1. Overview and Summary

Eisler Capital (UK) Ltd (“Eisler”) is regulated by the Financial Conduct Authority (“FCA”) as a Markets in Financial Instruments (“MiFID”) firm and subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook.

For the purposes of MIFIDPRU, the Firm has been classified as a non-small non-interconnected (“SNI”) firm, therefore a non-SNI firm.

The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to non-SNI firms.

This Public Disclosure Document has been prepared based on the audited financials as at 31 December 2022, covering the financial period 1 January 2022 to 31 December 2022.

Eisler provides discretionary investment management for non-EU AIFs and employs a top-down investment process. The investment universe of the AIFs it manages include (but are not limited to) global interest rate and fixed income instruments, credit instruments, currencies, commodities, equities, and their associated derivatives. The AIFs are primarily invested in liquid instruments with short, medium and long-term investment horizons and utilise significant leverage in their investment program.

2. Governance arrangements

Eisler has established a risk management process in order to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the Chief Operating Officer, with the Firm’s Management Committee holding overall responsibility for the risk appetite of the Firm. The Management Committee is responsible for determining the strategic direction, senior-level hires, material issues and risk appetite of the Firm. This includes control of areas such as financial projections, business performance, strategic initiatives, recruiting, remuneration, compliance and regulation, and risk management and the control environment.

The Management Committee has established four key committees to assist it with its management and oversight responsibilities.

• Risk Management Committee: responsible for the drafting and implementation of the Firm’s risk policies. This includes identifying, measuring, analysing and monitoring the market risks at both a portfolio and individual trader level. The chair of this committee is the Chief Risk Officer.
• Operational Risk Committee: responsible for identifying and mitigating the risk of loss resulting from the Firm’s operations. Such risk may come from, amongst other sources, inadequate internal processes or policies, staff who fail to perform at the expected level and external events. It is chaired by the Deputy Chief Operating Officer.
• Conflicts Committee: The Conflicts Committee is responsible for the drafting, implementation and maintenance of Eisler’s Conflicts of Interest Policy. The Committee is responsible for ensuring that Eisler has appropriate and consistent procedures to identify, investigate, mitigate, remediate and disclose such conflicts of interest as may arise from time to time in the course of Eisler’s business.
• Valuation Committee: responsible for overseeing the drafting and implementation of the Firm’s Valuation Policy. It ensures that the Policy is applied fairly and consistently across various assets. It will also escalate valuation issues to the Firm’s and, if necessary, the clients’ boards. It is chaired by the Chief Financial Officer.

The Management Committee meets on a regular basis to discuss current projections for profitability, cash flow, regulatory capital, management, business planning, and risk management. There is a framework of policies and procedures having regard to the relevant laws, standards, principles, and rules (including FCA principles and rules) with the aim to operate a defined and transparent risk management framework. These policies and procedures are updated as required.

2.1. External Directorships

In line with MIFIDPRU 8.3.1 (2), the Firm has detailed below the number of external appointments, both as executive and non-executive roles of its Board of Directors members:

2.2. Promoting diversity and inclusion

The Firm promotes equality and diversity throughout its workforce and whilst the Firm does not have any active targets based on metrics, equality and equal opportunities are implemented into the Firm’s HR and recruitment processes.

3. Risk management objectives and policies

The Firm has implemented and embedded risk management framework, policies and procedures across all relevant risk areas of the Firm. The Board of Directors sets the business strategy and risk appetite statement of the Firm, which flows through to the risk management framework of the Firm.

In line with the Firm’s business strategy, risk appetite and risk management framework the Firm identifies and further assesses key risks within the Firm’s Internal Capital and Risk Assessment (“ICARA”) process.

The Firm maintains a risk register, which includes risk assessment and rating methodologies in accordance with its risk appetite statement. Key risks are reported to the Management Committee at each meeting.

3.1. Own funds requirements – MIFIDPRU 4

The Firm’s investments risks are captured within its K-AUM calculation and operational risks are predominantly captured within its Fixed Overhead Requirement (“FOR”) calculation. The Firm has further assessed any operational risks within its ICARA and quantified additional own funds and liquidity, where required.

3.2. Concentration risk – MIFIDPRU 5

The Firm does not conduct any trading on own account and does not have regulatory permissions for dealing as principal. The Firm therefore does not have any concentration risks on or off balance sheet and does not operate a trading book.

3.3. Liquidity – MIFIDPRU 6

The Firm maintains minimum liquidity at all times in compliance with the Basic Liquid Asset Requirement (BLAR), being at least 1/3 of its FOR.

The Firm does not provide any client guarantees and therefore its entire liquidity requirement is driven by its expenses, as captured by the FOR.

As part of the ICARA, the Firm also maintains liquidity to satisfy its net wind-down costs and any additional liquidity requirements which the ICARA identified for supporting the ongoing business activities of the Firm.

4. Own funds

4.1. Own funds resources

In line with MIFIDPRU 8.4 the Firm has prepared the reconciliation of own funds in line with MIFIDPRU 8 Annex 1 as follows:

4.2. Own funds requirements

The Firm calculates tis own funds requirements as a non-SNI firm in line with the rules and requirements in MIFIDPRU 4.3 for non-SNI firms.

In addition, the Firm has completed its ICARA and analysis to determine its net wind-down requirements and any additional own fund requirements to fund its on-going operations.

The Firm’s risk appetite statement and assessment of risks through its risk management framework and risk register form the basis of its ICARA and assessment of the overall financial adequacy rule in line with MIFIDPRU 7.4.7.

The Board of Directors reviews, challenges and approves the ICARA and conclusions of own funds requirements.

5. Remuneration arrangements

The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).

In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:

• The Firm’s remuneration policies and practices are reviewed annually to ensure they are appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the firm.
• The Board of Directors, as the Remuneration Committee, is directly responsible for the overall remuneration policy.
• The Firm ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all Staff.
• Variable remuneration is adjusted in line with capital and liquidity requirements as well as the firm’s performance.

Eisler does not benefit from exceptional government intervention.

Eisler’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categories as either fixed or variable remuneration.

Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.

Variable remuneration is based upon staff members performance or, in exceptional cases, other conditions.

Performance reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment, and:

• includes discretionary pension benefits; and
• includes carried interest, as referred to in SYSC 19G.1.27R.

Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit.

The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.

5.1. Quantitative Remuneration

All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded. As a non-SNI firm and in accordance with MIFIDPRU 8.6.8, Eisler is required to disclose the following information, as set out below:

For the performance year ending 31 December 2022: