# Barclays Investment Solutions Limited
# MIFIDPRU 8 Disclosure
# 31 December 2025

# MIFIDPRU Disclosure Requirements

MIFIDPRU 8 sets out the disclosure requirements for BISL as a non-SNI MIFIDPRU investment firm. The key areas for disclosure requirements are:

- Risk management objectives and policies (MIFIDPRU 8.2)
- Governance arrangements (MIFIDPRU 8.3)
- Own Funds (MIFIDPRU 8.4)
- Own funds requirements (MIFIDPRU 8.5)
- Remuneration policy and practices (MIFIDPRU 8.6)
- Investment policy (MIFIDPRU 8.7)

The MIFIDPRU 8 disclosure is required at an individual entity level.

It is acknowledged that in accordance with FCA rules, the firm’s parent, Barclays Bank PLC, has published Pillar 3 information on its remuneration, risk management objectives and policies and on its regulatory capital requirements and resources. This information is available at https://www.home.barclays/barclays-investor-relations/results-and-reports/annual-reports.html.

BISL applies the same general principles as set out in the BBPLC Pillar 3 disclosure.

The table below and the subsequent appendices 1-5 set out the disclosure requirements for BISL as a non-SNI MIFIDPRU investment firm.

| Disclosure Requirement | Reference |
| --- | --- |
| Risk management objectives and policies MIFIDPRU 8.2 | Appendix 1 |
| Governance arrangements MIFIDPRU 8.3 | Appendix 2 |
| Own funds MIFIDPRU 8.4 | Appendix 3: uses the template from MIFIDPRU 8 Annex 1R to disclose the information requested at MIFIDPRU 8.4.1R |
| Own funds requirements MIFIDPRU 8.5 | Appendix 4 |
| Remuneration policy and practices MIFIDPRU 8.6 | Appendix 5 |
| Investment policy MIFIDPRU 8.7 | N/A: This disclosure relates to investments where the shares are directly held on the entity balance sheet or has a voting right attached to a share in a fiduciary capacity. The Company deals in securities on behalf of clients, not on its own account and does not hold shares on its balance sheet. This disclosure is therefore considered not applicable for the Company. |

# Appendix 1: MIFIDPRU 8.2 Risk Management Objectives and Policies

The following information sourced from the Company’s financial statements and ICARA is disclosed with respect to MIFIDPRU 8.2 Risk management objectives and policies.

### Risk Management
The Company’s activities are exposed to a variety of financial and non-financial risks. As a subsidiary legal entity within the Barclays Group, the Company is required to follow the requirements of the Barclays Group risk management frameworks, policies and standards, which include specific guidelines on the management of foreign exchange, interest rate and credit risks, and advice on the use of financial instruments to manage them.

Risk is inherent in the business activities of the Company and whilst it is not possible nor desirable to eliminate risk altogether, uncontrolled risk poses a threat to the profitability of the Company and its potential long-term viability. The Risk Management Framework in place is developed and implemented to manage risk in a manner appropriate to the business activities and strategic objectives and to confirm there is sufficient capital to cover the risks to which the business is exposed whilst delivering successful outcomes for clients, safeguarding their interests and fulfilling regulatory obligations.

### Enterprise Risk Management Framework
For the Company, risks are identified and overseen through the Enterprise Risk Management Framework (ERMF), which governs the way in which Barclays and its subsidiary legal entities, including the Company, identifies and manages its risks.

The purpose of the ERMF is to:

i. Set out clear principles of risk management to protect the firm, our clients, customers and markets.
ii. Support the Chief Executive Officer (CEO) in embedding a strong risk culture within the firm by setting out clear risk management practices and requirements.
iii. Identify the Principal Risks faced by the firm.
iv. Describe the way in which the firm establishes its Risk Appetite and operates within it.
v. Delineate the key responsibilities of different groups of employees in enabling the firm to operate within its Risk Appetite (the Lines of Defence).
vi. Specify risk management accountabilities and responsibilities for key roles.
vii. Explain the role of Frameworks, Policies and Standards within risk management in implementing this Framework.
viii. Describe the governance for managing risk within the firm.

