the annual review criteria for individuals:

  • Meeting the Company's regulatory obligations (such as treating clients fairly; no upheld

complaints; compliance with any stipulations set by the Compliance Officer, etc);

  • Observing and adhering to the firm's risk management and compliance policies, and systems and controls that are in place;

  • Observing and adhering to the compliance and governance procedures that are in place;

  • Not having been subject to any disciplinary action or breached any of the Financial Conduct Authorities (FCA) conduct rules;

  • Measures relating to building and maintaining positive external relationships with vendors, brokers and investors;

  • Performance in line with the Firm's strategy and values, and represents a good role model, ensuring no risks are taken and no compliance requirements ignored;

  • Prompt and transparent response on regulatory compliance attestations;

  • Prompt completion of any training administered to the individual; and

  • Good teamwork and culture, supporting each other, and working together.

MKP Europe does not discriminate against anyone on the grounds of any of the following characteristics (without limitation) age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion/belief, sex (gender) and sexual orientation.

The Firm's compliance consultants provide comments and input at least on annual basis into its Remuneration Policy arrangements to ensure it is balanced and proportionate to nature, scale and complexity of the risks inherent in MKP Europe's business model and regulatory activities; does not lead to any undue risk taking by any employees; and is compliant with FCA relevant requirements.

The composition and breakdown of MKP Europe's remuneration for the financial year ended 31 December 2022 is:

Composition and breakdown of remuneration

Business AreaTotal remuneration
All staff£2,631,728
Fixed Remuneration£1,214,022
Variable Remuneration£1,417,706

MKP Capital Europe LLP's commitment to the UKStewardship Code Shareholder Rights Directive II

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, MKP Capital Europe LLP (the "Firm") is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy. Directive (EU) 2017/828 as implemented by the Shareholder Rights Directive (Asset Managers and Insurers)

Instrument 2019 ("SRD II") came into force in the United Kingdom on 10 June 2019. The Code and SRD II are voluntary and set out a number of principles relating to engagement by investors with UK equity issuers as well as shareholder rights. Investors that commit to the Code and SRD II can either comply or choose not to comply with aspects of each, in which case they are required to explain their non compliance. We have detailed below the reasons why the firm has chosen not to commit to the Code and SRD II.

The Firm pursues a top-down fundamental approach to identify and exploit imbalances in global economies and asset classes. The Firm generally invests in a diversified portfolio, including, but not limited to, global interest rate products, credit instruments, currencies, commodities, equities (including UK equities) and their associated derivatives. The Code and SRD II are therefore relevant to some aspects of the Firm's trading. While the Firm generally supports the objectives that underlie the Code and SRD II, the Firm has chosen not to commit.

The Firm invests in a variety of asset classes and in a variety of jurisdictions globally. The approach of the Firm in relation to engagement with issuers and their management is determined globally, on a group-wide basis. The Firm (together with MKP Capital Management, L.L.C.) takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice or voluntary directive relating to any individual jurisdiction.

For further information on the Firm's approach contact: Derek Backofen at [email protected].