Legal | CREDO

Website Terms of Use

Version 2.0, as at July 2023

Status disclosure

www.credogroup.com is a site operated by Credo Capital Limited (Credo or we). Credo is registered in England and Wales under company number 3681529 whose registered office is at York Gate, 100 Marylebone Road, London, NW1 5DX, United Kingdom. Credo is authorised and regulated by the Financial Conduct Authority in the United Kingdom, as well as being regulated by the Financial Sector Conduct Authority in South Africa.

If you are accessing this site in the United Kingdom, please note that the information contained on this site has been issued by Credo. The information on this site is not intended for publication to, directed at, nor for use by residents outside the United Kingdom or South Africa, if such publication, direction or use would be contrary to local law or regulatory requirements and Credo would accordingly not be able to provide any services to any person in such circumstances. You are responsible for satisfying yourself that you may lawfully access this site.

Site terms

These terms govern your use of this site and by accessing this site you agree to be bound by them. Please note that if you are an existing Credo customer, these terms will apply in addition to those contained in your agreement with Credo. All Credo products and services are also subject to separate terms and conditions which govern their use. We can change these terms of use at any time without notice by updating this posting and your continued access to or use of this site will mean that you accept any such changes.

Use of site

By using our site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms, you must leave this site immediately.

We may stop your access to or use of this site for any reason, including without limitation where we believe that you have not acted in accordance with the terms of use.

Information not recommendation

The content included in this site is provided for personal use and information purposes only and should not be construed as an invitation, offer, or recommendation, to buy or sell any investment or to engage in any other transaction, or to provide any investment advice or service.

This site may include forward-looking statements that are based upon current opinions, expectations and projections. We have no obligation to update or revise any forward-looking statements. Actual results could differ materially from those anticipated in the forward-looking statements.

No warranties

Although we have taken all reasonable care to ensure that the information provided on this site is accurate, some information may be incorrect, incomplete or out of date.

Nothing contained on the site is investment, legal, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain your own professional advice before making any investment decision..

No liability

The internet is not a completely reliable transmission medium and there may be arbitrary delays and omissions in the provision of services or site accessibility. We will not be liable for any damages or loss arising out of, or in connection with your use or inability to use this site, any error, omission, defect, computer virus or system failure, the access of, use of, performance of, browsing in or linking to other sites from this site. This means that we are not legally responsible for any money you lose (or other forms of loss) in connection with how you use the site, or how the site works.

Whilst endeavouring to ensure availability of this site 24 hours a day, we may at any time and without notice, temporarily or permanently suspend or limit access to the site or any part of it. We will not be liable for any loss or damage suffered by you or anyone else as a result of this site not being available.

We accept no responsibility for information or software provided by other sites which may be accessed by hypertext link from these pages and we are not responsible for the maintenance or availability of such pages or the information or software which they contain.

We undertake to comply with our obligations under the Financial Services and Markets Act 2000 (the Act) and any disclaimers contained on this site do not operate to exclude or restrict our duties or liabilities under the Act or any other applicable legal or regulatory authority.

US residents

If you are a resident in the United States of America (the US) or you are otherwise regarded as a US person pursuant to the Securities Act of 1933 and you are not an existing client of Credo, then you may not access this website. Credo is not registered with the Securities Exchange Commission (SEC) in the US and accordingly does not hold itself out generally to the public in the US as an investment adviser and does not solicit for business in the US. Credo is entitled to have a limited number of US clients based on it complying with the relevant exemptions from registration with the SEC. If you are an existing client or you are unsure whether you are a US person, please contact your Relationship Manager or send your query to info@credogroup.com.

Swiss residents

To the extent that this website contains information regarding collective investment schemes that are not authorized for distribution in Switzerland, such collective investment schemes may not be offered or publicly distributed in Switzerland.

The information on this website is only aimed at qualified investors according to Swiss law which include:

banks, securities dealers, fund managers and asset managers of collective investment schemes (including their clients with whom a written asset management agreement is in place),
insurance companies,
public corporations and pension funds with professional treasury operations,
companies with professional treasury departments,
high-net-worth individuals (i.e. private investors who have, prior to accessing this website, confirmed in writing to Credo that they possess net financial assets of at least CHF 2'000'000); and
independent asset managers and investors who have entered into an asset management contract in writing with an independent asset manager to the extent that the asset manager is subject to the Swiss Money Laundering Act and to a code of conduct of a professional organisation which is recognized as a minimum standard by the Swiss Financial Markets Supervisory Authority (FINMA) and that the asset management agreement is in accordance with the recognized guidelines of a professional organization.

If you are not a qualified investor, you may not access this site.

Call recording

Relevant telephone calls are recorded in accordance with our regulatory obligations. This means that all telephone calls to Credo landlines which relate to the reception, transmission and execution of your orders are recorded. Most calls to Credo mobile phones between a client or potential client and a Credo employee, self-employed consultant or contractor are recorded.

Your queries

If you wish to contact Credo, please refer to the ‘Contact’ link which can be found in the top right corner of each page of the site.

Treating Customers Fairly

Customer Statement

At Credo we are committed to offering our customers the highest possible standard of service and have accordingly incorporated the FCA's concept of 'Treating Customers Fairly' into our mission statement.

We recognise that we have as much to gain as you, our customers, when we look after your best interests and treat you fairly in all aspects of our dealings with you and so we are stating our commitment to you on this site.

Our commitment to you

To provide you with clear information about the products and services we offer you, including fees and charges;
To ascertain your individual needs, preferences and circumstances before recommending a product to you or investing in a product for you;
To deal openly and in a timely manner with your queries;
To meet or speak with you on a regular basis;
To only recommend products and services that we believe are suitable or appropriate for you;
To manage conflicts of interest fairly, both between ourselves and our customers and between customers themselves;
To encourage you to ask if there is anything that you don't understand;
To encourage you to give us feedback (whether positive or negative) on our services; and
To give you access to a formal complaints procedure should you become unhappy with our service.

How you can help us

You can assist us to provide you with the products and services that are suitable for you by:

providing us with information relating to your financial position, knowledge, experience, understanding of risk and personal background to enable us to offer you tailored products that are suitable or appropriate for you;
informing us of any changes to your financial or personal information, in a secure manner, to ensure that we keep our records up to date;
letting us know if there is any aspect of our service, or of a product we have discussed or recommended that you don't understand or you are not happy with; and
telling us if you think there are ways we can improve our service.

Feedback

Should you have any comments (positive or negative) regarding the implementation of our commitment to you or any service that we provide to you (or you have any question) please tell us by contacting your relationship manager and/or send your comments to info@credogroup.com.

Complaints Policy & Procedures

Introduction

Credo’s intention is always to provide all clients with the highest quality of service and to act in their best interests at all times. Occasionally, however, a client may feel they have a cause for complaint regarding the service, or part of the service, provided, or failure to be provided, by Credo. This summary outlines who is an ‘eligible complainant’ and the process and timeline that Credo will follow when dealing with any complaint brought by a client.

Financial Conduct Authority and Financial Ombudsman Service

Credo Capital Limited (FRN: 192204) (Credo) is authorised and regulated by the Financial Conduct Authority (FCA).

As part of its statutory obligation, the FCA has established the Financial Ombudsman Service (FOS) which has the power to consider, arbitrate and settle complaints between FCA authorised firms and an ‘eligible complainant’ where the parties have been unable to resolve the matter themselves, or a client is not satisfied with the way in which a firm has dealt with the client’s complaint.

Only complaints by persons (or on behalf of persons) who are ‘eligible complainants’ (as defined by the FCA) may be made to the FOS. Not all clients would accordingly be able to make a complaint to the FOS, i.e. clients who are categorised as professional or eligible counterparties are generally not regarded as being ‘eligible complainants’, which for the purposes of the type of businesses that Credo carries on, are the following persons:

a consumer; or
a micro enterprise (an enterprise that employs fewer than 10 persons and has a turnover or annual balance sheet that does not exceed €2m); or
a charity which has an annual income of less than £6.5 million at the time the complainant refers the complaint to Credo; or
a trustee of a trust which has a net asset value of less than £5 million at the time the complainant refers the complaint to Credo.

If you have a complaint, please advise us at the following address:

Compliance Department
Credo Capital Limited
8-12 York Gate
100 Marylebone Road
London NW1 5DX
Tel: 020 7968 8300
Email: complianceteam@credogroup.com

To enable us to resolve your complaint as quickly as possible, please provide us with the following information:

the name, address, contact phone number and email address of the complainant; or
the name and address of the organisation you represent, if you are making a complaint on behalf of an eligible complainant as well as the name and contact details of the person at the organisation who is making the complaint on behalf of an eligible complainant; and
the account number or other reference for the account that the complaint relates to; and
details of the complaint, including relevant references and dates.

Time Limits for Handling Complaints

Once we receive a complaint we will endeavour to resolve it as fairly and as quickly as possible, either informally or formally.

Informally Resolved Complaints

If a client makes a complaint to us that we are able to resolve informally within three business days of the complaint being received, we will do so. In that event, we will issue a Summary Resolution Communication (SRC) to the complainant which will include the following content which has been prescribed by the FCA:

A statement that Credo considers the complaint to be resolved;
A statement that the complainant may refer the complaint to the FOS if they subsequently decide that they are dissatisfied;
The website address for the FOS and comment that further information is available there; and
Whether Credo consents to waive the six-month time limit for referring the complaint to the FOS.

Formally Resolved Complaints

Where we are unable to resolve the complaint informally we will follow the formal ‘eight-week process’, as follows:

We will promptly issue a written acknowledgement of the complaint after receipt or failure to resolve it informally (the Date of Receipt), stating that the complaint has been received and is being dealt with or that we have been unable to deal with it informally and it will be dealt with formally;
Thereafter, we will keep the complainant informed of the progress of the complaint including the steps taken to resolve the complaint;
Within eight weeks of the date of Receipt, Credo will issue a written ‘final response’ to the complainant which;

accepts the complaint and, where appropriate, offers redress or remedial action; or
offers redress or remedial action without accepting the complaint; or
rejects the complaint and gives reasons for doing so;
encloses a copy of the FOS's standard explanatory leaflet;
provides the website address of the FOS;
informs the complainant that if they remain dissatisfied with the Company's response, they may now refer the complaint to the FOS and must do so within six months; and
indicates whether, or not, Credo consents to waive the relevant time limits.

If at the end of the eight-week period, Credo is not yet in a position issue a ‘final response’, it will send a written response to the complainant which;

explains why Credo is not in a position to make a final response and indicates when it expects to be able to provide one;
informs the complainant that they may now refer the complaint to the FOS;
indicates whether, or not, Credo consents to waive the relevant time limits;
encloses a copy of the FOS standard explanatory leaflet; and
provides the website address of the FOS.

If Credo is unable to issue a final response or it does so, but the complainant is not satisfied with the final response, the complainant has six months to refer the matter to the FOS.

Further information about the FOS may be obtained from;

The Financial Ombudsman Service
Exchange Tower
London E14 9SR

Telephone: 020 7964 1000 (Open 9am-5pm Monday-Friday)
Email: complaint.info@financial-ombudsman.org.uk
Website: http://www.financial-ombudsman.org.uk

MIFIDPRU 8 Disclosures

31 December 2024

Introduction

Background

The Investment Firms Prudential Regime sets out requirements for investment firms to disclose additional information relating to their risk management approach, capital adequacy, remuneration approach and board diversity. This represents an evolution from its predecessor regime, the Capital Requirements Directive (“CRD”) and Capital Requirements Regulation, usually referred to together as CRD IV and is intended to help enable stakeholders, including investors and counterparties to make informed decisions about their relationship with Credo Capital Limited (“Credo”) on the basis of the harm that Credo may pose to customers and markets. This supports effective market discipline and facilitates constructive engagement by all stakeholders.

This information is known as Credo's “MIFIDPRU disclosures” and is intended to contain an overview of the following aspects of Credo as at 31 December 2024:

Risk management objectives, policies and processes for managing material risks identified through the course of assessing Credo’s Own fund requirements (MIFIDPRU 4), Concentration risk (MIFIDPRU 5) and Liquidity (MIFIDPRU 6);
Internal governance arrangements and a summary of the policy promoting diversity in Credo’s management body and its application;
Own Funds and Own Funds Requirements, including its K-Factor and Fixed Overheads Requirements; and
The key characteristics of Credo’s remuneration policy and practices and specific quantitative information in support of this.

Scope of Application

Credo is subject to the Investment Firms Prudential Regime (“MIFIDPRU”) which was introduced in the United Kingdom (“UK”) on 1 January 2022 and seeks to address specific risks that investment firms face in a more appropriate and proportionate manner than the previous rules which were based on regulatory standards for large banks.

As a UK based investment firm, undertaking activities within the scope of the UK Markets in Financial Instruments Directive (“MIFID”), Credo is subject to the rules and guidelines codified in the prudential sourcebook for MiFID investment firms, MIFIDPRU, which forms part of the Financial Conduct Authority (“FCA”) Handbook.

The MIFIDPRU disclosures set out below are provided solely in respect of Credo which is a non-SNI (Small and Non-Interconnected) MIFIDPRU investment firm.

Frequency of Disclosure

This disclosure is subject to review and update at least annually. Regulatory capital requirements and firm-level own funds set out within this disclosure reflect Credo’s position as at 31 December 2024. Other disclosures covering Credo’s approach to assessing the adequacy of its own funds are based on Credo's Internal Capital Adequacy and Risk Assessment (“ICARA”) approved on 25 September 2025.

Board Approval

These disclosures were approved for publication by Credo's Board (the “Board”) on 25 September 2025. The Board has verified that the disclosures are consistent with formal policies and are satisfied with the adequacy and effectiveness of the risk management arrangements.

Verification

The information contained in this document has not been audited by Credo’s external auditors, does not constitute any form of financial statement and must not be relied upon in making any judgement concerning Credo.

Materiality

Regulations permit the omission of one or more of the required disclosures if that information is immaterial. A disclosure is deemed to be material if the omission of that information would likely change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where a disclosure is considered to be immaterial, this has been stated.

Company Background

Credo is a company incorporated in England (company number: 03681529) with its registered office at 8-12 York Gate, 100 Marylebone Road, London NW1 5DX and website www.credogroup.com. Credo is an independent wealth management business that has been in existence since 1998 and employs just under one hundred employees.

In October 2024, Credo embarked on a new chapter as it merged with Anchor Group (Proprietary) Limited (“Anchor”). Anchor is a privately owned wealth management and asset management business that was founded in South Africa in 2008. Anchor provides its services to predominantly South African resident clients. This strategic merger effectively doubles the size of the respective businesses from an assets perspective and marks a significant step in Credo’s ongoing commitment to provide clients with the best possible investment opportunities and services.

As at 30 June 2025, Credo had assets under custody in excess of £5.14bn (£1.68bn of which is under management), represented by over 8,000 underlying investor portfolios.

Credo is authorised and regulated by the FCA as an investment firm in the UK (FRN: 192204) and is licensed as a Financial Services Provider by the Financial Sector Conduct Authority (“FSCA”) in South Africa (FSP: 9757).