# Appendix 1: MIFIDPRU 8.2 Risk Management Objectives and Policies (continued)

### Principal Risks
The Company is exposed to internal and external risks from ongoing activities. These risks are managed as part of the Company's business model and are defined in the table below:

| Principal Risk | Barclays ERMF Definition | Applicability to BISL |
| --- | --- | --- |
| Credit Risk | The risk of loss to the firm from the failure of clients, customers or counterparties (including sovereigns), to fully honour their obligations to the firm, including the whole and timely payment of principal, interest, collateral and other receivables. | BISL is exposed to Credit Risk as part of its day-to-day business activities. Its main exposures are through trade debtors, settlement risk and counterparty risk on balances with Barclays Group entities. BISL has minor exposures to FX Risk as it settles payments for debtors and creditors in currencies other than GBP. |
| Market Risk | The risk of loss arising from potential adverse changes in the value of the firm’s assets and liabilities from fluctuation in market variables including, but not limited to, interest rates, foreign exchange, equity prices, commodity prices, credit spreads, implied volatilities and asset correlations. | BISL has no direct exposure to traded Market Risk. |
| Treasury and Capital Risk | Capital Risk: The risk that the firm has an insufficient level or composition of capital to support its normal business activities and to meet its regulatory capital requirements under normal operating environments and stressed conditions (both actual and as defined for internal planning or regulatory testing purposes). This also includes the risk from the firm’s pension plans. Liquidity Risk: The risk that the firm is unable to meet its contractual or contingent obligations or that it does not have the appropriate amount, tenor and composition of funding and liquidity to support its assets. Interest Rate Risk in the Banking Book: The risk that the firm is exposed to capital or income volatility because of a mismatch between the interest rate exposures of its (non-traded) assets and liabilities. | BISL is exposed to Capital Risk should it not maintain sufficient capital to support its normal business activities and to meet its regulatory capital requirements under normal operating environments and stressed conditions. BISL is exposed to Liquidity Risk should it not hold an adequate liquidity to meet its internal and external requirements. |
| Operational Risk | The risk of loss to the firm from inadequate or failed processes or systems, human factors or due to external events (for example fraud) where the root cause is not due to credit or market risks. Operational risks are organised into risk categories to help manage and report them effectively, including meeting regulatory requirements. These risk categories are further defined through the Operational Risk Framework | Operational risk is a material risk to BISL. A scenario-based approach is used to quantify Operational Risk for BISL. |
| Model Risk | The potential for adverse consequences from decisions based on incorrect or misused model outputs and reports. | BISL is exposed to Model Risk should there be adverse consequences due to incorrect or misused model outputs and reports. BISL ICARA Counterparty Credit Risk model is used to assess the capital required for counterparty credit risk. |
| Reputation Risk | The risk that an action, transaction, investment, event, decision, or business relationship will reduce trust in the firm’s integrity and/or competence. | Reputation Risk is relevant to BISL in the case that any actions, investment, event, decision or business relationship fail to meet client expectations and/or reduce trust in the firm’s integrity and/or competence. |
| Compliance Risk | The risk of poor outcomes for, or harm to, customers, clients and markets, arising from the delivery of the firm’s products and services (also known as 'Conduct Risk') and the risk to Barclays, its clients, customers or markets from a failure to comply with the laws, rules and regulations applicable to the firm (also known as Laws, Rules and Regulations Risk 'LRR Risk'). | BISL is exposed to Compliance Risk in the case that inadequate delivery of the firm’s products & services leads to poor outcomes or harm to customers, clients and markets. The risk could materialise if there is a failure to properly manage the financial risks inherent in managed investment products or services in line with BISL’s clients’ reasonable expectations or agreed risk appetites, if defined; it is governed via the Fiduciary Investment Risk Standard and its associated controls. |
| Legal Risk | The risk of loss or imposition of penalties, damages or fines from the failure of the firm to meet applicable laws, rules, regulations or contractual requirements or to assert or defend its intellectual property rights. | Legal Risk is relevant for BISL, should it face loss or imposition of penalties, damages or fines from failure to meet its legal obligations, including regulatory and contractual requirements. |
| Climate Risk | The risk of financial losses arising from climate change through, physical risks and risks associated with transitioning to a lower carbon economy. Climate Risk focuses on the Financial and Operational Risks associated with climate change. | Climate Risk is a principal risk for Barclays Group, therefore climate considerations are relevant to BISL in investment management and strategy. However, as the latter does not have a direct balance sheet impact, it is addressed under Reputation Risk. |
| Financial Crime Risk | The risk that the firm and its associated persons (employees or third parties) commit or facilitate financial crime, and/or the firm’s products and services are used to facilitate financial crime. Financial Crime undermines market integrity and may result in: Harm to clients, customers, counterparties or employees; Diminished confidence in financial products and services; Damage to the firm’s reputation; Regulatory breaches; and/or financial penalties. | BISL is exposed to Financial Crime Risk, which has formally been elevated to a principal risk within the Enterprise Risk Management Framework (ERMF). This reflects the increasing complexity and significance of financial crime risks Barclays (including BISL) faces, and ensures we continue to meet regulatory expectations whilst strengthening our ability to protect our clients and customers. |

