Remuneration policy

This document sets out Two10 Investment Services remuneration disclosure for performance period 01/01/24 to 31/12/24
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Main performance objectives

The objectives of the Policy are:
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- To attract, retain and motivate talented employees of the quality required to manage the business successfully, whilst ensuring that remuneration is not excessive or detrimental to the health of the firm as a whole, including its clients.
- To motivate and reward good, long-term performance.
- To meet relevant regulatory requirements, including the requirements of the FCA Remuneration Code.

The principles of the Policy are:
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- To ensure that total remuneration is set at a level that is competitive versus peers, taking account of size, complexity and sector, whilst taking into account market practice.
- To maintain appropriate proportions of fixed and performance-related pay, to help to drive performance over the short and longer term, maintain a flexible cost base, and avoid creating incentives for excessive risk taking.
- To align incentive plans with the business strategy, prudent risk management and client interests.
- To ensure that culture and values are prioritised when assessments are made.
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Our company's risk tolerance is aligned with our commitment to delivering long-term value to our clients while prudently managing investment risks. We strive to achieve attractive risk-adjusted returns within an acceptable risk framework. Our risk tolerance is guided by the following firm values:
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- Preservation of Capital
- Consistency of Returns
- Client Outcomes
- Long-term thinking
- Regulatory and Legal Compliance
- Market and Economic Conditions
- Risk-Return Trade-off
- Transparency and Communication

This risk tolerance framework is linked to remuneration as follows:

1. Identification of Key Risk-Taking Roles: This includes senior managers, certified persons, and employees who have the authority to make decisions that can significantly affect the company's risk profile, including investment decisions.

2. Performance Metrics: Our performance metrics reflect both financial and non-financial aspects of risk management.

3. Evaluating Performance and Risk Culture: We regularly assess individual and team performance. Additionally, we foster a risk-aware culture by promoting open communication, accountability, and ethical behaviour throughout the organisation.

4. Variation of Remuneration: Based on the performance evaluations, remuneration is adjusted accordingly. We recognise and reward employees who demonstrate sound risk management practices, achieve risk-related targets, and contribute to the organisation's risk culture. Conversely, we consider reducing or withholding remuneration for individuals or teams that take excessive risks or fail to meet risk-related expectations.

5. Monitor and Review: We continuously monitor and review the effectiveness of the risk appetite-remuneration linkage. This includes assessing whether the remuneration policy is effectively incentivising desired risk behaviours and driving appropriate risk management practices. Adjustments may be necessary over time to ensure continued alignment with the company's evolving risk landscape.

Details of variable remuneration schemes or long-term incentive plans

All staff members have basic salaries, plus discretionary, performance-based bonuses. Bonus payments are paid depending on, but not limited to, firm performance, quantitative individual performance based on KPIs and line manager qualitative line manager assessments.

Types of remuneration paid in 2024 (all staff)

Fixed remuneration total - £0
Variable remuneration total - £0

In 2024, all staff were paid by our sister company Validus Wealth Management, but as planned this has altered in 2025. Two10 investment services now directly employs some of its key staff members. This will be reflected in the 2025/2026 remuneration performance data.
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How has the firm maintained and how will it continue to maintain effective risk management plans

The firm may adjust the level of the annual bonuses, including to zero if appropriate, to mitigate any of the following material events:

- underlying financial performance
- risk management or regulatory compliance issues
- personal performance

The firm reserves the right to hold back bonuses against the quantitative and qualitative assessment data should it foresee significant risks and challenges in the coming year that may incur losses and require further capital to maintain a strong capital position.

Overview of how conflicts of interest are managed or mitigated and how responsible business conduct is achieved

The firm maintains a robust conflicts of interest policy which is reviewed annually and maintained by senior management. Any conflicts are registered against individuals and considered when relevant risks arise.

We make use of best-in-class external consultants who – at least annually – review these arrangements and advise us in such a way to mitigate risks as far as possible.
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