Credo undertakes the regulated activities of Managing investments, Dealing in investments as agent, Advising on investments (except on Pension Transfers and Pension Opt-Outs), Safeguarding and administration of assets, Arranging safeguarding and administration of assets, Arranging (bringing about) deals in investments and since 2024 it has started to provide advice in relation to non-investment insurance contracts and personal and stakeholder pensions including retirement advice, advising on pension switching and managing investments within a pension. Credo is a wealth management business which provides investment services (i.e. trading, platform and asset management services) to individual and corporate, retail and professional clients, as well as to other regulated Financial Intermediaries (“FIs”).

Credo offers both bespoke and model discretionary asset management services. Its clients can invest through individually managed equity and bond bespoke and model portfolios or through multi-asset model portfolios, which offer a selection of carefully chosen best-of-breed funds. All underlying securities within these portfolios are considered vanilla instruments (developed market listed equities and corporate bonds, listed UCITS ETFs and UCITS funds). Credo also offers investments through three of its own UCITS Irish Collective Asset-management Vehicle funds. Credo’s aim is to protect and enhance its clients' wealth.

Credo also provides its clients with global discretionary, advisory as well as execution-only trading services and uses the clearing and custodian facilities of industry leaders. Credo operates a fully disclosed, Model B arrangement with its primary custodians, Pershing Securities Limited (“PSL”) and with Pershing (Channel Islands) Limited (“PCI”). This means each client and their assets are fully identified in PSL and PCI’s books and records and they are recognised as the beneficial owner of those assets which are fully segregated from PSL and PCI’s own assets. In addition, Credo utilises PSL and PCI as its settlement agents so that once a trade has been matched (for settlement purposes), PSL or PCI, as appropriate, adopts the counterparty risk.

In addition, Credo offers platform services to FIs, such as wealth managers and financial advisory firms looking for a trusted partner for trading and settlement and to arrange custody facilities. The FIs remain responsible for complying with all the regulatory requirements of their local regulator (which for many is the FCA), including suitability and appropriateness as well as compliance with PROD in respect of their Underlying Clients (“UCs”) and, where appropriate, Credo will apply simplified due diligence to the FI and the UCs or it will rely on the FI to carry out customer due diligence on the UCs. Credo carries out its own Enhanced Due Diligence (“EDD”) checks, when appropriate. Although the platform services have been provided to South African FIs for some time, the provision of these services to FIs outside of South Africa (primarily in the UK) has grown since the inception of that business in 2014.

Governance Arrangements

Governance

The Board of directors of Credo comprises Charles van der Merwe, Roy Ettlinger, Alan Noik, Debra Chalmers, Deon Gouws, Rupert Silver, Jarrod Cahn and Gareth Crosland.

Credo is committed to ensuring that its clients, employees and suppliers/contractors are all treated equally and protected from discrimination. This commitment is enshrined in Credo’s Equal Opportunities Policy, which reflects the principles of the Equality Act 2010 and describes how Credo seeks to create diversity within its business by providing equal opportunities to all staff within an inclusive work environment. This commitment is not only important to the culture of Credo and to each director as individuals, but it is also crucial to Credo’s ability to serve its clients and grow its business. Credo recognises the benefits of having individuals with diverse backgrounds, experience, and viewpoints on the Board for the different perspectives and unique contributions they provide. Board appointments are based on an individual’s knowledge, skills, experience, performance, and other valid role-related requirements.

The Board is responsible for ensuring that the systems and controls implemented satisfy the applicable legal and regulatory framework which Credo operates under. The Board meets quarterly to review the management information relating to the conduct of the business and to assess the current and emerging risks faced by the business, although the Executive Committee (“Exco”), which is comprised of all the directors of the Board (save for Jarrod Cahn and Rupert Silver) plus David Wilkinson (Head of Operations) and Matthew Norwood-Young (Strategic Business Development). Exco meets on a bi-weekly basis and operates as Credo’s management body. The Board has delegated its authority to the Exco to carry out all of its functions and to exercise all of its powers where a formal resolution is not required, although the Board will set Credo’s strategy, objectives and overall direction and will oversee and monitor the Exco’s decision-making.

Sub-committees

In addition to the Board, the following sub-committees have delegated authority to oversee more specialised activities, with their main responsibilities set out below:

Executive Committee

Considering any risk-related matters in its weekly meetings;
Defining Credo’s risk tolerance (i.e. its appetite for risk) as detailed in the ICARA document; and
Reviewing the monthly liquidity calculation and management accounts.

Operating Committee

Managing the general day-to-day operational matters delegated to it, including, but not limited to:
- devising and implementing improvements to controls, procedures and associated documentation;
- ensuring policies and culture are appropriately implemented within Credo;
- ensuring employees are aware of their responsibilities, accountabilities and relevant policies and procedures;
- fostering a culture within Credo which emphasises and demonstrates the benefits of a risk-based approach to the internal control and management of Credo.

Investment Committee

Overall governance of Credo’s investment offering.

Compliance Committee

Managing the day-to-day compliance activities delegated to it by the Board.

Risk Committee

Although Credo's Board remains ultimately responsible for the identification, measurement, management, and mitigation of risk, it has chosen to delegate its day-to-day risk management activities to the Risk Committee (“Riskco”).

Senior Management and how SMCR is applied within Credo

The Credo senior manager functions (as described in the FCA Handbook) are performed by those persons holding the positions noted in the list below as recorded in the UK FCA Register.

Each individual has been assessed by Credo as competent to discharge their role as described under the UK Senior Manager and Certification Regime (“SM&CR”).

Senior Management Function	Name	Position
SMF 3, SMF 9	Roy Ettlinger	Chairman*
SMF 1, SMF 3	Charles van der Merwe	Chief Executive Officer
SMF 3	Alan Noik	Director: Private Clients
SMF 3, SMF 16 & SMF 17	Debra Chalmers	Director: Legal and Compliance
SMF 3	Deon Gouws	Chief Investment Officer
SMF 3	Rupert Silver	Director
SMF 3	Jarrod Cahn	Director
SMF 3	Gareth Crosland	Chief Financial Officer
() 3 other external directorships*

Risk Management Objectives and Policies

Risk Management Principles

Credo’s principles of risk management are designed to accomplish the following objectives:

Provide a coherent foundation for effective management of key risks, including liquidity, counterparty, compliance, market, financial crime and operational and security.
Identify emerging risks to Credo, mitigate these risks on a timely basis and maintain satisfactory capital levels to ensure that Credo’s sustainability on a stand-alone basis is always maintained.
Implement sound risk management practice into Credo’s accounting and financial reporting process.

Risk Management Framework

The key components of risk management within Credo are:

Risk identification;
Risk assessment;
Risk control and remediation;
Risk monitoring; and
Risk reporting.

Risk Management is a responsibility of all employees with specific risk responsibilities being allocated to different groups and levels of employee seniority within Credo. Risk management is not a stand-alone discipline but requires integration with existing business processes such as business planning, to provide Credo with the greatest benefits.

Risk Management encompasses the culture, processes and structures that are directed towards realising potential opportunities whilst managing potentially adverse effects, which involves the following key steps:

Communicate and consult
Establish the context
Identify risks
Analyse risks
Evaluate risks
Deal with the risks
Monitor and review

The Risk Register and Incident Log

Credo maintains a Risk Register that contains key risks faced by Credo, based on an enterprise-wide risk assessment. The Risk Register is a living document and is reviewed at quarterly Riskco meetings.

In addition to the Risk Register, Credo maintains an incident log. Incidents are logged by staff and reviewed by the Risk Officer and Head of Operations on a weekly basis. The purpose of recording incidents is to ensure that when something does go wrong, the information is captured so that the seriousness of the issue can be assessed. This allows the Riskco to track the specific actions required in order to address any underlying cause and prevent recurrence.

Risk Assessments

Credo undertakes annual enterprise-wide risk assessments to identify and assess the risks faced by the business from operational, strategic, regulatory and financial crime perspectives.

Risk Appetite

Risk appetite defines the risks that the business is willing to accept in pursuit of its strategic objectives. The risk appetite statement reflects the business strategy and all business activities, capacity to take on risk, the resources and technology required to manage and monitor risk exposure, and defined risk tolerances measured on both a quantitative and qualitative basis.

The overall risk appetite of Credo is low.

The risk appetite statement is an expression of how much risk Credo is willing to take. Some risks must be taken, but these are managed to prevent unnecessary risk taking. Other risks must be avoided such as harm to clients or failure to comply with relevant regulation.

The Board has the ultimate responsibility for the development of appropriate strategies, systems, and controls for the management of risks within the business. The risk appetite statement is reviewed at least annually, or more often as deemed appropriate, as part of the ICARA review process and approved by the Board. This is to ensure that Credo’s risk appetite continues to be aligned with its objectives.

Apart from the internal controls implemented, this low-risk appetite is also reflected in the services Credo offers, which are investment services (i.e. trading, platform, and asset management services) to retail and corporate clients, largely in lower risk jurisdictions, and platform services to FIs which are authorised and regulated in the UK, as well as FIs which are regulated outside of the UK.

Risk Profile

The table below sets out some of the risks that Credo is exposed to:

Key Risks	Risk Types
Financial	Credit risk Market risk Capital and liquidity risk
Operational	Duties to customer risk Employment practices & workplace safety risks Regulatory risk Financial crime risk IT risk Complaints or claims Fraud / Unauthorised payments Unsuitable management of client portfolios
Strategic	Business and strategic risk
Other	Concentration risk Reputational risk Conduct risk Supplier risk Group risk

ICARA

The ICARA is a process of ongoing identification, monitoring and mitigation of the harms that a firm may pose to itself, its clients and the markets it operates in from both its ongoing business operations and those that may arise from winding down its business. It is also intended to identify the amounts and spread of types of capital and liquid assets considered adequate to cover unmitigated harms that Credo may cause itself, its clients and the markets it operates in.

Outputs from these activities support Credo’s assessment of the adequacy of its capital and liquidity. The ICARA is used within the business to support decision-making processes, identify potential risk exposures, and implement appropriate mitigants. Should business plans or significant re-positioning of Credo's business model or activities require it, interim reviews will be undertaken.

Key Harms and Risks

MIFIDPRU 8.2.1 requires Credo to disclose its risk management objectives and policies for the categories of risk addressed by:

MIFIDPRU 4 (Own funds requirements);
MIFIDPRU 5 (Concentration risk); and
MIFIDPRU 6 (Liquidity).

Key Harms and Risks identified within MIFIDPRU 4 – Own Funds Requirements

The ICARA process is linked to Credo’s overall risk management, business planning and capital management, with each of these components informing the others. Capital planning takes place annually together with Credo’s financial forecasting process. The ICARA process allows Credo to determine its Own Funds Threshold Requirement and Liquid Assets Threshold Requirement and therefore determine how Credo meet its Threshold Conditions.

Credo has identified and assessed the following categories of risk within its assessment of the “Own Funds” requirements:

Operational Risk

Operational risk is the risk of loss or negative impact to Credo resulting from inadequate or failed internal processes, people and systems or from external events and reflects the risks that inherently arise from Credo’s operations.

Operational risk covers a broad set of risks which includes:

Operational delivery - Risks arising from the delivery of Credo’s business operations including failures in its customer and fund-level transactions e.g., transaction capture, those associated with the use of vendors and suppliers, unclear or untimely internal communication, fund accounting errors and change programme risks.
Duties to customers - Risks arising from the failure to ensure fair, impartial and suitable treatment of customers, including misleading customer communication and investment compliance breaches.
Financial crime - Risks arising from internal and external financial crime, including bribery and corruption, fraud, money laundering and terrorist financing, embargos/sanctions and market abuse.
Information security - Risks arising from losses of sensitive information, including cybersecurity, unauthorised and inappropriate access and information asset security.
Technology failure - Risks arising from significant failures of technology.
Business disruption - Risk of business disruption that adversely impacts Credo’s staff, clients and/or processes, e.g. impacts due to property damage.

When operational risk events occur, they carry the potential for harm to one or more of Credo’s own clients, the markets it operates in, as well as to its business performance, operations and reputation.

Risk appetite statement: Credo has a low appetite for operational risk but recognises that Credo must accept some operational risk, because it is impossible to eliminate it entirely. Credo strives to maintain a regime of operational efficiency, continuity of service and reliability which matches Credo’s commitment to minimising harm to clients, the integrity of the market and loss to Credo.

Business and Strategic Risk

This is the risk that Credo cannot compete effectively, becomes unviable, or that the business strategy being pursued is inappropriate or incomplete. This includes risks related to market dynamics, business strategy and business performance. Typically, strategic risks would affect the revenues and/or profitability of Credo or result in opportunity costs which are not directly mitigated by capital.

Risk appetite statement: Credo will always seek to be well capitalised. The Board has agreed that Credo should hold sufficient excess capital above its minimum regulatory capital requirement, which will enable it to withstand stress events and provide security for clients and market counterparties in the event of a wind down.

Key Harms and Risks identified within MIFIDPRU 5 – Concentration Risk

Concentration risk is that associated with Credo’s exposure to sectoral, geographic and entity or obligor concentrations.

Credo’s own cash is spread across a number of financial institutions with good credit ratings.

In terms of client concentration risk, the largest FI client in terms of percentage of total revenue earned, is less than 5%. Credo has over 150 FI clients, predominantly based in South Africa and the UK, with over 5,000 UC portfolios. In addition, Credo has approximately 2,600 retail and professional, private client portfolios with an average portfolio value of approximately £800,000.

Risk appetite statement: Credo has a low appetite for this risk and has worked extremely hard to build a diversified business, avoiding concentration risk as much as possible.

Key Harms and Risks identified within MIFIDPRU 6 – Liquidity Risk

This is the risk of Credo failing to meet its short-term liabilities as they fall due.

Risk appetite statement:Risk appetite statement: Credo has a low appetite for liquidity risk. It will always maintain a minimum liquidity adequacy requirement and will maintain a healthy buffer of +10% before Early Warning Indicators are triggered. Credo prepares a monthly Liquidity Report that is sent to the Exco and the other Board members not part of the Exco. This rolling report outlines Credo’s Core Liquid Assets vs its Basic Liquid Asset Requirement, including the surplus, as well as Credo’s Non-Core Liquid Assets (subject to a 50% haircut). To date, there have been no deficiencies in Credo’s liquidity requirements.

Own Funds and Own Funds Requirement

MIFIDPRU 8.4 – Own Funds

MIFIDPRU 8.4 requires Credo to reconcile its Own Funds to the balance sheet in the audited financial statements. The below tables provide the reconciliation as at 31 December 2024:

Composition of regulatory own funds
No	Item	(£‘000)	Source
1	Own Funds	9,679
2	Tier 1 Capital	9,679
3	Common Equity Tier 1 Capital	9,679
4	Fully paid-up capital instruments	750	Note 21 of financial statements
5	Share premium	-
6	Retained earnings	8,929	Statement of Changes in Equity

Credo’s Tier 1 Capital of £9,679k is comprised of Share Capital of £750k being 750,000 ordinary shares of £1 each and Retained Earnings of £8,929k.