# Appendix 1: MIFIDPRU 8.2 Risk Management Objectives and Policies (continued)

The Company’s risk management framework is described below and key indicators remain within the risk appetite defined by the Company.

### Own Funds, Concentration Risk and Liquidity
Own Funds: management conducts its own assessment of risk with reference to all the principal risks identified through the Enterprise Risk Management Framework. These principal risks and their relevance to the Company are described in the table below.
Concentration Risk: the Company deals in securities on behalf of clients, not on its own account. Securities transactions in the normal course of settlement are excluded under MIFIDPRU 5.10.1.(2). Therefore, the Company’s concentration risk focuses on assets not recorded in the trading book. This risk is monitored under the Credit Risk principal risk category.
Liquidity Risk: this is monitored under the Treasury and Capital Risk principal risk category.

### Risk Appetite
Risk Appetite defines the level of risk the Company is willing to take across the different risk types, taking into consideration varying levels of financial and operational stress. Risk Appetite is key in any decision making process, including ongoing business planning, new product approvals and business change initiatives. The management of risk is embedded into each level of the business, with all colleagues being responsible for identifying and controlling risks.

### Three Lines of Defence
The First Line of Defence (the “first line”) comprises all employees engaged in the revenue generating and client facing areas of the firm and all associated support functions, including Finance, Treasury, Technology and Operations, Human Resources, etc. Employees in the first line have primary responsibility for their risks, including:

i. Identifying and managing all the risks to which they are exposed as a result of activities in which they are engaged.
ii. Operating within any and all limits which the Risk and Compliance functions, as the Second Line of Defence (the “second line”), establish in connection with the Risk Appetite of the firm.
iii. Escalating risk events as per the Operational Risk Framework and to Risk and Compliance as per the requirements in their respective frameworks.

The first line may establish their own Policies, Standards and controls subject to the Barclays Control Framework (BCF) for their operational activities and require their colleagues to manage all controls to specified tolerances. These activities are permitted so long as they are within any applicable limits and/or tolerances, and Policies and/or Standards.

Where activities are not within applicable limits and/or tolerances, Policies and/or Standards, the first line is responsible for identifying, raising and remediating these in accordance with the Operational Risk Framework.

All activities in the first line are subject to oversight from the relevant parts of the second and third lines.

Employees of Risk and Compliance comprise the Second Line of Defence. The role of the second line is to establish the Frameworks, Policies and Standards, limits, rules and constraints under which all activities shall be performed, consistent with the Risk Appetite of the firm, and to oversee the performance of the firm against these Frameworks, Policies and Standards, limits, rules and constraints. Where these limits, rules and constraints are quantitative and/or model based, the measures may only be developed or approved by the second line.

