Financial Year 2025

Purpose of disclosure

This disclosure is designed to provide information on the remuneration policies and practices of Sapphire Capital Partners LLP (“Sapphire”). Sapphire is a MiFID investment firm prudentially regulated by the Financial Conduct Authority in the UK and is subject to the MIFIDPRU Remuneration Code in the FCA Handbook at SYSC 19G. Sapphire applies the remuneration requirements on a proportionate basis as a small and non-interconnected investment firm.

This disclosure has been reviewed and approved by the partners of Sapphire and is published on Sapphire’s website. It has not been subject to audit.

As a private limited partnership, each of Sapphire’s member partners liability for the obligations of the firm is limited.

Overview of Sapphire’s remuneration approach

Sapphire seeks to reward staff fairly and appropriately for their contribution to the success of the business and the quality of service delivered to clients. Sapphire’s remuneration framework is designed to:

• promote sound and effective risk management;
• support the firm’s long-term strategy, objectives, culture and values;
• avoid conflicts of interest; and
• discourage excessive risk-taking beyond the firm’s risk tolerance.

Remuneration is reviewed annually following the performance review process and the setting of goals and objectives for the following year. Bonus arrangements are also reviewed annually to ensure they remain fair, proportionate and aligned with the firm’s financial position and long-term objectives. The remuneration committee is comprised of Sapphire’s partners and remuneration is reviewed annually at board level.

Remuneration governance framework

The partners of Sapphire are responsible for the operational management of the firm and for adopting, reviewing and overseeing the implementation of the remuneration policy. They also authorise salary increases and variable remuneration awards under the annual performance review process. The partners may exercise discretion to adjust the bonus pool and individual awards in light of financial performance, risk outcomes and market conditions.

The most recent review of the remuneration policy took place on 15 December 2025.

Fixed and variable remuneration

Sapphire’s remuneration arrangements for employees comprise:

• fixed remuneration, primarily annual base salary;
• discretionary annual bonus; and
• where applicable, employee share carry participation.

Partners do not receive salaries during the year and are instead remunerated through profit distributions, which Sapphire does not classify as remuneration for these purposes.

Fixed remuneration is determined by reference to role, experience, market benchmarking and annual review factors including conduct, performance, client feedback and alignment with Sapphire’s culture and ESG objectives. Variable remuneration is discretionary and is based on the partners’ assessment of individual contribution and business performance. Sapphire’s policy states that the fixed component represents a high proportion of total remuneration, allowing full flexibility to reduce variable remuneration, including to zero where appropriate.

Performance assessment

Sapphire assesses performance using both financial and non-financial criteria. These include profitability, contribution to the business, conduct, compliance, client outcomes, teamwork and alignment with Sapphire’s culture and values, including ESG-related objectives. Sapphire also states that remuneration practices are gender neutral and that salary levels are reviewed with fairness and equity in mind.

Risk adjustment

Variable remuneration is subject to risk adjustment. When determining the bonus pool, Sapphire considers trading results, cash position at year end, working capital needs, capital adequacy requirements and the wider economic outlook. Variable remuneration is structured so that it does not undermine the firm’s ability to maintain a sound capital base.

Employee share carry, malus and clawback

Where applicable, eligible full-time employees may participate in employee share carry arrangements after completion of probation. Carry awards are subject to vesting and may be forfeited in certain circumstances. The employee carry documentation also includes malus and clawback provisions. These apply where there is a risk-adjusting event, including reasonable evidence of misbehaviour or material error, a material downturn in Sapphire’s financial performance, a material restatement of accounts, or a material failure of risk management.

Material Risk Takers

Sapphire’s policy states that there were 4 eligible participants in the 2025 employee remuneration scheme which includes junior partners and excludes member partners as they are outside that employee remuneration scheme. Sapphire has not formally designated any employees as Material Risk Takers for the 2025 financial year other than the member partners.

AIFMD disclosure

Sapphire also maintains remuneration policies and practices consistent with the UK AIFMD framework. These are intended to promote sound and effective risk management, discourage risk-taking that is inconsistent with the risk profiles of the AIFs it manages, and support Sapphire’s duty to act in the best interests of the AIFs and their investors.

Quantitative disclosure for the 2025 financial year

For work related to Sapphire’s role as AIFM during the 2025 financial year:

• Fixed remuneration: £216,500
• Variable remuneration: £17,250
• Total remuneration: £234,000
• Number of staff: 7
• Number of Material Risk Takers: 0

The remuneration figures above represent the overall remuneration of full-time, part-time and intern staff involved in AIF-related work.

Review cycle

The remuneration policy is reviewed annually by members of Sapphire’s board. The last review took place on 15 December 2025.