Own Funds and Balance Sheet Reconciliation
Assets - Breakdown by asset classes	(£’000)
1. Non-current assets	55
2. Investments	5,296
3. Current assets	8,995
Total Assets	14,346

Liabilities - Breakdown by liability classes
1. Creditors: amounts falling due after more than one year	45
2. Creditors: amounts falling due within one year	4,622
Total Liabilities	4,667
Net assets	9,679

Capital and reserves
1. Called up share capital	750
2. Profit and loss account	8,929
Total Shareholder’s Equity	9,679

Since the year ended 31 December 2024, a dividend of £4.85m was declared and paid in April 2025.

MIFIDPRU 8.5 – Own Funds Requirement

Credo is required to disclose the K-Factor requirement and the Fixed Overhead Requirement amounts calculated for compliance with the Own Funds requirement set out in MIFIDPRU 4.3. These calculations are set out in the two tables below.

Own Funds Requirement	31-Dec-24
	(£’000)
Permanent Minimum Requirement (“PMR”)	150
Fixed Overheads Requirement (“FOR”)	3,400
K-Factor Requirement (“KFR”)	305
Own funds requirement (Highest of PMR, FOR and KFR)	3,400

K-factor requirements	31-Dec-24
	(£’000)
K-AUM	297
K-COH	8
K-CMH	0
K-ASA	0
Total KFR	305

K-Factor Requirement

The K-Factor Requirement (“KFR”) is the minimum capital requirement based on FCA-prescribed quantitative indicators representing specific risks that investment firms pose to their clients, the markets in which they operate, or to themselves. Below are the K-factors relevant to Credo:

K-AUM (assets under management) addresses risks to clients resulting from the operation of an asset management business.
K-COH (client orders handled) addresses risks of harm to clients when receiving and transmitting client orders and executing orders on behalf of clients.
K-CMH (client money held) addresses the risk of potential harm where an investment firm holds money for its customers taking into account the legal arrangements in relation to asset segregation and irrespective of the national accounting regime applicable to client money.
K-ASA (Assets Safeguarded and Administered) captures the risk of safeguarding and administering client assets and ensures that investment firms hold capital in proportion to such balances, regardless of whether they are on its own balance sheet or in third‐party accounts.

Credo has followed regulatory guidance in assessing the K-factor requirements, with the results shown in the table above.

Credo’s approach to assessing adequacy of Own Funds Requirements

Credo’s ICARA identifies the amounts and spread of types of capital and liquid assets considered adequate to cover unmitigated harms that Credo may cause itself, its clients, and the markets in which it operates. This is achieved through:

An assessment of Credo’s business strategy and ongoing operating activities. The extent to which this poses harm to Credo, its clients and the markets it operates within is assessed and quantified through ICARA scenarios, which identify and assess plausible, yet material manifestations of those harms and quantifies any capital and liquidity required to address those harms that are not fully mitigated by existing controls and processes.
Capital and Liquidity Planning and Stress-testing, which identifies an appropriate range of adverse circumstances of varying nature, severity and duration relevant to Credo’s risk profile, business model and strategy. This assesses how Credo, through application of recovery plans, can recover from such risks on a forward-looking basis and to ascertain whether it holds sufficient capital and liquidity to withstand such shocks.
An assessment of the level of capital and liquidity required to support an orderly wind down of Credo that minimises potential harms to itself, its clients and counterparties.

The ICARA approved by the Board in 25 September 2025 sets out the business model and risk appetite of Credo and the level of capital required to help mitigate risks. That document demonstrates that Credo has sufficient capital and liquid resources to support its activities and, even after the occurrence of a severe but plausible event, would expect Credo to continue into the future. The conclusion of the ICARA process is that Credo has sufficient financial resources in terms of both capital and liquidity, to ensure that there is no significant risk that its liabilities cannot be met as they fall due.

The Board has continued to review its liquidity and capital resources against its requirements and as a result the Board remains satisfied that as required by MIFIDPRU 7.4.7R, Credo holds Own Funds and liquid assets which are adequate, both as to their amount and their quality, to ensure that:

Credo is able to remain financially viable throughout the economic cycle, with the ability to address any material potential harm that may result from its ongoing activities; and
Credo’s business can be wound down in an orderly manner, minimising harm to consumers or to other market participants.

Remuneration Disclosures

Background

This section sets out remuneration-related disclosures for Credo. This document provides details of Credo’s remuneration policy and satisfies the remuneration disclosures for the year ended 31 December 2024.

The remuneration policies and practices of Credo are governed by the MIFIDPRU rules.

MIFIDPRU’s remuneration code is based on the principle of proportionality and the disclosure requirements are based on Credo’s balance sheet assets on a solo basis as it is not part of a consolidation situation.

Remuneration Committee and Oversight

Credo has a Remuneration Committee, which has responsibility for oversight of the principles and parameters of remuneration for Credo and for determination of the remuneration for the directors who are members of the sub-remuneration committee. A sub-remuneration committee determines the remuneration for all other staff. These committees are responsible for confirming annually to the Board that the principles contained in the remuneration policy have been complied with.

The Risk Officer performs an independent annual review of Credo’s compliance with the terms set out in its Remuneration Policy and provides a report to the Board following his review.

The remuneration policy and annual remuneration awarded to staff are both subject to independent challenge at a level which is considered appropriate for a privately-owned, wealth management company of Credo’s size.

Credo has taken independent legal advice on the correct interpretation and implementation of the remuneration requirements contained in the MIFIDPRU rules.

The Board and Exco take full account of Credo’s strategic objectives in setting the remuneration policy and the Board is mindful of its duties to shareholders and other stakeholders. In making decisions on remuneration, the Remuneration Committees seek to preserve shareholder value by ensuring the successful recruitment, retention and motivation of employees.

No individual is involved in decisions relating to his or her own remuneration.

Pay and Performance

The remuneration awarded by Credo to staff is made up mainly of fixed pay, i.e., salary and benefits, and variable pay which is related to performance and is designed to reflect performance against a range of quantitative and qualitative targets.

The remuneration package is structured in a way that the fixed element is sufficiently large to enable Credo to operate a fully flexible and discretionary bonus policy, although certain members of staff who are business developers have formulaic non-discretionary bonuses, which are nevertheless subject to Credo’s risk management principles.

Credo currently sets the variable component in a manner which takes into account individual performance, performance of the individual’s business unit and the overall results of Credo.

Staff performance is formally evaluated annually. The evaluations also consider the staff member’s contribution in promoting sound and effective risk management, where appropriate.

Gender neutrality is a core feature of Credo’s approach to remuneration and a fundamental principle is equal pay for employees for equal work, or work of equal value.

Aggregate Quantitative Information on Remuneration

Credo has undertaken ‘quantitative’ as well as ‘qualitative’ tests of material risk-taking in drawing up its list of Remuneration Code Staff (the “Code Staff”)

The Code Staff are split between senior management and other members of staff whose actions have a material impact on the risk profile of Credo.

The Code Staff have been drawn from categories of staff including:

Senior management and risk takers
Staff engaged in control functions
Key Function Heads

Qualitative Information Disclosures

In line with MIFIDPRU requirements, Credo has identified its Material Risk Takers (“MRTs”), being staff whose professional activities have a material impact on the risk of the Group. A total of 12 MRTs were identified in accordance with SYSC 19G.5 for the 2024 financial year and the total remuneration of the MRTs is given in the table below.

Total amount of remuneration awarded to MRTs

	MRTs
	Senior Management	Other	Other Staff	Total
Number	8	4	78	90
Fixed Remuneration - £’000	2,127	615	6,659	9,401
Variable Remuneration - £’000	1,422	145	1,439	3,006
Total Remuneration - £’000	3,549	760	8,098	12,407

Guaranteed Variable Remuneration and Severance Pay

The variable remuneration programme is flexible to allow Credo to respond to changes in market conditions and to maintain its pay-for-performance approach. Credo did not award any guaranteed variable remuneration to MRTs during the financial year.

One severance payment was made during the financial year to an MRT.

Ex-Post Adjustment of Remuneration, Including Malus and / or Clawback

Credo ensures that all variable remuneration awarded to MRTs is subject to ex-post risk adjustment, including the operation of malus and clawback. Credo has set specific criteria for the application of malus and clawback and ensures these cover, in particular, situations where the MRT participated in or was responsible for conduct which resulted in significant losses to Credo and/or failed to meet standards set out in the Conduct Rules.

Malus and/or clawback may be applied in the following situations, namely where the MRT participated in or was responsible for:

unacceptable conduct which resulted in significant losses to Credo;
failure to comply with the Conduct Rules;
conduct which has resulted in disciplinary action against that MRT; and/or
any conduct which breached the Non-Financial Criteria (described in each MRT’s employment contract).

The maximum period when malus or clawback may be applied is three calendar years following the Remuneration Period in which the event leading to the malus or clawback occurred. Clawback may be applied to up to 100% of any variable remuneration awarded during that period on a net of tax basis.

Issued on 26 September 2025 by Credo Capital Limited. Authorised and regulated by the Financial Conduct Authority (FRN: 192204)

Stewardship Code Disclosure

Version 2, as at February 2023

Introduction

In accordance with the requirement under COBS 2.2.3R of the FCA Handbook, Credo Capital Limited (Credo) is obliged to make a disclosure in relation to its commitment to the Financial Reporting Council’s Stewardship Code (the Code).

The Code was originally published by the Financial Reporting Council (FRC) in 2010 and subsequently updated in September 2012. The principal aim of the Code is to enhance the quality of engagement between institutional investors and the listed companies they invest in (Investee Companies) to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities by Investee Companies. The FRC believes that institutional investors should aspire to achieve the standards of engagement with Investee Companies in accordance with the good practice that it describes in the Code.

The Code sets out the principles of effective stewardship by investors and aims to assist asset owners and asset managers to exercise their stewardship responsibilities. Adherence to the Code is governed on a ‘comply or explain’ basis.

Although Credo supports the principles underlying the Code, Credo’s investment strategy is not supported by the Code and so it is no longer a signatory to the Code. This document describes the extent to which Credo has applied the seven principles of the Code and where appropriate, its alternative investment strategy.

Principle 1

Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

Credo’s policy is set out in this document which is available on the Credo website at https://www.credogroup.com. Credo currently manages investments on behalf of a limited number of professional clients who are not natural persons. Credo seeks to act in the best interests of its clients and as part of managing designated investments, engages and monitors companies on a wide range of matters such as performance, risks, strategy, capital structure and corporate governance, including culture and remuneration.

Good stewardship and monitoring of companies contributes to the Credo investment philosophy. These responsibilities are discharged internally as part of an integrated investment process. Although Credo recognises the importance of quality engagement between Investee Companies and institutional investors and the appropriate exercise of governance responsibilities in line with the investment objectives and needs of individual clients, we are not usually in a position to facilitate such engagement between our clients and Investee Companies.

Principle 2

Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.

The latest version of the Credo Conflicts of Interest Policy is available on the Credo website at https://www.credogroup.com/legal.

Credo seeks at all times to act in the best interests of clients, including with regard to conflicts of interest as required by the 8th principle of the FCA Principles for Business (PRIN 2.1) and SYSC 10 of the FCA Handbook. Under these obligations Credo is required to take all reasonable steps to identify, record, manage and disclose conflicts that may arise in the course of business. This includes identifying and managing actual or potential conflicts of interest that may arise either between Credo and its clients or between two separate clients.

Credo has in place a robust conflicts of interest policy, which is regularly reviewed and is committed to managing and resolving complaints fairly and efficiently.

In addition to the Conflicts of Interest Policy, Credo also maintains and reviews on a regular basis a conflicts register which records actual or potential conflicts of interest and sets out how these conflicts are managed or mitigated.

Principle 3

Institutional investors should monitor their investee companies.

Effective monitoring and review of investments is a vital element of good stewardship. Whilst the holdings that our clients have that fall within the scope of the Code is small, and our ability to influence company management is limited, we nevertheless regularly monitor holdings and companies as part of our investment process.

Credo takes a variety of factors into consideration as part of its monitoring including company performance and corporate governance arrangements and uses a variety of research tools and publicly available information to monitor company performance and developments. Where possible a call may be held with the company to discuss performance and developments.

Credo does not seek to be made an insider on company information, however if inside information is received this will be recorded and managed in accordance with the Credo Market Abuse Policy in respect of which all relevant staff have received training.

Principle 4

Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.

Credo forms its own view on the strategy and governance of an Investee Company as a result of its monitoring and that will influence the investment decisions made in relation to those Investee Companies. Generally, the holdings that our institutional investor clients hold is small and so our ability to influence the management of Investee Companies is limited, however Credo may speak to other shareholders or third parties if an issue arises in an Investee Company that we feel should be escalated, but we wouldn’t usually take the lead in any engagement with an Investee Company.

Credo’s investment strategy where an issue is identified with an Investee Company would usually be that it would be more effective and efficient for our clients to sell their holdings rather than to take any action.

Principle 5

Institutional investors should be willing to act collectively with other investors where appropriate.

We are willing to act collectively with other investors where appropriate and where this may be in the best interests of our clients. We would be willing to work with other regulated entities including members of recognised industry associations such as the Wealth Management Association (WMA) or Investment Management Association (IMA), but we would not usually take the lead in initiating any such action.

Due to the size of our clients' holdings, any arrangement would be informal and determined on a case by case basis.

Anyone seeking to act collectively should contact Credo at info@credogroup.com or call 020 7968 8300.

Principle 6

Institutional investors should have a clear policy on voting and disclosure of voting activity.

Credo does not have a voting policy per se and we will act on our clients’ instructions in relation to a vote where appropriate or where we have discretion, we may vote our client’s shares having due regard to the nature of the issues at hand, the relevant clients’ investment objectives as well as our obligation to act in the best interests of our clients.

Credo will not automatically support the board of an Investee Company and may abstain from voting if it cannot get instructions from a client or it determines that to do so would be in the best interests of clients.

Credo does not routinely attend company meetings but may attend a meeting depending on the issues being addressed at the meeting and the impact on the interests of our clients.

When considering placing votes on behalf of any funds for which Credo is the investment manager Credo will act exclusively in the interest of the relevant fund’s shareholders. Credo does not seek for the funds to take an active ownership role in investee companies. Investments in companies in which the funds are invested are not of such nature or size so that any fund will be a large shareholder. Investments in a company will usually represent less than 1% of the market capitalisation of the investee companies. Credo believes, given that the investments are not of a permanent nature, it is in the interests of shareholders of the funds not to actively participate in the investee companies’ election committees and activities of the board but rather to focus on the core investment strategy of the funds.

Principle 7

Institutional investors should report periodically on their stewardship and voting activities.

Credo maintains records of voting activities and how votes have been exercised and that information would be made available only to a client in relation to their own shares (upon request) or as required by legal/regulatory obligations. Credo will not normally disclose voting intentions, make public statements or advise any third party of its voting activities due to client confidentiality.

Engagement Policy

Version 1.1, as at June 2023

1. Introduction and Background

1.1. The amended European Shareholder Rights Directive II (SRD II), applicable since 10 June 2019, includes transparency obligations for European Union (EU) institutional investors as well as European and United Kingdom asset managers to the extent investments in EU equity instruments are made.

1.2. SRD II requires Credo Capital Limited (Credo) to disclose a shareholder engagement policy in respect of the EU equity instruments that it provides portfolio management services for on a ‘comply or explain’ basis.