The Second Line of Defence may establish limits for first line activities to manage risk exposure in line with Risk Appetite as appropriate.

In the event that the first line breaches limits or contravenes rules or constraints, the second line may, at its discretion, direct the activities of the first line to bring it within compliance including but not limited to the implementation of new controls and cessation of business or trading. Such activity will take place under the appropriate risk governance and/or oversight of the relevant risk committee. The second line has the authority and responsibility to perform independent challenge of all risks in the first line at any time.

The second line may establish limits for first line activities to manage risk exposure in line with Risk Appetite as appropriate. Controls for first line activities will ordinarily be established by the Control Owners operating within the Control Framework of the firm. The inherent and residual risks of the firm will be self-assessed through a Risk and Control Self-Assessment program defined in the Operational Risk Framework, and subject to second line oversight.

The second line is responsible for defining in its Policies and Standards details of its own responsibilities and activities and governing them, establishing controls to manage its performance, and assessing its conformance to these Policies and Standards as well as controls.

Employees of Internal Audit comprise the Third Line of Defence (the “third line”). They provide independent assurance to the Board and Executive Management of the effectiveness of governance, risk management and controls over current, systemic and evolving risks.

The Legal function and the services it provides does not sit in any of the three lines of defence, but supports them all. The responsibilities of the Legal function supplement and do not replace any of the responsibilities of the first and second line. Except in relation to the legal advice it provides or procures, the Legal function is also subject to oversight from the Risk with respect to its own Operational Risk, and Compliance with respect to its own Compliance Risks (including Laws, Rules and Regulations (LRR) Risk). The Compliance function also provides oversight of Legal Risk. For the avoidance of doubt, LRR Risk is part of Compliance Risk and Compliance is responsible for second line of defence oversight over the Legal function in relation to LRR Risk except in relation to the legal advice the Legal function provides or procures.

# Appendix 1: MIFIDPRU 8.2 Risk Management Objectives and Policies (continued)

Specifically in relation to LRRs, the Legal function is responsible for proactively identifying, communicating and providing legal advice on applicable laws, rules and regulations. This includes Legal having responsibility for ensuring that LRRs are effectively identified, defined, and allocated to appropriate Principal Risks and Horizontals, and adequately reflected within, the relevant Policies, Standards, and controls. Further, the Legal function has responsibility for providing the relevant information (including the requirements of LRRs) to the Policy and Standard owners to enable them to design and implement the controls that ensure compliance with relevant LRRs. As part of its role, Legal must satisfy itself that adequate controls have been established (for existing or newly identified LRR risks) based on its advice concerning control requirements, the results of second line oversight, and in accordance with Barclays Control Policy and Standard. This must be done both at inception of an LRR, when an LRR is updated or when there is a business process/product/service change impacting an LRR.

### Monitoring the Risk Profile
Together with a strong governance process, using Business and Group-level Risk Committees as well as Board level forums, the Directors of the Company receive regular information in respect of the risk profile of the Company, and have ultimate responsibility for Risk Appetite and capital plans.

The Directors have established a Board Risk Committee and a Board Audit Committee to implement and oversee this framework. The Board Risk Committee defines the risk appetite of the Company within that framework and the Board Audit Committee monitors the key performance indicators, by reviewing the controls that operate within the framework.

# Appendix 2: MIFIDPRU 8.3 Governance arrangements

The following information describes the governance arrangements of the Company.

### Management of the Company
The Board is the management body of BISL and has a schedule of Matters Reserved to the Board which states that its responsibilities include:

- Responsibility for the overall leadership of BISL
- Approval of BISL strategic aims and objectives
- Approval of the BISL Risk Appetite
- Responsibility for overseeing the maintenance of a sound system of audit, risk management, compliance and internal control and approval of BISL’s Risk Management Framework
- Adoption and review of policies.

