Scott Capital Partners LLP is authorised and regulated by the Financial Conduct Authority in the United Kingdom.

If you wish to make a complaint in relation to the services we provide to you, please contact our Chief Compliance and Risk Officer, Anna O’Shaughnessy, at:

Mail: 24 St James’s Square, London, SW1Y 4JH
Email: aoshaughnessy@scottcp.com
Phone: 0204 574 2854

We handle all complaints fairly, consistently, and promptly in accordance with our complaints handling procedure which is available on request. We make every effort to resolve a complaint. However, if you are not satisfied with the response we provide or if your complaint remains unresolved 8 weeks from the date you made the complaint, it may be possible to refer it to the Financial Ombudsman Service (“FOS”). You can contact the FOS at:

Mail: The Financial Ombudsman Service: Exchange Tower, London, E14 9SR
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk
Phone: 0800 023 4567

Further information about the FOS also is available on their website.

The purpose of this document is to provide clients of Scott Capital Partners LLP with information regarding our Order Execution Policy, also referred to as our Best Execution Policy.

We are required by the Financial Conduct Authority (“FCA”), implementing MiFID II, to implement an Order Execution Policy and to make this publicly available on our website.

The Policy sets out all the sufficient steps we must take to ensure our clients receive the best possible result (“best execution”) in respect of the execution of their orders.

Best execution requirements apply to both Retail and Professional clients. An order for the purposes of the Policy is an instruction from a client to buy or sell a financial instrument or where we decide to buy or sell a financial instrument under a discretionary investment management mandate. We always act as agent; we do not trade for our own principal account.

We do not hold client assets. So, each of our clients have appointed third-party custodian bank(s) for the provision of custody services and, in most cases, execution services. In these cases, this means that we transmit orders for execution to the third-party custodian banks that our clients have appointed and operate in the client’s “best interests”; the responsibility for best execution sits with the custodian.

Where the third-party custodian banks that our clients have appointed are subject to MiFID II, they are required also to comply with best execution requirements. Each custodian bank’s execution arrangements are explained in their Order Execution Policy, where applicable, and clients should refer to the policy and the terms and conditions of the custodian bank(s) they have appointed for more information.

If a client’s custodian bank does not perform execution services for them, we transmit the order to a third-party broker, and the broker then settles the order with the client’s third-party custodian. In these cases, it is our responsibility to obtain best execution for our client. The broker that we use is Winterflood, a division of Marex Financial.

The third-party custodian bank – or broker – will either execute the orders transmitted to them themselves, or transmit them to another broker for execution.

If we take specific order execution instructions from a client, we will follow these but, in doing so, we may be prevented from achieving best execution.

We may combine or aggregate an order for our clients with orders of other clients before we transmit them. Aggregated orders may work to our clients’ disadvantage in relation to such orders.

The sufficient steps that we must take to help ensure our clients receive the best possible result in respect of the execution of their orders are:

• Preparing, implementing, and maintaining up to date an Order Execution Policy which also sets out our expectations of third-party custodian banks’ and brokers’ execution arrangements to achieve best execution.
• Reviewing each third-party custodian bank’s or third-party broker’s Order Execution Policy and arrangements, where applicable.
• Monitoring third-party brokers’ execution arrangements to achieve best execution.
• Reporting the results of this monitoring on an exceptions basis to our Management Board, or sub-committee thereof.

This supports us to assess whether we can reasonably expect that the third-party custodian bank – or broker – will achieve best execution in respect of our clients’ orders every time.

We do not receive or give inducements of any kind in relation to any party involved in the execution of our clients’ orders.

This policy is subject to an annual review, or whenever there is a material change that affects our ability to continue to take all sufficient steps to ensure our clients receive the best possible result in respect of the execution of their orders.

Scott Capital Partners and the UK Stewardship Code

This statement sets out Scott Capital Partners LLP’s (“SCP”, the “firm”, “we”, “us”) position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010, amended in September 2012 and updated in January 2020. Compliance with the Code is voluntary. We make this statement as the firm is required by the FCA to explain on its website the nature of its commitment to the Code if it manages investments for professional clients who are legal entities.

The aim of the Code is to enhance the quality and quantity of transparency, engagement and accountability between institutional investors and companies to improve long-term returns to shareholders. It is made up of a number of principles which provide a clear benchmark for good stewardship.