1.3. This policy accordingly sets out the extent to which Credo will comply with the engagement requirements of SRD II and should be read together with Credo’s Stewardship Code Disclosure last updated in February 2023, available on our website, which describes the extent to which Credo has applied the seven principles of the Stewardship Code.

1.4. Credo’s investment philosophy is generally to invest for the long-term on behalf of its Clients for the purpose of assisting our Clients to achieve their financial objectives.

1.5. Although Credo supports the aims of SRD II which encourages long-term shareholder engagement, Credo’s investment philosophy does not generally include active engagement with EU listed companies in which we hold investments on behalf of our Clients (Investee Companies), for the reasons set out below.

1.6. Credo is authorised by the Financial Conduct Authority (FCA) and, as such, will act in accordance with the Principles as defined in the FCA Handbook, which will take precedence over the requirements of this policy.

2. Review of this Policy

This policy will be reviewed at least annually or more frequently in the event of changing circumstances or regulations by Credo’s Management Body, being its Executive Committee. This policy is publicly available on Credo’s website.

3. SRD II Requirements

We set out below a description of the extent to which Credo does comply with the SRD II requirements and the reasons why we may not fully comply.

3.1. How Credo integrates shareholder engagement in its investment strategy:

3.1.1. Prior to Credo making an investment in any listed company or fund for its Model Portfolios or UCITS funds, its specialist investment teams (comprising equity, fixed income and multi-asset specialists) (ITs) will carry out research and analysis which will include evaluating the company’s strategy, financials, risk appetite and the overlaps between these elements. If appropriate, we will engage with management of the company and/or its investor relations team to gain a better understanding of the company, industry and sector that it operates in. The investment, equities and fixed income teams have access to reports, investment research and industry information and may take such information into account when making investment decisions.

3.1.2. The purpose of Credo’s research and engagement as described above is to eliminate potential investee companies which don’t fit into Credo’s investment strategy and not to identify potential investee companies that Credo can engage with for the purpose of influencing the strategy of those companies.

3.1.3. All Credo’s investment activity is performed by the ITs and overseen by the Investment Committee.

3.2. How Credo monitors investee companies on relevant matters:

3.2.1. Once an investment has been made, the ITs continue to monitor the financial and non-financial performance of Investee Companies for the duration that the investment is held and will monitor the strategy, financial and non-financial performance and risk and capital structure, through financial analysis of the Investee Company’s reports, by attending analyst meetings, investor presentations and using media and third-party research. Any concerns that arise as a result of this monitoring will inform engagement and investment decisions.

3.2.2. In addition, external research enables the ITs, where considered appropriate for a Client, to consider Environmental, Social and Governance (ESG) factors for bespoke Client portfolios (although these factors are not currently considered key with regard to the Model Portfolios or the UCITS funds), which may then inform subsequent engagement and investment decisions.

3.3. How Credo conducts dialogues with Investee Companies:

3.3.1. Credo has an outcomes-based philosophy underpinning our approach to engagement. The majority of dialogues that form Credo’s engagement with Investee Companies are conducted by the ITs with the management and/or the investor relations. We would consider the extent of the engagement required, if any, with the Investee Company based on our investment policies, the nature of our Clients who are invested, the size of our holdings, materiality of the risks and issues and the feasibility of achieving change or influencing the Investee Company through engagement.

3.3.2. The nature and frequency of the dialogue depends on the location of the Investee Company, stage of engagement, severity of the issue and willingness by the Investee Company to engage.

3.3.3. Generally, our engagement activity is limited as we invest in very large and liquid companies so our relative shareholding size tends to be small.

3.4. How Credo exercises voting rights and other rights attached to shares:

Credo would not as a general policy exercise any voting rights on behalf of its discretionary Clients, given that its shareholding will be relatively small as most of the investments will be in mid to large-cap entities, although it will do so if specifically requested by a Client to do so or we believe it would be beneficial to our Clients to do so.

3.5. How Credo cooperates with other shareholders:

Credo may in exceptional circumstances collaborate with other shareholders, when Credo believes that the interests of its Clients are aligned with those of other shareholders and there is a material issue at stake and that such collaboration:

3.5.1. may enhance its ability to engage with the Investee Company; and

3.5.2. may enable Credo and/or the other shareholders to influence the actions and governance of the Investee Company to achieve the desired outcome for our Clients.

3.6. How Credo communicates with relevant stakeholders of the Investee Companies:

Credo’s activities may in exceptional cases, and only where the size of the shareholding that Credo is managing, warrants and/or requires such engagement, include discussions with relevant stakeholders of Investee Companies.

3.7. How Credo manages actual and potential conflicts of interests in relation to Credo’s engagement:

3.7.1. We actively identify, report and mitigate conflicts of interest. When any staff member recognises a potential conflict of interest with an Investee Company in which they are engaging, he or she must raise this with their line manager and Compliance.

3.7.2. Potential conflicts of interest may arise where a Credo member of staff has a personal interest in the same Investee Company as a Client either as a result of an investment in the Investee Company or as a result of a material personal relationship with a material person at the Investee Company. Our Conflicts of Interest Policy which is available on our website here: https://www.credogroup.com/legal, sets out the processes to avoid or mitigate the risk of any such potential conflicts.

3.7.3 Where a staff member has a personal connection with a company, he or she is required to report this to Compliance.

4. Transparency

Annual implementation of this Engagement Policy

Since it is not Credo’s intention to exercise voting rights on behalf of Clients unless specifically instructed to do so, it is unlikely that Credo will have any information to disclose regarding its voting behaviour but to the extent that it has exercised any voting rights on behalf of any of its discretionary Clients, it will make such disclosures as required by the applicable law.

UK GDPR Privacy Notice

UK GDPR Privacy Notice Version 7, as at July 2026 General Credo Capital Limited and its group-affiliated companies (together Credo, we or us) are committed to protecting the privacy and security of the information we hold about you which includes, without limitation, your personal details, transactions and use of our products and services whether or not as part of your direct client relationship with us or otherwise (referred to as ‘personal data’ in this privacy notice). For the purposes of the UK General Data Protection Regulation (UK GDPR) as applied under the Data Protection Act 2018 (and regulations made thereunder), the Data (Use and Access) Act 2025, and all other legislation and regulatory requirements in force from time to time which apply to the use of personal data and the guidance and codes of practice issued by the Information Commissioner’s Office (ICO), or other relevant regulatory authority (collectively, the Data Protection Laws), we are a data controller. This means that we are responsible for determining how and why we process your personal data. This privacy notice describes how, when and why we may collect and use your personal data, your rights relating to that data, and how others may gain access to it. Collecting your personal data We collect personal data about you from different places including: directly from you; from someone acting on your behalf; from publicly available sources (such as media stories and online registers or directories) or third parties (such as credit reference agencies and fraud prevention agencies and criminal record checks and information); or where we or our designated service providers might generate such information. We may collect, use, store, transfer and share certain categories of your personal data which include, without limitation: Identity data: your name, date of birth, national insurance/identity number(s), nationality and passport information or other identification information; Contact data: your home address, place of residence, mobile number, and email address; Tax data: tax status and tax identification number; Income/employment data: employment details, proof of income (such as payslips or bank statements), and personal wealth (for example, your properties) Education history: education and experience data Special category data: health data, racial or ethnic origin, sexual orientation, genetic data, trade union membership, or political opinions (processed only where permitted under Article 9 of UK GDPR); Visual/auditory data: voice and/or image, as captured in audio and/or video recordings of telephone or video conversations with us; Criminal data: information about criminal convictions and offences; Financial data: bank account details and/or account balance information; and Technical data: electronic device identification number. Using your personal data We will only use your personal data when there is a lawful basis under the Data Protection Laws. The primary legal bases we rely on include: Consent: where you have explicitly agreed to data processing for specific purposes; Provision of services: to provide services to you or fulfil our contractual obligations as part of our agreement with you; Legal obligations: to comply with applicable laws and regulations; and Legitimate interest: crime prevention, public security, national security or defence safeguarding, emergencies, sharing personal information to help other organisations perform their public tasks or official functions, our business interests, the interests of a third-party, commercial interests; The table below sets out examples of when and why we may use your personal data. Whilst we generally rely on compliance with a legal/regulatory obligation or contractual performance as a legal basis for processing your personal data, where our legal basis is (or may be) a legitimate interest, those interests are also set out in the table: What we use your information for The legal basis for doing so Detecting, preventing and investigating fraud, money laundering, and/or other types of financial crime and to verify your identity. Carrying out client due diligence, identifying and correcting issues relating to client records, or supporting regulatory requirements or operational processes. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. We have a legitimate interest to detect and prevent and investigate fraud, money laundering and other crimes and to verify your identity in order to protect our business. Where applicable, we may share information within our group of companies for internal administrative purposes, including group-wide financial crime prevention, compliance monitoring, risk management and governance activities, where this is necessary and proportionate. Where applicable, we may share information within our group of companies for internal administrative purposes, including remediation, compliance reviews, risk management, and governance. This remains subject to the legitimate interests assessment, including consideration of necessity and the impact on individuals’ rights. Providing products and/or services requested by you. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. Where applicable, we may share information with other entities within our group for internal administrative purposes where necessary to support the delivery, management or oversight of our products and services. Managing your Credo accounts and dealing with any of your transactions. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. We have a legitimate interest to make sure that our client accounts are well-managed, and to protect our business interests and the interests of our clients. We may share information with other group entities where necessary for internal administrative purposes, such as account oversight, operational support, risk management, compliance, and governance. Enforcing or defending our rights. We have a legitimate interest to protect our business. Regulatory reporting. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. We may share information within our group where necessary for regulatory oversight, compliance monitoring, reporting, and internal governance purposes. Such sharing will be carried out in accordance with the Data Protection Laws. Monitoring and recording calls. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. Managing our relationship, including electronic communications, with you. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. We have a legitimate interest to make sure that our client accounts are well-managed, and to protect our business interests and the interests of our clients. Managing complaints, take action to put matters right, and to answer your questions. Where necessary to carry out our agreement or to take steps to enter into an agreement with you. Where the law and/or regulation requires this. We have a legitimate interest to make sure that complaints are investigated to put matters right and so we can prevent complaints from arising in the future. Telling you about Credo, our products and services (unless you have opted out of marketing, or we are prevented by law from doing so). We have a legitimate commercial interest to give you information about Credo and our products and services that you may be interested in. Where required by law, we have your permission to do so. Responding to any enquiries from law enforcement, regulatory or other governmental, quasi-governmental or judicial authorities about you or your trading activity or to assist any third party in responding to such enquiries. Where the law and/or regulation requires this. We have a legitimate interest to protect our business. Obtaining or providing professional advice from or to other third parties contracted with us, including accountants, auditors and lawyers. Where the law and/or regulation requires this. We have a legitimate interest to obtain advice on issues relating to you, your account, trading and other relevant matters in order to protect our business. Sensitive personal data In order to meet our regulatory obligations in relation to our assessment of your investment objectives and customer vulnerability, we may collect and use your sensitive personal data, in particular information relating to your health. We will obtain your permission to do so. Sharing of your personal data When we use your personal data for the purposes set out above, we may only share it with: our group companies (which may include entities within the wider Credo corporate group which includes Anchor Group (Pty) Ltd in South Africa and its subsidiaries in South Africa, and elsewhere, from time to time), our delegates or other appointed agents; any depository, stock exchange, custodians, clearing or settlement houses, market counterparty, broker or other third parties contracted with us (and that agree to be bound by appropriate confidentiality restrictions or who are subject to professional confidentiality codes); service providers outsourced by us for the purposes of conducting client due diligence checks and other similar checks; any law enforcement, regulatory and other governmental, quasi-governmental or judicial authorities; any introducer or financial intermediary from whom we receive your personal data; persons acting on your behalf, including your financial advisers, appointed persons or your bank; third parties placing reliance on us to carry out due diligence on you in connection with investments made on your behalf, including fund administrators and other entities performing a similar function in relation to your investments; or other third-party suppliers, such as technology or cybersecurity providers, we may engage to support the delivery of our services to you, to fulfil our business purposes, or to meet our regulatory compliance obligations. Transfer of your personal data to third parties We or the above recipients may transfer your personal data to third parties, both in the United Kingdom or a jurisdiction outside of the United Kingdom (such as South Africa, where data privacy laws are not equivalent to those in the United Kingdom). In those instances, we will take the necessary steps to ensure that your personal data is protected in accordance with the Data Protection Laws. Your rights You have a right to: Receive: request certain information about our processing activities; Access: request access which may be subject to a fee (as amended from time to time) to meet our costs in providing you with details of the personal data we hold about you; Rectification or erasure: request the rectification, erasure or withdrawal of your personal data; Restriction: restrict or object to the processing of your personal data; Prevention: prevent our use of your personal data for direct marketing purposes; and Data portability: in certain circumstances, request to transfer your personal data from us to another data controller. If you wish to exercise any of these rights, you should contact our Data Sponsor using the details provided under the Contact tab. However, please note that in some circumstances we might not be able to comply fully with your request if it conflicts with Data Protection Laws or other laws and regulatory obligations by which we are bound. If you are not satisfied with our response, you also have the right to lodge a complaint with the ICO if you consider that the processing of your personal data carried out by us infringes the applicable Data Protection Laws. Please see: https://ico.org.uk/ for more information on how to lodge a complaint. Security of your personal data We have taken and will continue to take the necessary steps to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held. Our current policy is to retain your personal data for the period specified in our Data Protection Policy, which reflects the nature of the data, the purpose for which it is processed and our legal and/or regulatory pertaining to the same. Changes to this Privacy Notice We may revise or supplement this privacy notice at any time to reflect, for example, any changes in relevant laws and regulations or as a result of a significant change to our business practices or technologies used. Please ensure that you check our website from time to time for such modifications. Contact All enquires, requests or comments regarding this privacy notice or relating to the processing of your personal data are welcomed and should be sent to the Data Sponsor at Credo Capital Limited, 8-12 York Gate, 100 Marylebone Road, NW1 5DX, London, United Kingdom or by email to dataprotection@credogroup.com.

POPIA Privacy Statement

Version 1.0, as at September 2025

Credo Capital Limited (CCL) and Credo Group SA (Pty) Limited (CGSA) (collectively we, us or our, as appropriate) collect, process and store information of data subjects (defined under POPI as a natural or legal (juristic) person whose information is collected, processed and/or stored; you) in the usual course of our business. We need to continue doing so whilst being compliant with the Protection of Personal Information Act 4 of 2013 (POPI). We are fully compliant with POPI and this privacy statement serves as our disclosure to data subjects (and other interested parties) of how we achieve that in relation to your (and their) personal information.

POPIA applies to every responsible party, so long as it is either based in South Africa (SA), or outside of SA, but processes personal information within SA (unless it is only forwarding personal information through SA). This means that POPI creates a broad compliance framework which captures not only personal information of the SA residents (as the case is with the UK GDPR which only applies to personal data of the UK residents) such as our clients and staff members based in SA but also to anyone whose personal information simply passes through the SA territory regardless of their residency.

Why do we collect and process your personal information?

As CCL provides data subjects with a service, we need to gather certain information to be able to do so.
The kind of information CCL or CGSA collects (on behalf of CCL) will depend on the reasons for which it is collected and used. We will only collect information that we need for the particular purpose as agreed upon and no more than necessary. We will also tell data subjects what information they need to provide to us and what information is optional.