The Board has standing committees which operate primarily in an advisory/review capacity and whose responsibilities are contained in written Terms of Reference. None have executive powers although the BISL Board Audit Committee, BISL Board Remuneration Committee, BISL Board Risk Committee and BISL Board Nominations Committee all have important control functions. Membership of standing committees is restricted to Non-Executive Directors.

The Board has scheduled meetings at least four times a year and receives written reports from senior management on key areas of the business and key functions as well as receiving reports from the standing committees.

The Board maintains a conflicts of interest register and has adopted a Charter of Expectations which sets out the role profile and expectations for Directors.

The Board and its standing committees are subject to annual evaluations.

### Directorships
Three directors held one directorship; one director held three directorships; and two directors held four directorships.

No waiver has been requested in order to allow a member of the management body to hold additional directorships.

### Diversity Policy
**Gender Diversity**
The Board’s current target is to ensure that by 2025:
The proportion of women on the Board is at least 40 per cent; and
At least one of the following senior Board positions is held by a woman: Chair, Chief Executive or Chief Finance Officer, and that this is maintained going forward.

The proportion of women on the Board is 25 per cent and a woman holds the position of Chair. There was a vacant position on the Board as at 31 December 2025 and so the gender diversity target will be considered when seeking candidates for that vacancy.

**Ethnic Diversity**
The target that at least one Board member is from a minority ethnic background excluding white ethnic groups, has been met.

### Risk Committee
The firm is required to have a Risk Committee and has established a Risk Committee.

# Appendix 3: MIFIDPRU 8.4 Own Funds

Composition of regulatory own funds
31 December 2025

| | Item | Amount (GBP thousands) | Source based on reference numbers/letters of the balance sheet in the audited financial statements |
| --- | --- | --- | --- |
| 1 | OWN FUNDS | 137,100 | Note 21 |
| 2 | TIER 1 CAPITAL | 137,100 | Note 21 |
| 3 | COMMON EQUITY TIER 1 CAPITAL | 137,100 | Note 21 |
| 4 | Fully paid up capital instruments | 87,325 | Note 21 |
| 5 | Share premium | 53,425 | Note 21 |
| 6 | Retained earnings | -3,650 | Note 21 |
| 7 | Accumulated other comprehensive income | | |
| 8 | Other reserves | | |
| 9 | Adjustments to CET1 due to prudential filters | | |
| 10 | Other funds | | |
| 11 | (-) TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 1 | | |
| 19 | CET1: Other capital elements, deductions and adjustments | | |
| 20 | ADDITIONAL TIER 1 CAPITAL | | |
| 21 | Fully paid up, directly issued capital instruments | | |
| 22 | Share premium | | |
| 23 | (-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 1 | | |
| 24 | Additional Tier 1: Other capital elements, deductions and adjustments | | |
| 25 | TIER 2 CAPITAL | | |
| 26 | Fully paid up, directly issued capital instruments | | |
| 27 | Share premium | | |
| 28 | (-) TOTAL DEDUCTIONS FROM TIER 2 | | |
| 29 | Tier 2: Other capital elements, deductions and adjustments | | |

# Appendix 3: MIFIDPRU 8.4 Own Funds (continued)

Own funds: reconciliation of regulatory own funds to balance sheet in the audited financial statements
31 December 2025

| | a | b | c |
| --- | --- | --- | --- |
| | Balance sheet as in published/audited financial statements | Under regulatory scope of consolidation | Cross-reference to template OF1 |
| | As at period end | As at period end | |

**Assets - Breakdown by asset classes according to the balance sheet in the audited financial statements**

| | | | | |
| --- | --- | --- | --- | --- |
| 1 | Investments in equity accounted associates | 0 | | |
| 2 | Deferred tax assets | 6 | | |
| 3 | Cash and cash equivalents | 304,366 | | |
| 4 | Cash collateral and settlement balances | 92,450 | | |
| 5 | Trade and Other receivables | 51,443 | | |
| 6 | Current Tax Asset | 1,725 | | |
| | Total Assets | 449,990 | | |