For us, good stewardship means our commitment to act to deliver good outcomes to our clients when we manage their investment portfolios. We support the aim of the Code, and we incorporate the Code’s principles (where they are relevant to the firm’s business) in our policies, procedures, governance arrangements and decision making.

However, the firm has chosen not to make a formal commitment to compliance with the Code at this stage. Instead, we determine our approach to stewardship on a case-by-case basis in the way which best supports the delivery of good outcomes to our clients.

Scott Capital Partners and the Shareholders Rights Directive II

To improve stewardship, the FCA also requires a firm who manages for clients investments in shares traded on a regulated market in the UK, and on ‘comparable’ markets situated outside the UK, to either (i) put in place and publicly disclose its policy for engaging as a shareholder on behalf of its clients or (ii) publicly disclose why it has chosen not to do so. These requirements originate from The Shareholders Rights Directive II (“SRD II”).

We support the aims of SRD II, however, we have chosen not to maintain and publicly disclose a shareholder engagement policy at this time. This is because we do not currently take material positions in shares to which the requirements apply.

Purpose

The purpose of this document is to disclose Scott Capital Partners LLP’s (“SCP”, the “firm”, “we”, “us”) approach to remunerating its executive members and employees in accordance with the requirements of its regulator the FCA during the financial year ended 31 March 2026.

It is not a financial statement on SCP, nor a record or opinion on any of SCP’s activities.

Firm profile and classification

SCP was incorporated as a limited liability partnership (“LLP”) on 16 June 2021 (with UK Companies House number OC437931) and was authorised as a MIFIDPRU investment firm by the FCA on 6 May 2022. It is a standalone entity and is not part of a group.

SCP is authorised and regulated by the FCA (with firm reference number 957221). The firm is classified as a Small Non-Interconnected (“SNI”) firm in accordance with the FCA’s Rules and it does not issue Additional Tier 1 equity instruments. This means the firm must comply with a subset of the FCA’s remuneration disclosure requirements.

The principal activities of the firm are the provision of Investment Management, Private Markets, and Family Office services.

The firm does not hold client assets or client money, nor does it extend credit to its clients. It holds its working capital accounts at reputable credit institutions. The firm does not take proprietary positions and does not have any significant foreign exchange exposures.

We consider the firm’s website the most appropriate way to communicate these disclosures. We will make these disclosures annually, or more frequently if there is a material change to the firm’s approach to remuneration, and/or business.

The FCA requires the firm to disclose a summary of:

• its approach to remuneration of all executive members and employees;
• the aims/objectives of these financial incentives; and
• the governance and decision-making procedures around the development of the firm’s remuneration policies and practices in accordance with the FCA’s Remuneration Code for investment firms.

Governance

SCP’s governing body is its Management Board which determines the firm’s business strategy and sets the firm’s risk appetite. The members of the Management Board are executive members of the firm.

The Management Board is ultimately responsible for the effective management of risks to which the firm is exposed. During the financial year covered by these disclosures, it was supported by three sub-committees – the Executive Committee, the Investment Committee and the Product Governance Committee – which report directly to it. The Management Board has established a risk management framework which supports the firm to manage risks within risk appetite.

In line with the FCA’s proportionality guidance, SCP’s Management Board has not established a separate Remuneration Committee. This means it is also responsible for developing the firm’s remuneration policy and practices and for reviewing them periodically, supported by the firm’s Risk and Compliance functions. The review will take place annually, or more frequently if there is a material change to the firm’s approach to remuneration and/or business.

The firm has not used external consultants to develop its remuneration policy and practices.

Risk management

The Management Board is responsible for monitoring the risk profile of the firm relative to risk appetite and for making decisions that affect the firm’s risk profile. All business activities carry an element of risk, and the Management Board is committed to fostering a culture where sound and effective management of those risks is everyone’s responsibility.

The firm’s business model, operating model, and internal systems and controls mean that the Management Board considers that SCP presents a low risk of potential material harm to our clients, the firm itself and the market. The primary risks to which the firm is exposed are set out below. The Management Board has made this determination in accordance with the firm’s Internal capital adequacy and risk assessment (“ICARA”) process.

Business and strategic risk
This is the risk associated with the fluctuating business cycles and economic conditions over time and the ability of the firm to deliver its business plan in unfavourable business and economic conditions.