How do we collect and process your personal information?

We have a fully developed POPI compliance framework in place which comprises, without limitation, impact assessments and a POPI Policy.
We will usually obtain information from a data subject directly but may from time to time also obtain it from someone acting on your behalf, publicly available sources or where we or our designated service providers generates such information.
Information about data subjects may be processed by third parties such as (i) our group companies (which may include entities within the wider Credo corporate group which now includes Anchor Group (Pty) Ltd in South Africa and its subsidiaries in South Africa, and elsewhere, from time to time), our delegates or other appointed agents; (ii) enforcement, regulatory and other governmental or judicial bodies; or (iii) other third-party suppliers, such as technology or cybersecurity providers, custodians, service providers outsourced by us for the purposes of conducting client due diligence checks and other similar checks, we may engage to support the delivery of our services to you, to fulfil our business purposes, or to meet our regulatory compliance obligations.
The information we collect may be transferred outside of SA, for instance to CCL which is UK-based or where we use Cloud services to store data or if one of our service providers is situated overseas.

What personal information do we collect and process?

From time to time, we may collect some of the personal information set out below, however our specific interaction with the data subject will detail the exact information we need. In the usual course we will collect, process and/or store the following personal information:

information relating to the education or the medical, financial, criminal or employment history of the data subject;
any identifying number, symbol, email address, physical address, telephone number, location information, online identifier or other particular assignment to the data subject;
the biometric information of the data subject, such as voice and/or image captured in audio and/or video recordings of telephone or video conversations with us;
the personal opinions, views or preferences of the data subject;
correspondence sent by the data subject which is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
the views or opinions of another individual about the data subject; and
the name of the data subject if it appears with other personal information relating to the data subject in question or if the disclosure of the name itself would reveal information about the data subject;
information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the data subject; and
personal information concerning a child.

Your rights

Data subjects have the right not to share their personal information with us but should they so decide, this may impact the level of service we can provide to them or whether we can provide the service at all. They may contact us to enquire what personal information of theirs we hold. They also have the right to correct their personal information or to request us to delete it, unless we are legally obliged to hold this information under POPI or otherwise. Where consent was obtained from a data subject in relation to the processing of certain sensitive personal information, they also have a right to revoke this consent.

Enquiries or complaints

If you have any enquires, requests or comments regarding this privacy statement or relating to the processing of your personal information, please contact our Information Officer at the following email address:

Information Officer: Christelle Coetzee ccoetzee@credogroup.com.

Deputy Information Officer: Louise Usher lusher@credogroup.com.

or by post at:

199 Oxford Road

Dunkeld

Johannesburg

2196

South Africa.

Data subjects have the right to lodge a complaint to the Information Regulator by e-mail to POPIAComplaints.IR@justice.gov.za or https://inforegulator.org.za/.

Consent

By visiting our website and/or communicating with us by email, you consent to the collecting, processing and storing of your personal information, including the transfer of your personal information as set out in this privacy statement.

PAIA Manual

Version 2, as at May 2024

List of Acronyms and Abbreviations

“CEO” Chief Executive Officer
“DIO” Deputy Information Officer;
“CIO” Information Officer;
“Minister” Minister of Justice and Correctional Services;
“PAIA” Promotion of Access to Information Act No. 2 of 2000 (as Amended);
“POPIA” Protection of Personal Information Act No.4 of 2013;
“Regulator” Information Regulator; and
“Republic” Republic of South Africa

Introduction

On 23 November 2001. The Promotion of Access to Information Act No. 2 of 2000, ("the Act") came into operation. Section 51 requires that we as a private body compile a manual providing information to the public regarding the procedure to be followed in requesting information from us for the purpose of exercising or protecting rights of those requesters. This manual is to be read with the POPIA Policy or statement of the institution as well.

When a request is made in terms of the Act, there is an obligation to release the information, except in circumstances whereby the Act expressly provides that the information must not be released or may be withheld. The Act stipulates the requisite procedures in order to process any request for information.

Members of the public will be able to:

review the categories of information which we possess and which they can obtain access to;
know the process to follow when requesting information;
access the contact details of the Information Officer and Deputy Information Officer;
know the purpose of processing personal information and thebdescription of categories of data subjects, if we will process personal information;

A copy of this manual is also available on our website:(PAIA Manual)

Contact Details

Credo Group South Africa (Pty) Limited will deal with all requests relating to any of the entities. All requests for information in terms of this manual should be directed to:

The Information Officer
199 Oxford Road
Dunkeld
2196
Johannesburg
South Africa
Telephone: +27 11 463 6312

The Responsible Parties

Credo Group SA (Pty) Ltd - Registration: 2000/002330/07

199 Oxford Road
Dunkeld
2196

Directors	Telephone	email
Alan Noik	+44 207 968 8401	anoik@credogroup.com
Charles van der Merwe	+44 207 968 8342	cvandermerwe@credogroup.com
Information Officer	Telephone	email
Christelle Coetzee	+27 11 463 6312	ccoetzee@credogroup.com
Deputy Information Officer	Telephone	email
Louise Usher	+27 11 463 6312	lusher@credogroup.com

Credo Capital Limited - Registration: 03681529

8-12 York Gate
100 Marylebone Road
London
NW15DX

Directors	Telephone	email
Charles van der Merwe	+44 207 968 8342	cvandermerwe@credogroup.com
Information Officer	Telephone	email
Christelle Coetzee	+27 11 463 6312	ccoetzee@credogroup.com
Deputy Information Officer	Telephone	email
Louise Usher	+27 11 463 6312	lusher@credogroup.com

The Act

The Act grants a requester access to records of a private body, if the record is required for the exercise or protection of any rights. If a public body lodges a request, the public body must be acting in the public interest. Requests in terms of the Act shall be made in accordance with the prescribed procedures, at the rates provided.

Records of the Responsible Party

This section serves as a reference to the records we hold in order to facilitate a request in terms of the Act.
It is recorded that the accessibility of the documents listed below, may be subject to the grounds of refusal set out hereinafter and in the Act.
The information is classified and grouped according to records relating to the following subjects and categories.

Automatically available records

Records that are automatically available to the public are all records of the Responsible Party lodged in terms of government requirements with various regulatory and statutory bodies, including the Registrar of Companies, and the Registrar of Deeds etc. Other records include but are not limited to:

Website information
Brochures
Pamphlets
General Marketing campaigns
Social Media

Records available on request

We set out below the subjects and categories of records that are, subject to access being denied as set out in the Act, available for the purposes of the Act: Records are held on the following subjects:

8.1 Internal Company Records

The following are considered to include but not be limited to records, which pertain to the private body’s own affairs:

Financial records
Operational records
Databases
Information technology
Marketing records
Internal correspondence
Records relating to products and services
Statutory records
Internal Policies and procedures
Securities and equities
Record held by officers of the Responsible party

8.2 Personal Records

This includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time employees, as well as contract workers.

Internal evaluation records and performance appraisals
Personal records provided by and to personnel
Records provided by a third party relating to personnel
Conditions of employment and other personnel-related contractual and legal records
Correspondence relating to personnel; and
Training schedules and materials

8.3 Client Related Records

This refers to any natural or juristic entity that utilizes the products and services of the Responsible Parties and include:

Records and correspondence provided by clients;
Records provided by a client to a third party or outsourced service provider acting for or on behalf of the Responsible Party;
Records provided by a third party of a client
Any other client related record generated through the lifetime of the relationship or thereafter, including transactional records

8.4 Other Party records

The Private body may possess records pertaining to other parties, including without limitation contractors, suppliers, subsidiary/holding/sister companies, joint venture companies, service providers. Alternatively, such other parties may possess records, which can be said to belong to the private body.

These include:

Personnel, client or private body records which are held by another party as opposed to being held by the private body; and
Records held by the private body pertaining to other parties, including without limitation financial records, correspondence, contractual records, records provided by the other party, and records third parties have provided about the contractors / suppliers.

It is recorded that the accessibility of the records and documents listed above, may be subject to the grounds of refusal as set out in this manual below.

Grounds for refusal of access to records

The main grounds for the Responsible Party to refuse a request for information relates to the:

mandatory protection of the privacy of a third party who is a natural person, which would involve
unreasonable disclosure of personal information of that natural person;
mandatory protection of the commercial information of a third party, if the record contains:

trade secrets of that third party;
financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of that third party;
information disclosed in confidence by a third party to the Responsible Party if the disclosure could put that third party at a disadvantage in negotiations or commercial competition.

Mandatory protection of confidential information of third parties if it is protected in terms of any agreement;

mandatory protection of the safety of individuals and the protection of property;
mandatory protection of records that would be regarded as privileged in legal proceedings;
the commercial activities of the Responsible Party, which may include:

trade secrets;
financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of the Responsible Party;
information, which, if disclosed, could put the Responsible Party at a disadvantage in negotiations or commercial competition;
a computer programme which is owned by the Responsible Party, and which is protected by copyright.

The research information of the Responsible Party or a third party, if its disclosure would disclose the identity of the Responsible Party, the researcher or the subject matter of the research, and would place the research at a serious disadvantage.

Requests for information that are clearly frivolous or vexatious or which involve an unreasonable diversion of resources shall be refused.

Remedies in case of information request denial

10.1 Internal Remedies

The decision made by the Information Officer is final and requesters will have to exercise such external remedies at their disposal if the request for information is refused and the requester is not satisfied with the answer supplied by the Information Officer.

10.2 External Remedies

A requester that is dissatisfied with the information officer's refusal to disclose information, may within 30 calendar days of notification of the decision, apply to a Court for relief.

Likewise, a third party dissatisfied with the information officer's decision to grant a request for information, may within 30 calendar days of notification of the decision, apply to a Court for relief. For purposes of the Act, the Courts that have jurisdiction over these applications are the Constitutional Court, the High Court or another court of similar status.

Access to records procedure

The requester must comply with all the procedural requirements contained in the Act relating to the request for access to any of the above categories of information.

The requester must complete the prescribed Form 2 in accordance with Regulation 7, and submit same as well as payment of a request fee and a deposit, if applicable, to the information officer or the designated deputy information officer, at the postal or physical address or electronic mail address.

The prescribed form which is also available on the Information Regulator's website (www.inforegulator.org.za) must be filled in with enough particularity to at least enable the information officer to identify:

the record or records requested;
the identity of the requester
which, form of access is required, if the request is granted;
the postal address or e-mail address of the requester.

The requester must state that he/she/it requires the information in order to exercise or protect a right, and clearly state what the nature of the right is so to be exercised or protected. In addition, the requester must clearly specify why the record is necessary to exercise or protect such a right.

the Responsible Party will process the request within 30 calendar days unless the requester has stated special reasons which would satisfy the information officer that circumstances dictate that the above time periods not be complied with. The requester shall be informed in writing whether access was granted or denied. If, in addition, the requester requires the reasons for the decision in any other manner, he/she must state the manner and the particulars so required.

If a request is made on behalf of another person, then the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the information officer.

If a requester is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally.

The requester must pay the prescribed fee as detailed in this policy before any further processing can take place.

Types of requesters

Records held by the Responsible Party may be accessed by requests only once the prerequisite requirements for access have been met.

A requester is any person making a request for access to a record of the Responsible Party. There are two types of requesters:

12.1 Personal Requester

A personal requester is a requester who is seeking access to a record containing personal information about the requester.
the Responsible Party will voluntarily provide the requested information or give access to any record with regard to the requester's personal information. The prescribed fee for reproduction of the information requested may be charged.

12.2 Other Requester

The requester (other than a personal requester) is entitled to request access to information on third parties. However, the Responsible Party is not obliged to voluntarily grant access. The requester must fulfil the prerequisite requirements for access in terms of the Act, including the payment of a request and access fee.

Fees

The Act provides for two types of fees, namely:

a request fee, which will be a standard fee; and
an access fee which must be calculated by considering reproduction costs, search and preparation time and cost, as well as postal costs.

If the levying of a fee is invoked, it will be charged at the Responsible Party’s standard admin fee per hour.

When the request is received by the information officer, such officer shall by notice require the requester, other than a personal requester, to pay the prescribed request fee (if any) before further processing of the request.

If the search for the record has been made and the preparation of the record for disclosure, including arrangement to make it available in the requested form, requires more than the hours prescribed in the regulations for this purpose, the information officer shall notify the requester to pay as a deposit, the prescribed portion of the access fee which would be payable if the request is granted.

The information officer shall withhold a record / outcome until the requester has paid the fees in accordance with Regulation 8 and as captured in Form 3

A requester whose request for access to a record has been granted, must pay an access fee for reproduction and for search and preparation, and for any time reasonably required in excess of the prescribed hours to search for and prepare the record for disclosure including making arrangements to make it available in the request form.

If a deposit has been paid in respect of a request for access, which is refused, then the information officer must repay the deposit to the requester.

Decisions

The Responsible Party will, within 30 calendar days of receipt of the request, decide whether to grant or decline the request and give notice with reasons (if required) to that effect.

The 30 calendar day period with which the Responsible Party has to decide whether to grant or refuse the request, may be extended for a further period of not more than 30 calendar days if the request is for a large number of information, or the request requires a search for information held at another office of the Responsible Party, and the information cannot reasonably be obtained within the original 30 calendar day period. the Responsible Party will notify the requester in writing should an extension be sought.

Availability of the manual

The manual is made available in terms of Regulation Number R 187 of 15 February 2002 and is available on our website as well as at our registered offices on the contact details as stated in this policy.

Updating the manual

The Information Officer/s of Credo Group SA (Pty) Ltd and Credo Capital Limited will update this manual as and when updates are deemed necessary or at least annually.

Internal appeal related to public bodies

It is important to note that there is a process in place regarding the Internal appeal against the decision of the Information Officer of a Public Body.

A complainant may lodge an internal appeal against a decision of the Information Officer of a Public Body as contemplated in section 75(1) of the Act, in accordance with Regulation 9 and Form 4.

Appendix 1: Information available in terms of other legislation

The Responsible Party is required to keep records in terms of certain legislation. Insofar as may be applicable, the Responsible Party keeps records of information to the extent required in terms of the following legislation, as amended, and codes of best business practice:

Administration of Estates Act No. 66 of 1965

Basic Conditions of Employment Act No. 75 of 1997

Companies Act No. 71 of 2008

Compensation for Occupational Injuries and Diseases Act No. 130 of 1993

Competition Act No. 89 of 1998

Consumer Protection Act No. 68 of 2008

Employment Equity Act No. 55 of 1998

Financial Advisory and Intermediary Services Act No. 37 of 2002

Financial Intelligence Centre Act No. 38 of 2001

Income Tax Act No. 58 of 1962

Labour Relations Act No. 66 of 1995

National Credit Act No. 34 of 2005

Occupational Health and Safety Act No. 85 of 1993

Prescription Act No. 68 to 1969

Prevention of Organised Crime Act No. 121 of 1998

Transfer Duty Act No. 40 of 1949

Unemployment Insurance Act No. 63 of 2001

Value-added Tax Act No. 89 of 1991

Cookie Policy

Version 2.1, as at July 2023

1.1. Our website and the functionality of our online information, trading and reporting platform available through our website (and any related sub-domains), which – if you are our client – enables you to access and manage the investments for and on behalf of the investors (MyCredo Platform) use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website or access the MyCredo Platform and also allows us to improve those. You can find out more about cookies and how to control them in the information below.

1.2. A cookie is a small piece of data (file of letters and numbers) that a website asks a visiting user to store on their device in order to remember information about them. Cookies contain information that is transferred to your computer's hard drive. Those cookies are set by us and called first-party cookies. We also use one type of third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our analytical and performance efforts.

1.3. We use the following types of cookies:

1.3.1. Strictly necessary cookies. These are cookies that are required for the MyCredo Platform to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as logging into secure areas of the MyCredo Platform. You can set your browser to block or alert you about these cookies, but some parts of the MyCredo Platform will not then work. These cookies do not store any personally identifiable information. They include cookies that enable you to log into secure areas of our website.

1.3.2. Analytical or performance cookies. These allow us to recognise and count the number of visitors and traffic sources and to see how visitors move around our website when they are using it. This helps us to measure and improve the way our website works, for example, by ensuring that users are finding what they are looking for easily, and to know which pages are the most and least popular. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our website, and will not be able to monitor its performance.

1.3.3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to provide enhanced functionality and to personalise our content for you, greet you by name and remember your preferences (for example, your choice of region or cookie settings). If you do not allow these cookies then some or all of these services may not function properly. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name	Type & Purpose	More Information
-ga, -gid, -gat	These third-party cookies written by Google Universal Analytics allow us to collect analytics information about your visit and to estimate our audience size and usage pattern.	Cookie usage Remarketing audiences	Analytical or performance cookies
ARRAffinity	This technical cookie enables us to route your requests to the correct server	Cookie written by our website	Strictly necessary cookies
OpenIDConnect.nonce	This security cookie enables us to prevent certain security replay attacks	Cookie written by our website	Strictly necessary cookies
SignInMessage	This security cookie enables us to manage user authentication	Cookie written by our website	Strictly necessary cookies
ASP.NET-SessionId	This security cookie enables us to identify and hold information about the current session of an authenticated user	Cookie written by our website	Strictly necessary cookies
V6.Auth & SL.Auth	The authentication cookie that contains your bearer token	Cookie written by our website	Strictly necessary cookies
*.XSRF	These security cookies enable us to prevent certain cyber attacks	Cookie written by our website	Strictly necessary cookies
Cookie banner cookie	This cookie is used to remember your privacy preferences	Cookie written by our website	Functionality cookies

1.4. We do not share the information collected by the cookies with any third parties.

1.5. If you do not accept the use of these cookies, please disable them by clicking on the cookie settings links from our cookie banner. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website or the MyCredo Platform.

1.6. Except for strictly necessary cookies, all cookies will expire after at the end of each session.

Investment Research

From time to time, Credo Capital Limited ("Credo") may publish investment research and recommendations on this website. Such investment research will usually be impartial or not. Set out below is Credo 's policy on the impartiality of research.

Policy of impartiality

Investment research issued by analysts is conducted under the following circumstances:

The analysts have no relationship with the issuer of securities;
The analysts' remuneration is not linked in any manner to the outcome of the recommendation;
The analysts do not receive any inducement from the issuer of securities to provide favourable research;
The research is not reviewed by any persons whose impartiality might reasonably be considered to conflict with the interests of the clients to whom the investment research is to be distributed.
The analysts are not involved in any other activities in the Credo Group that will place their impartiality in question.

In addition, Credo does not undertake proprietary trading.

In terms of Credo's policy, no dealing is permitted by staff or clients (other than an unsolicited client order) until the clients for whom the publication is principally intended have had (or are likely to have had) a reasonable opportunity to act upon it.

In the event that a company in the Credo Group has a mandate to provide services or advice to the Issuer of the securities which are the subject of an investment recommendation, such securities are placed on a restricted list and will be subject to the policy referred to above.

The above policies and procedures are strictly monitored by the compliance team.

Research that is not impartial

In the event that a newsletter or recommendation does not comply with the above policy, readers will be warned that the research cannot be relied upon as being impartial, objective or independent.

Consumer Duty

Please click here for details of Credo’s Target Market and Price and Value Assessments.

RDR - Restricted Advice

If you are a UK resident retail client who wishes Credo Capital Limited ("Credo") to advise you in connection with certain types of retail investment products (such as units in collective investment schemes (regulated and unregulated), interests in investment trust savings schemes, securities in investment trusts, other designated investments in a packaged form or structured capital-at-risk products (collectively "RIPs")), Credo is obliged to bring to your attention that the advice that Credo will give to you will not be independent advice covering the whole range of RIPs (as defined in the Conduct of Business Rules of the Financial Conduct Authority) but will be given on a limited range of products and/or in respect of a limited number of providers and accordingly the advice will be restricted.

Conflicts of Interest Policy

Version 3.4, as at July 2023

1. Objectives and Scope

Conflicts of Interest and potential conflicts are ubiquitous in the financial services industry and Credo Capital Limited (we/us/it/our/Credo) takes the management and mitigation of such conflicts seriously. Although the potential for conflicts to arise is most likely to be greater in large organisations providing a full range of financial services, even smaller firms may have interests which conflict with the duties owed to Clients. The failure to deal appropriately with any conflict leads to the undermining of confidence in the financial markets in general. At the individual firm level, firms failing to address such conflicts may be exposed to the risk of litigation and loss of reputation. Therefore, regulatory authorities expect strong management oversight and control in this respect.

The objective of this Policy is to provide guidance around managing conflicts of interests under the Companies Act 2006 and the FCA High Level Standards – Senior Management Arrangements, Systems & Controls (SYSC).

It covers the following areas:

What is a conflict of interest;
When a conflict of interest may arise;
The types of conflicts which may arise;
The Company’s policy on managing conflicts of interest;
size and nature of the order;
The actions that an individual should take if there is a conflict; and
Regulatory requirements.

Under the FCA rules, a conflict may arise where a firm or individual is providing services to its Clients in the course of carrying out regulated activities and may entail a material risk of damage to the interests of a Client. In assessing whether a conflict of interest has arisen, Credo and its subsidiaries must consider whether a firm or individual:

is likely to make a financial gain, or avoid a financial loss, at the expense of the Client;
has an interest in the outcome of a service provided to the Client or of a transaction carried
out on behalf of the Client, which is distinct from the Client’s interest in that outcome;
has a financial or other incentive to favour the interest of another Client or group of Clients
over the interests of the Client;
carries on the same business as the Client;
receives, or will receive, from a person other than the Client an inducement in relation to a
service provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that service.

2. Definition

Conflicts of Interest can arise between various parties, including:

Credo and one or more of its Clients;
An employee and one or more of Credo’s Clients;
Two Credo group entities;
An employee and a Credo group entity;
Two or more of Credo’s Clients;
A third party service provider and a Credo group entity;
A third party service provider and of Credo’s Clients;
Two or more employees.

In accordance with the FCA Handbook, Credo has a regulatory obligation under SYSC 10 of the FCA Handbook and Principle 8 to establish processes and controls in order to identify conflicts of interest and manage them fairly. Managing conflicts of interest will lower the risk of Credo’s Clients being unfairly disadvantaged, legal action, and censure from regulatory bodies, and ensure that Credo conducts business in an ethical and appropriate way.

Conflicts of Interest can occur where an individual member of staff, or Credo, has a business or personal interest which potentially competes with an interest of a Client or that of Credo itself. That competing interest can make it difficult for individuals or Credo to fulfil their duties impartially. Even where there is no evidence of improper actions, a conflict of interest can create the appearance of impropriety, which could undermine confidence in the ability of Credo or its staff to act properly and fairly.

Credo must assess the material conflict scenarios prevalent within the business to ensure that there are sufficient procedures and measures in place to negate the conflict.

We are required to identify those circumstances which are likely to give rise to a conflict of interest between (1) Credo or persons connected to a Group Company (as defined in 3.1) on the one hand and a Client on the other hand and (2) conflicts as between the differing interests of one or more Clients in the carrying on of Credo’s services and activities in the ordinary course.

Credo, and its appointed representative are required to operate effective organisational and administrative arrangements to ensure that reasonable measures are in place to prevent conflicts of interest causing material risk of damage to the interests of its Clients, for example, through the use of Chinese walls, appropriate disclosure channels or where appropriate, from declining to act. When a conflict arises that entails a material risk a record must be kept and regularly updated.

3. Application and Fair Treatment

3.1. Normally we do not take positions or deal on our own account. However, a conflict could arise where we, or a company in the Credo Group (i.e. our holding company and its subsidiaries (a Group Company)) or some other person connected with us (including an employee, Director or Independent Investment Partner (IIP) of Credo):

3.1.1. is likely to make a financial gain, or avoid a loss, at the expense of a Client;

3.1.2. has an interest in the outcome of a service provided to, or transaction carried out on behalf of, a Client that is distinct from the Client's interest;

3.1.3. has a financial or other incentive to favour the interest of one Client or group of Clients over the interests of another Client;

3.1.4. carries on the same business as the Client; or

3.1.5. receives, or will receive, an inducement from a third party in relation to a service provided to the Client that is different from the standard commission, or fee, for that particular service.

3.2. Although we only provide restricted advice, we do offer a wide range of financial and investment advisory services, investment management services, securities trading and brokerage services and other commercial and investment products and services to a wide range of individuals and organisations and as a result we or any Group Company may at times have interests which conflict with those of our Clients. We aim to treat our Clients fairly, suitably and appropriately. One of the ways in which we seek to achieve these aims is to have regard to the conflicts of interest that may arise through our business activities where such conflicts may involve the risk of damage to our Clients.

3.3 As set out above and in order to comply with the provisions of the FCA Rules we are required to maintain and operate effective organisational and administrative arrangements with a view to taking all necessary and appropriate steps to identify, monitor and manage such conflicts of interest. We have put this Policy in place to meet this obligation and set out below a summary of that Policy and the key information that is needed by Clients to understand the measures we are taking to safeguard the interests of our Clients.

3.4 Our internal policies and procedures are designed to ensure that we identify potential conflicts of interest that arise or may arise between us and our Clients and between one of our Clients and another.

3.5 The circumstances in which such a conflict of interest or potential conflict of interest may arise, include, but are not limited to, where we or any of our associates (as defined in section 345 of the Companies Act, 2006) (including any Group Company) may:

3.5.1. act on behalf of a Client, as agent and also act for an associate (including any Group Company) or a third-party investor in the same transaction, or act as a distributor of an investment and receive a benefit, including a placement fee, commission, rebate or reduction (whether from standard rates of commission or otherwise), in connection with any service or transaction provided or entered into. Where we are not prohibited by any relevant rules of the FCA, we may retain such benefit and we undertake to provide the Client with further details of any such benefit that we receive on request;

3.5.2. act in relation to investments where any of us is involved in a new issue, rights issue, takeover or similar transaction concerning the investments;

3.5.3. act in relation to investments where it or any director or staff member may hold an interest or shareholding in the Issuer of the securities or the entity that is facilitating the investment;

3.5.4. invest a Client in or advise a Client to invest in a fund(s) of which we are the investment manager;

3.5.5. execute a transaction for or with a Client in circumstances where we have knowledge of other actual or potential transactions in the relevant investment;

3.5.6. hold a position in, or trade, deal or make markets in, investments purchased or sold by a Client;

3.5.7. recommend the purchase or sale of a designated investment in which one of our Clients has given instructions to buy or sell;

3.5.8. act as adviser to, or have any other business relationships with, or interest in, the issuer (or any of its associates or advisers) of any investments purchased or sold by a Client or advise any person in connection with a strategic transaction in relation to such investments, including but not limited to, a merger, acquisition or takeover by or for any such issuer (or associates or advisers);

3.5.9. recommend the purchase or sale of a designated investment in which we have the opposite position; or

3.5.10. in exceptional circumstances and where a Group Company is dealing as principal for its own account, buy or sell the investment concerned and therefore make a profit (or loss) or take a mark-up, mark-down or credit for its own account.

4. Managing Conflicts

4.1 We have implemented and maintain a number of procedures and measures for preventing or where appropriate, managing conflicts of interest that arise in the course of our business. Such measures may include, but are not limited to, the following:

4.1.1. where appropriate, structural separation which may be physical or otherwise, including but not limited to information barriers;

4.1.2. compensation arrangements and/or management and supervisory structures which are aligned with this Policy;

4.1.3. oversight of contacts between and within business units whose Clients have adverse or competing interests with the Clients of other business units;

4.1.4. where Credo is entitled to receive a fee from a third party, it will only do so in compliance with the FCA Rules;

4.1.5. regulation of personal investment and business activities of our employees by our Compliance Department to prevent conflicts of interest arising against the interests of Clients; and

4.1.6. disclosure on the website, in Credo's Terms of Business, in any specific information document and/or in person, that conflicts of interest situations may arise and by accepting those Terms of Business or the specific investment, the Client agrees that he/she/it does not object to a conflict of interest that is specifically disclosed.

4.2 Where these measures are not sufficient to ensure, with reasonable certainty, that risks of damage to the interests of one or more Clients will be prevented, we will be required to clearly disclose the general nature and sources of the conflict(s) and to disclose the steps taken to mitigate those risks, in relation to the Client(s) concerned, before undertaking business with or for the Client(s). The nature of the disclosures must:

4.2.1. be made in a durable medium;

4.2.2. clearly state that the organisational and administrative arrangements established to prevent or manage that conflict are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the Client(s) will be prevented;

4.2.3. include specific description of the conflicts of interest that arise in the provision of investment services or ancillary services;

4.2.4. explain the risks to the Client(s) that arise as a result of the conflicts of interest; and

4.2.5. include sufficient detail, taking into account the nature of the Client(s), to enable that/those Client(s) to take an informed decision with respect to the service in the context of which the conflict of interest arises.

4.3 We treat the disclosure of conflicts as a measure of last resort to be used only where the effective organisational and administrative arrangements established by us, to prevent or manage conflicts of interest, are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the Client(s) will be prevented.

4.4 If we believe there is no practicable way of preventing damage to the interests of one or more Clients, we may decline to act.

4.5 Subject to the circumstances set out in section 3.1 above, which may result in conflicts of interest, we require our Clients to agree that we and any relevant Group Company may provide the relevant services despite any such interest and that we are not required to account for any income, gain, profit, benefit or other advantage arising from doing so, provided that we do not contravene the FCA Rules.

4.6 Group Companies and/or their employees may make markets or specialise in, have positions in and effect transactions in securities of companies and may also perform or seek to perform investment advisory or corporate finance activities for those companies. As a result, we may not be able to advise or deal for Clients in certain investments and we reserve the right at any time in our absolute discretion to decline to deal or arrange any transaction or give advice or make any recommendation.

4.7 Where we act as an intermediary for packaged products (such as collective investment schemes and/or close ended companies), we may advise a Client and/or buy or sell units for a Client in, any packaged products, including those where we are or a Group Company is the trustee, operator, manager, administrator or an adviser of/to the scheme.

4.8 Where we have a discretionary or advisory mandate from a Client and invest or advise the Client to invest some or all of their assets in a Credo fund (where we are the investment manager) such as the Credo Dynamic fund, Credo Global Equity fund and the Credo Growth fund (an in-house fund), there could be a conflict of interest which must be managed.