Operational risk
Operational risk is the risk of loss resulting from inadequate or failed internal processes, people, or systems or from external events, either deliberately or accidentally. Conduct risk is considered within the scope of operational risk.

Conduct risk
Conduct risk is the risk that the acts or omissions of an executive member or employee of the firm causes harm to clients, the firm itself, and/or the market. This can also result in a loss of clients’ trust in the firm.

Reputational risk
Reputational risk is a second order effect that may arise if any of the other risks described above were to crystallise and damage the firm’s reputation amongst clients, investor members, and the FCA.

Approach to remuneration

The aims of the firm’s policy and practices for remuneration are to encourage individuals:

• to deliver good outcomes to clients;
• to support sound and effective risk management;
• to demonstrate responsible business conduct; and
• to further the firm’s business strategy, objectives, and long-term interests.

The firm awards equal remuneration to all individuals for equal work of equal value, avoids bias and does not discriminate based on the protected characteristics of an individual.

Executive members

Executive members may receive a monthly draw from the LLP in advance of the formal and fully discretionary allocation of profits at the end of the financial year once profits have been audited. This fully discretionary allocation of profits is subject to approval by the Management Board. There is no fixed share. These have been categorised as variable remuneration.

Fixed remuneration

For the financial year covered by these disclosures, fixed remuneration means base salary for employees and non-discretionary pension benefits.

Fixed remuneration is based on an individual’s role, for example the skills, qualifications and experience required to perform it.

The firm reviews each employee’s fixed remuneration annually based on market rates and inflation.

Variable remuneration

The aim of the firm’s variable remuneration scheme is to reward individuals who:

• act to deliver good outcomes to clients;
• demonstrate prudent risk taking;
• exemplify core values and standards of expected behaviour; and
• act in the long-term interests of the firm.

Awards of variable remuneration are based on an individual’s performance assessment and alignment with the firm’ Code of Conduct during the financial year to which the award relates. Variable remuneration is fully discretionary and can be reduced to zero.

Everyone is eligible to participate in the scheme. There are no deferred proportion or retention policies applied to variable remuneration awards.

The performance criteria used to assess whether to award an individual variable remuneration and, if so, how much, include financial and non-financial criteria, except for individuals in the firm’s support functions and control functions, e.g., its Risk and Compliance functions, where only non-financial criteria are used.

These criteria are:

Financial criteria:

• profitability of the firm; and
• individual’s contribution to the profitability of the firm.

Non-financial criteria:

• contributing to the achievement of the objectives of the firm and the function in which the individual works;
• achieving personal objectives;
• consistently delivering performance higher than that expected for the role;
• contributing to the delivery of good client outcomes;
• client retention and receiving positive feedback from clients and/or others;
• taking responsibility for compliance with the rules that apply to the firm and adhering to the firm’s compliance framework;
• taking responsibility for risk management and upholding the risk management practices of the firm;
• making decisions which are consistent with the firm’s risk appetite;
• exemplifying the firm’s core values and expected standards of behaviour;
• being inclusive; and
• prioritising the long-term interests of the firm.

The approach that the firm takes to the remuneration of those who work in the firm’s control functions is designed to support them to maintain their independence from the business and have appropriate authority.

Quantitative disclosures

The remuneration awarded by the firm in the period covered by these disclosures is:

Fixed Remuneration £233K
Variable Remuneration £2,155K

These disclosures cover the fourth financial year since the firm received authorisation from the FCA.

This website and the information on it are not intended to constitute any offer to sell, or the invitation or solicitation of an offer to buy, or a recommendation by Scott Capital Partners LLP in connection with any investment product or service, or security.

They are not intended for use by any person resident or located in any jurisdiction where (a) the distribution of such information is contrary to the laws of such jurisdictions or (b) such distribution is prohibited without obtaining the necessary licences or authorisations by the firm and such licences or authorisations have not been obtained. They are not directed at persons that are “U.S. persons” as defined in Regulation S under the U.S. Securities Act of 1933 and do not and are not intended to offer for sale or promote the offer for sale of the securities of any private fund in the United States or to a U.S. person.

There is no guarantee that any specific investment objective will be achieved. The value of investments and income from them may go down as well as up and you may not get back the amount invested.

By using this website, you confirm you understand and accept these terms of use.