4.8.1. However, for Clients who want an investment based on Credo’s investment methodology (CIM), there will not be a conflict where the in-house fund essentially reflects the CIM, where it is the same investment methodology used for Credo’s segregated model portfolios. Credo will always act in a Client’s best interests in making any recommendation to invest in an in-house fund and where it is a suitable investment, Credo’s intention is that Clients invest in an in-house fund in preference to its segregated model portfolios, save where the Client wishes to invest or we believe the Client should invest in an asset class that our in-house fund(s) do not cover. In any event and whether or not an in-house fund reflects the CIM, we will assess on an annual basis whether the investment remains suitable, and such an assessment may include a review of other similar funds.

4.8.2. We recognise that there could be conflicts between the trading undertaken by the in-house funds, the Credo model-portfolios, Client bespoke portfolios and personal account (PA) dealing and we have controls in place to mitigate the risk of such conflicts, e.g. the fund managers take into account whether a particular trade decision is suitable for all Clients with the same risk profile, but because of the portfolio construction rules applicable to the in-house funds, their holdings may be different; no PA dealing may be undertaken in the opposite direction to an in-house fund unless there are good reasons and the necessary approval has been obtained; trading for the in-house funds and the model portfolios which have the same risk profile will as far as possible be the same, save for timing differences.

4.9 We may match a Client’s transaction with that of another Client by acting on his/her/its behalf as well.

4.10 We may recommend or buy investments where we are or a Group Company is involved in a new issue, rights issue, takeover or similar transaction concerning the investment and/or where we or a Group Company has given advice to the issuer.

4.11 We will be entitled from time to time, at our absolute discretion, to delegate to any person or entity the performance of any of our duties, functions or powers. If required by any applicable regulations, the appropriate details of any delegation will be provided to Clients.

5. Updating the Policy

How often will we update the policy?

We will update the Policy periodically to take into account changes as and when appropriate.

How can Clients obtain the most recent version of the Policy?

The most recent version of the Policy is dated July 2023 and is published on the Credo website at www.credogroup.com. If a Client would like to receive a copy, they may contact us in the manner described in section 6.

6. Consenting to this Policy

We are required to obtain a Client’s written consent to this Policy before we undertake any transaction or provide any service to them. Client consent will be given in the Declarations and Signatures section in our Application Form and is deemed to refer to the most current version of this Policy.

7. Contact Details

How does a Client contact us in connection with this Policy?

If a Client has any queries about the Policy, they may contact our Head of Compliance via email to wpullin@credogroup.com or at the address below:

Head of Compliance
Credo Capital Limited
8-12 York Gate, 100 Marylebone Road
London NW1 5DX
Tel: +44 (0)20 7968 8300

Order Execution Policy

Order Execution Policy Version 5.0, as at December 2025 Introduction This Order Execution Policy (Policy) summarises the general basis on which Credo Capital Limited (referred to hereafter as we, us or our) will provide "best execution" as required by the European Union's Directive 2014/65/EU on markets in financial instruments and Regulation (EU) No 600/2014 on markets in financial markets (referred to collectively as MiFID II) as it applies in the UK and the Conduct of Business Rules of the UK Financial Conduct Authority (FCA Rules) to all retail and professional clients. The Policy is divided into fifteen sections: 1. Scope and Purpose 2. Achieving Best Execution 3. Choosing an Execution Venue 4. Order Handling 5. Compliance with Client Instructions 6. Methods of Execution 7. General Dealing Arrangements 8. Monitoring and Review 9. Market Hours 10. Fees and Charges 11. Conflicts of Interest 12. Limit Orders 13. Orders Executed outside a Regulated Market 14. Consenting to the Policy 15. Contact Details Annex A: List of Execution Venues 1. Scope and Purpose What is the purpose of the Policy? We recognise the importance of achieving the best possible result on a consistent basis when executing trades for you. This is important for maintaining and developing our relationship with you. We strive at all times to act fairly and reasonably in dealing with you. In certain cases where we are providing order execution services to our clients, we are required under MiFID II and the applicable FCA Rules to establish and comply with a policy on order execution. The purpose of this Policy is to set out our obligations to you in a clear and concise manner. When does this Policy apply? This Policy applies where we carry out orders in Financial Instruments (as defined by MiFID II*) for retail and professional clients, whether by executing such orders on a client’s behalf, or transmitting them to a third-party firm for execution (on which see section 2). For example, this will be the case when we: execute our client’s order by dealing as agent; and as agent, “work” an order on our client’s behalf, which occurs where our client’s place an order with us and we execute it over a period of time using one or more execution venues. The financial instruments covered by MiFID II include most financial instruments but do not include: spot foreign currency exchange transactions; or spot commodity derivative transactions. (*) The full definition can be found at https://www.handbook.fca.org.uk/handbook/glossary/G1519 2. Achieving Best Execution We operate centralised trading desks (“Desks”) for each financial asset class, such as equities, fixed income, foreign exchange, or collective investment schemes (Funds). The Desks are comprised of experienced investment professionals who use their commercial judgement and available market information to direct order flows to the most appropriate counterparties and venues. All of our employees who perform a Certification Function (Certified Persons) are required to be assessed as fit and proper in advance of performing their role and at least once a year after commencing in their role. This is required under the FCA’s Senior Managers and Certification Regime which came into effect on 9 December 2019. We have internal processes and controls in place to establish the initial and ongoing fitness and propriety of our Certified Persons, including the assessment of threshold competency to perform their role and evidence of their continued professional development as part of our training and competency requirements. What does "best execution" mean? "Best execution" means that we: have a set policy (namely this Policy) which is designed to achieve the best possible result (taking into account all relevant execution factors as described below) across all orders on a consistent basis for any financial instrument covered by MiFID II when placing the orders for execution; are committed to complying with the Policy; and take steps to monitor, review and update the Policy to ensure it continues to achieve the required results. Complying with our best execution obligations under MiFID II does not involve a transaction-by-transaction analysis. Instead, we are required to take all sufficient steps to obtain the best possible result overall when executing orders on your behalf having regard to the execution factors set out in MiFID II and the applicable FCA Rules. What factors do we take into account to achieve best execution? In achieving best execution, we take into account a number of execution factors (unless otherwise instructed by our client, as discussed in section 5 below). These include: price; costs; speed of execution; likelihood of execution (liquidity) and settlement; size and nature of the order; likely market impact; type and characteristics of financial instrument; characteristics of the possible execution venues; nature of the client (retail/professional); and any other consideration relevant to the execution of the order. We generally treat price as the most important factor for obtaining the best possible result. However, the overall value to our client of a particular order may be affected by the other factors listed above. In determining the relative importance of these factors, we will use reasonable judgment together with our understanding of the appropriate execution criteria for the specific order. For example, when transacting a large order, minimising market impact might be more important than price or, when trading an illiquid product, certainty of execution might be more important than price. We may therefore conclude that factors other than price and costs are more important in achieving the best possible result for you. The relative importance of each of the factors will differ depending on the following execution criteria: whether our client is categorised as a retail or professional client and any special objectives he/she may have in relation to the execution of the order; the characteristics of our client order; the characteristics of the financial instruments to which our client order relates; and the characteristics of the venues (if there is more than one) to which our client order may be directed. What is our responsibility when our client order is executed for us by a third party? To achieve best execution on an order we may use a third-party broker to provide access to markets where we otherwise may not be able to execute or where we believe it to be in our client’s best interests to do so, for e.g., to source liquidity or to access an algorithm. Where we owe best execution on an order and that order is passed to a third-party broker that has discretion over the execution of any aspect of such order (either in whole or in part), we will be relying on the third-party broker to execute the order in a way which enables us to meet our best execution obligation. We will monitor the execution and carry out due diligence on such third-party brokers to ensure that we are satisfied that they are enabling us to comply with our best execution obligations. 3. Choosing an Execution Venue Which execution venues will we use? A list of the execution venues and third-party brokers which we place significant reliance upon to enable us to obtain best execution on a consistent basis can be found in Annex A below. This list may be updated from time to time; our clients will not be notified separately of any changes to this list. We will regularly review the venues or third-party brokers utilised, taking into consideration the factors we describe below for determining the entities with which the orders are placed, or to which we transmit orders for execution, in order to ensure that the venues/brokers that we use are providing best execution, taking into account all orders executed during the review period. Where it appears in a particular case that better execution is available from an execution venue or third-party broker that we do not ordinarily use, we may use such other execution venue or third-party broker on a case-by-case basis. What factors are taken into account in determining the execution venues? Factors which we consider in selecting the entities with which our clients’ orders are placed or to which we transmit their orders for execution in respect of a particular financial instrument include: general prices available; depth of liquidity; relative volatility in the market; speed of execution; cost of execution; creditworthiness of the counterparties on the venue or the central counterparty; and quality and cost of clearing and settlement. Where applicable, we will take steps so that we do not structure or charge our commissions in such a way as to discriminate unfairly between execution venues. Where we have a choice of venues in respect of a particular order, how do we choose? We take into account factors such as costs and benefits of accessing multiple venues and accessibility in deciding which venues we use. In certain circumstances, we may have access to more than one venue for executing an order in a particular financial instrument. In such cases, we will endeavour to choose the best venue for the order taking into account the factors applicable to choosing venues. How often do we review our venues? Generally, we will review the venues we use to execute your orders on an annual basis. 4. Order Handling What procedures are in place for handling client orders? In accordance with the FCA’s Rules, we are required to have procedures and arrangements in place that provide for the prompt, fair and expeditious execution of orders. Orders must be executed sequentially and promptly, unless this is impracticable given the characteristics of the order, market conditions or if the interests of the client require otherwise. We may combine a client order with orders made for other clients. By combining the orders we must reasonably believe that this is unlikely to disadvantage any client and sufficient prior disclosure is therefore made in this Policy that the effect of aggregation may work to a client’s disadvantage, but the intention is to ensure that no consistent patterns of disadvantage are developed. As such, aggregation may result in our client obtaining a less favourable price in relation to a particular order. In the usual course, all executions of aggregated orders will be allocated in accordance with the original intended allocation recorded on the trading record at the time the orders are approved. In the event of an order being scaled back, the executed order will normally be allocated to clients on a pro-rata basis. There may be circumstances, however, where a pro-rata allocation is suboptimal, for instance, where the total allocation is significantly scaled back, which could leave certain clients with holdings that are either uneconomical or cannot be allocated as they fall below the minimum piece size. A client may not receive an allocation in accordance with the original intended allocation, for the reasons described above. 5. Compliance with Client Instructions What happens if a client gives us specific instructions as to how to execute his/her order? Where we owe our clients a duty of best execution and they provide us with specific instructions in relation to the entire order, or any particular aspect of the order, which we accept, then we will execute the order in accordance with those instructions and in doing so we will have satisfied our best execution obligations with respect to the relevant aspects of the order. Where the client’s instructions relate to only part of the order, the remaining element of the order not covered by the specific instructions will, subject to the following paragraph, remain subject to best execution requirements. Please note that if a client provides us with specific instructions this may change the way in which we execute his/her orders and may prevent us from taking the steps that we have designed and implemented in this Policy to obtain the best possible result for the execution of in-scope orders. We reserve the right to refuse to implement specific instructions from our clients regarding the execution of their orders where, in our opinion, such instructions are not practicable or may be contrary to their best interests. 6. Methods of Execution What methods of execution can be used to complete an order? Subject to any specific instructions that may be given by our client (see section 5), we will execute an order by one of the following methods or a combination thereof: i. On a Regulated Market, Multi-lateral Trading Facility (MTF) or Organised Trading Facility (OTF) by: executing the order directly on a Regulated Market, MTF or OTF or where we are not a direct member of the relevant Regulated Market, MTF or OTF, with a third-party broker; or executing the order with, or transmitting it for execution to a liquidity provider that forms part of a Regulated Market, MTF or OTF; or executing the order with a matching order from another client under the rules of a Regulated Market, MTF or OTF. ii. Where we have obtained prior express consent from our client (section 12 below), outside a Regulated Market, MTF or OTF by: executing the order with, or transmitting it for execution to a liquidity provider that is not part of a Regulated Market MTF or OTF; or executing the order with a matching order from another client outside the rules of a Regulated Market, MTF or OTF. iii. In respect of a financial instrument not admitted to trading on a Regulated Market, MTF or OTF, we will carry out our client’s order in the manner that we consider the most appropriate. We will endeavour to check the fairness of the price by gathering market data used in the estimation of the price of such financial instrument and, where possible, by comparing it with similar financial instruments. 7. General Dealing Arrangement What execution methods are used for dealing in the various asset classes? The following information will demonstrate in more general terms how we execute orders for more commonly traded financial instruments: i. Equities (including Investment Trusts, Exchange Traded Products (ETP) Warrants and Depository Receipts): Assuming normal market conditions, we will typically select counterparties by operating on a request for quote (“RFQ”) basis taking into account the execution factors. In practice, RFQ means making a direct approach to an entity in order to request a firm price or spread at which that entity is willing to buy or sell a specific financial instrument. When executing orders using this method, price will normally be the most significant factor. However, there may be circumstances, where opting for the RFQ method, may alert the market to our trading strategy which could be detrimental to our clients. In such circumstances, larger and/or illiquid orders that exceed the pre-set parameters, and/or cannot be executed via the RFQ network, will be manually executed via the Equities Desk. Subject to the execution criteria, execution factors, the complexity of the order and any specific client instructions, our dealers will determine how best to execute the order to achieve the best outcome. This may be via: the RFQ network; and/or direct negotiation with registered market makers or other member firms of the London Stock Exchange (LSE) exchange (capital commitment from the counterparty could be utilised, this is a situation where the counterparties will be called upon to go ‘on risk’ to facilitate Credo executing its business in large order size. Credo will consider both size and the counterparties’ perceived ability to locate natural business in the stock and the willingness to commit capital to facilitate the execution of its clients’ business); and/or transmission to a third-party broker that will provide access to electronic communication networks (ECNs), crossing platforms, algorithmic trading strategies, systematic internalisers (SIs) and other execution venues that we cannot access directly; and/or by agency cross, where we match buyers and sellers internally. Larger or more complex orders may need to be worked over a period of time and might be executed using a combination of the above. ii. Debt securities (such as Government Bonds (Gilts) and Corporate Bonds): For fixed income transactions, liquidity and price are typically the primary determining factors given the nature of the securities, as well as the size of transaction. The best price in a market usually represents an opportunity to trade in a particular size, and should an order be above that size then the order may have to be split, or we may decide to execute with a single counterparty, if a better overall price can be achieved. When a large order is split, there is potential for information leakage which may lead to the price for subsequent executions becoming less favourable. Secondary factors will also direct us to use a particular counterparty. These include speed of execution, market positioning and the likelihood of execution and settlement. Counterparties are also selected based upon additional factors, including but not limited to, the credit quality of a counterparty, client instruction, price or any other limit value, or the underlying market conditions. We will typically select counterparties by operating on a RFQ basis taking into account the execution factors. Larger and/or illiquid orders that exceed the pre-set parameters, and/or cannot be executed via the RFQ network, will be manually executed via the Fixed Income Desk. Quotations are available from competing venues and trades will be concluded through the counterparties where best execution can be obtained taking into account the criteria above. The Fixed Income Desk will take into consideration market levels by utilising alternative pricing and valuation sources where quotations are not available to determine how best to execute the order to achieve the best outcome. This may be via: the RFQ network; and/or direct negotiation with registered market makers or other member firms of the LSE exchange (capital commitment from the counterparty, a situation where the counterparties will be called upon to go ‘on risk’ to facilitate us executing its business in large order size. We will consider both size and the counterparties’ perceived ability to locate natural business in the stock and the willingness to commit capital to facilitate the execution of its clients’ business); and/or transmission to a third-party broker; and/or by agency cross, where we match buyers and sellers internally. Larger or more complex orders may need to be worked over a period of time and might be executed using a combination of the above. Debt securities often have a minimum tradable size; if an order is placed that does not meet the minimum tradable size then the Desk will notify the client. The client can either elect to cancel the trade or provide the Fixed Income Desk with specific instructions if they wish to continue with the trade on an ongoing basis. iii. Collective Investment Schemes (Open Ended Investment Companies/Unit Trusts/Hedge Funds): For transactions in the shares or units of Collective Investment Schemes, the sole point of execution will be via our custodian who will transmit the order with the scheme manager, or their agent and the price will be established according to the scheme’s particulars or prospectus. Orders will be placed with the relevant single venue in accordance with our cut off times to meet the next valuation point of the scheme in question at the quoted price. Clients should be aware that if there is no existing relationship between our custodian and the scheme manager, or their agent, further documentation may be required, and this could delay the investment. iv. Structured Products: Structured products are executed directly with the product provider or via a specialist broker. v. Traded Options (Exchange Traded Options only): All orders will be executed via ADM Investor Services International Limited which is obliged to provide best execution. vi. Foreign Exchange (FX): FX trades are only permitted in facilitation of a currency conversion or the settlement of a security trade in accordance with the permitted currencies. For the avoidance of doubt, proprietary FX trading or FX trading for investment or speculative purposes is not permitted. Standalone FX forwards (>T+5) are therefore not permitted. All orders will be executed promptly with the relevant custodian. We will endeavour to aggregate orders to reduce your costs. Our default settlement period for FX transactions is T+1 unless we are informed otherwise by our client’s. vii. Other Asset Classes: We will execute all other trades in an appropriate manner recognising the importance of achieving the best possible result on a consistent basis when executing trades for our clients. 8. Monitoring and Review Monitoring We monitor the effectiveness of our execution arrangements and this Policy on a regular basis and assesses whether the execution quality and price achieved generally obtains the best possible result for clients. The monitoring of best execution is performed by the Trading Desk as part of the first line of defence with oversight by the Head of Trading. In addition, our compliance team monitors best execution as part of the second line of defence. The following information will demonstrate in more general terms how we monitor orders for more commonly traded financial instruments: i. Equities (including Investment Trusts, ETPs, Warrants and Depository Receipts): In order for us to meet the regulatory, monitoring and performance reporting requirements, we utilise an exception based price / basis point (BPS) approach. Exception based price monitoring uses price and BPS tolerances to identify trades which have been executed outside a specific range compared to various benchmark prices. The price and BPS tolerance ranges are set or agreed by our Head of Trading and are ratified by our compliance team. Tolerances are determined using independent third-party Transaction Cost Analysis (TCA) tools and an ex-post review of our trading activity. Exception reports are generated to identify trade executions that are outside the market price / benchmark price tolerance range, or where no comparable quote has been obtained. For those trades where no market price / benchmark is available, we will analyse the available data and competing spreads from the universe of available counterparties to model a transaction and establish a price position. Our dealers and Head of Trading review the trades and the corresponding execution factors documented at the point of trade, which resulted in the price achieved, to validate that a good outcome has been achieved for the client. ii. Debt securities (such as Government Bonds (Gilts) and Corporate Bonds): We regularly monitor the quality of the execution against an appropriate benchmark to ensure a good outcome has been achieved for the client. Execution quality monitoring for debt securities is performed on a sample basis by our compliance team. Exceptions to the set parameters will be highlighted and where appropriate, additional controls will be implemented in order to avoid future exceptions. We maintain an audit trail for all executed orders in the past 12 months which assists us in ascertaining whether the best possible results have been achieved. The results of our monitoring allow us to identify and implement changes to this order execution policy and arrangements as we deem necessary. How often will we update the Policy? This Policy is reviewed at least annually and may also be updated periodically to take account of any changes to the applicable regulation or otherwise. How can you obtain the most recent version of the Policy? The most recent version of the Policy is published on our website, but if you would like to receive a hard copy of the Policy, please contact us in the manner described in section 15 below. 9. Market Hours Our dealing team is available from 8am to 5pm during UK business days. If an order is submitted outside of these hours then we will execute on a reasonable endeavours basis, but clients should have no expectations that we will do so outside of our regular trading hours. 10. Fees and Charges The fees and charges for all asset classes are disclosed to the client in advance via the fee schedule. To obtain a copy of the fee schedule, contact the Client Services Department on +44 (0) 207 968 8300 or via email clientservices@credogroup.com quoting the relevant client account details. To enable us to offer clients access to markets where we are not members and/ or to access certain algorithms, a third-party broker may be utilised. Any additional charges will be passed on to the client with full transparency and disclosed in the contract note. Please be aware that the charges may vary according to the execution venue. For further information in this regard, please contact the dealing team on +44 (0) 207 968 8400 or via email dealers@credogroup.com. 11. Conflicts of Interest We are responsible for ensuring that our systems, controls and procedures are robust and adequate in order to allow us to identify and manage any conflicts of interest that may arise. In general, we arrange our business to minimise the potential for such conflicts and where they do arise we manage such conflicts to ensure that our own interests are never put ahead of those of our clients and that one group of clients is not treated more favourably than another. We have established procedures which are designed to identify on an on-going basis any conflicts of interest that may arise. Controls and procedures are implemented to ensure that the interests of the client are never compromised. Our Conflicts of Interest Policy details the types of conflict that may arise and how they are managed should they occur. This process is overseen by our compliance team and a copy of our Conflicts of Interest Policy can be accessed via the above tab ‘Conflicts of Interests Policy’. If the arrangements made to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that the risk of damage to the client’s interests will be prevented, we will clearly disclose the general nature and/or sources of the conflicts of interest to the client before undertaking business for that client. 12. Limit Orders We will not immediately make public any limit order in respect of shares admitted to trading on a market which is not immediately executed under prevailing market conditions. Our clients will have provided their consent to this when they signed the application form to become a client or via the regular Know Your Customer (KYC) updates we will have sent to our clients since we believe it is in their best interests to allow us to exercise our discretion in accordance with this Policy, failing which we cannot provide our investment service to them. 13. Orders Executed outside a Regulated Market In order for us to achieve the best possible results for each order when we execute them on our clients’ behalf, we may sometimes seek to place the orders with an execution venue other than a Regulated Market, MTF or OTF. However, for a Financial Instrument that is admitted to trading on a Regulated Market, MTF or OTF, we are required to obtain our clients’ prior express consent before we execute an order in such a Financial Instrument outside a Regulated Market, MTF or OTF and our clients will have provided their consent when they signed the application form to become a client or via one of the KYC updates, failing which we cannot provide our investment service to them. 14. Consenting to the Policy We are required by the FCA Rules to obtain prior consent from our clients to be bound by to this Policy. Once a client signs the application form to become our client, we ask him/her to confirm (in the Declarations and Signatures section) that he/she accepts this Policy. 15. Contact Details How do you contact us in connection with this Policy? If you have queries about this Policy, please contact our Head of Compliance at the address below or send an enquiry via email to _ComplianceTeam@credogroup.com. Head of Compliance Credo Capital Limited 8-12 York Gate 100 Marylebone Road London NW1 5DX Tel: +44 (0)20 7968 8300 ANNEX A: LIST OF EXECUTION VENUES Detailed below is a list of the execution venues and third party brokers, on which we currently place significant reliance in meeting our best execution obligation. The list is not exhaustive and we may execute on alternative venues or with other third party brokers so long as such venues are appropriate and consistent with this Policy. Types of Instrument Venues/Brokers Considered UK Equities (Investment Trusts, Warrants and Depository Receipts) All LSE Member Firms International Equities (Investment Trusts, Warrants and Depository Receipts) Jefferies LLC/Intl Ltd Barclays Bank plc/Capital Inc Structured Products Product provider or specialist broker Exchange Traded Products All LSE Member Firms Bloomberg Trading Facility Ltd Tradeweb Markets LLC Collective Investment Schemes (including Unit Trusts, Open Ended Investment Companies, Hedge Funds) The fund managers/administrators of the relevant Collective Investment Schemes Traded Options (Exchange Traded Options only) ADM Investor Services International Ltd Debt Securities (Government & Corporate Bonds) All LSE Member Firms Bridport & Co (Jersey) Ltd RIA Capital Markets Ltd Guy Butler Ltd King & Shaxson Ltd Bloomberg Trading Facility Ltd Tradeweb Markets LLC

Whistleblowing Policy

Version 2.2, as at January 2023

1. Introduction and Background

1.1 This policy details how Credo Capital Limited (the Company) all employees, workers, contractors, agency workers, consultants, interns and the like working at the Company and directors and members of the Company (the “Employees”) should disclose any concerns they may have about any aspects of the Company’s activities.

1.2 Whistleblowing is protected by law under the Public Interest Disclosure Act 1998 (the Act). The stated objective of the Act is ‘to protect individuals who make certain disclosures of information in the public interest; to allow such individuals to bring action in respect of victimisation; and for connected purposes.’ The Act applies to people at work raising genuine concerns about crimes, civil offences (including negligence, breach of contract, breach of administrative law), miscarriages of justice, dangers to health and safety or the environment and the cover up of any of these.

1.3 The Company is authorised by the Financial Conduct Authority (the FCA) and, as such, will act in accordance to the Whistleblowing rules as defined in the FCA Handbook, which will take precedence over the requirements of this policy.

2. Review of this Policy

This policy will be reviewed regularly, at least once a year, and amended as considered necessary by the Company’s Compliance Committee (ComplCo), in the event of changing circumstances or regulations.

3. Responsibilities

3.1 The Company has appointed its Legal and Compliance Director, currently Debra Chalmers, Senior Management Functions (SMF) 3, 16 and 17, as its whistleblowing champion. The Company will ensure that the whistleblowing champion has a sufficient level of authority and independence within the Company and access to the necessary resources and information to enable him/her to carry out his/her responsibilities.

3.2 Where there is a potential conflict with the whistleblowing champion and the department and/or function that is in question Gareth Crosland (SMF 3), shall act as the whistleblowing champion in respect of that issue until he is satisfied that the matter has been resolved.

3.3 The whistleblowing champion has the responsibility for ensuring and overseeing the integrity, independence and effectiveness of this policy and procedure.

3.4 Employees are encouraged to disclose any and all issues falling within the types of matters to be disclosed in Section 4 below.

4. Types of Issues that can be Raised

4.1 Under the Act, Employees can make protected disclosures. This means any disclosure of information which, in the reasonable belief of the Employee making the disclosure, tends to show one or more of the following:

That a criminal offence has been committed, is being committed or is likely to be committed;
That a person has failed, is failing or is likely to fail to comply with any legal obligation to which he/she is subject;
That a miscarriage of justice has occurred, is occurring or is likely to occur;
That the health or safety of any individual has been, is being or is likely to be endangered;
That the environment has been, is being or is likely to be damaged;
That information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.

4.2 For the purposes of the above disclosures, it is immaterial whether or not the information is confidential and whether the malpractice is occurring in the UK or overseas.

5. Recipients of the Disclosure

5.1 The Act protects disclosures made to the following persons:

The relevant employer;
A legal adviser in the course of obtaining legal advice;
A prescribed person such as the FCA.

5.2 To disclose issues to the wider public like the police or the media, the whistleblower will be protected to the extent that:

The whistleblower reasonably believes he will be victimised if he raises the matter internally or with a prescribed regulator; or
There is no prescribed regulator and he reasonably believes the evidence is likely to be concealed or destroyed; or
The concern had already been raised with the employer or a prescribed regulator; or
The concern is of an exceptionally serious nature.

6. Protections under the Act

6.1 Under the Act an Employee has the right not to be subjected to any detrimental effect by any act, or any deliberate failure to act, by the Company on the grounds that the Employee has made a protected disclosure. Where a whistleblower is victimised, or dismissed in breach of the Act, he/she can bring a claim to an employment tribunal for compensation.

6.2 As a responsible firm, the Company is committed to good practice and the highest standards of protection for the whistleblower. The Company will not tolerate any harassment or victimisation of a whistleblower (including informal pressure) and will take appropriate action to protect Employees when they raise a concern in good faith and will treat any harassment as a serious disciplinary offence which will be dealt with under the Company’s disciplinary rules and procedure.

7. Raising a Concern

7.1 Employees may report disclosable concerns to the Company, the FCA or both. It is not a requirement that reports are made to the Company before reporting to the FCA.

7.2 Concerns may be raised to the Company by telephone, in person or in writing.

Telephone: Please call +44207 968 8300;
In writing: Send an email to dchalmers@credogroup.com or by post to the Legal and Compliance Director, Credo Wealth, 8-12 York Gate, 100 Marylebone Road, London NW1 5DX;
In person: Please raise it to your immediate line manager, or if deemed inappropriate, to the Company’s Legal and Compliance Director.

7.3 If you are uncomfortable with raising the issue internally at the Company, then you are able to seek advice from the independent charity, Protect (Whistleblowing Advice) Limited (PWAL) which provides free, legal and confidential advice. For Whistleblowing advice from PWAL, call 020 3117 2520.

7.4 Concerns may be raised with the FCA as follows:

Call: +44 (0)20 7066 9200 during office hours or leave a message
Email: whistle@fca.org.uk
Post: Intelligence Department (Ref PIDA), Financial Conduct Authority, 12 Endeavour Square, London E20 1JN
Online: FCA Incident Report: https://fca.clue-webforms.co.uk/webform/fca/en

7.5 As part of the disclosure, the following details should be included where possible:

The names of any individuals involved in the misconduct;
Any key dates;
The ‘how’, ‘what’ and ‘where’ of any supporting documents or evidence;
The type of wrongdoing and who else knows about it;
It is not a requirement to be able to prove your suspicions beyond reasonable doubt.

8. Raising a Concern

8.1 The Company is committed to the highest levels of conduct with regards whistleblowing. All malpractice is taken seriously.

8.2 On receipt of a disclosure, the Company will investigate the matter fully and take any necessary action. The confidentiality of the Employee making the disclosure will be respected fully where so requested.

8.3 The Company also commits to ensuring that the Employee raising the concern is protected to the fullest extent possible from any harassment or other detriment as a result of making the disclosure. The Employee will be kept updated as to the progress of the investigation and the action taken to resolve the issue.

8.4 It is a disciplinary matter both to victimise a bona fide whistleblower and for someone to maliciously make a false allegation.

Further information

https://www.fca.org.uk/firms/whistleblowing

https://protect-advice.org.uk/a-guide-to-pida/

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