**Liabilities - Breakdown by liability classes according to the balance sheet in the audited financial statements**

| | | | | |
| --- | --- | --- | --- | --- |
| 1 | Cash collateral and settlement balances | 96,684 | | |
| 2 | Trade and other payables | 215,856 | | |
| 3 | Current tax liabilities | - | | |
| 4 | Provisions | 350 | | |
| | Total Liabilities | 312,890 | | |

**Shareholders' Equity**

| | | | | |
| --- | --- | --- | --- | --- |
| 1 | Share capital | 87,325 | | 4 |
| 2 | Share premium reserve | 53,425 | | 5 |
| 3 | Retained earnings | -3,650 | | 6 |
| | Total Shareholders' equity | 137,100 | | |

# Appendix 4: MIFIDPRU 8.5 Own Funds Requirements

The IFPR rules seek to mitigate risk to clients and risk to the market, as well as the regulatory focus of risks of the firm. Firms are expected to hold sufficient capital and liquidity, in their own name, to meet these risks. BISL is an FCA investment firm and subject to these ICARA requirements (Internal Capital Adequacy & Risk Assessment).

The Company has considered the INITIAL CAPITAL REQUIREMENT as the highest value from three different tests:

i. The firm’s Permanent Minimum Requirement (£750k).
ii. The firm’s Fixed Overheads Requirement (one quarter of its fixed cost base).
iii. The firm’s K-factor Requirement (a prescribed regulatory capital assessment).

In addition to the Company’s INITIAL CAPITAL REQUIREMENT, as part of its ICARA process and to determine its OVERALL CAPITAL REQUIREMENT, the Company has also assessed whether it should hold additional own funds adequate for:

i. The estimated cost of executing an orderly wind down of the firm with minimal market disruption.
ii. The firm’s assessment of the specific risks for its ongoing operations and the capital it should hold against those risks.

The Company has also conducted a stress test of its expected capital resource to ensure resources remain above capital requirement during a stress event.

The capital requirements have been assessed and having considered the Company’s risk appetite the ICARA process has set the Company’s capital requirement. The Company maintains capital resource above that requirement and continues to monitor the capital surplus and related early warning indicators.

The table below sets out the Company’s K-factor requirements and fixed overhead in accordance with MIFIDPRU 8.5.1

| Disclosure Requirement | £’000 |
| --- | --- |
| Sum of the K-AUM requirement, the K-CMH requirement and the K-ASA requirement | 21,300 |
| Sum of the K-COH requirement and the K-DTF requirement | 77 |
| Sum of the K-NPR requirement, the K-CMG requirement, the K-TCD requirement and the K-CON requirement | 9 |
| Fixed overhead requirement | 44,800 |

The Company has also assessed its liquidity requirements and has considered the overall financial adequacy rule which requires a firm to hold adequate liquid assets to ensure that the firm is able to remain financially viable throughout the economic cycle, with the ability to address any potential harm that may result from its ongoing activities and that the firm’s business can be wound down in an orderly manner.

Having considered the Company’s risk appetite the ICARA process has set the Company’s liquidity requirement. The Company maintains liquidity resource above that requirement and continues to monitor the liquidity surplus and related early warning indicators. At 31 December 2025 the Company held core liquid assets of £303m.

# Appendix 5: MIFIDPRU 8.6 Remuneration policy and practices

The following disclosures are made in accordance with section 8.6 of the FCA’s Prudential Sourcebook for MiFID Investment Firms ('MIFIDPRU').

### Remuneration governance
Barclays Bank PLC (‘BBPLC’) is the parent company of Barclays Investment Solutions Limited (‘BISL’). BISL had no direct employees during 2025 and there were no employees of other entities within the Barclays Group whose services or remuneration were under the control of BISL, although some Barclays Group employees (all of whom were identified as Material Risk Takers (‘MRTs’) of BBPLC) provided services to BISL during 2025.

Remuneration decisions in respect of BBPLC MRTs are overseen by the Barclays PLC and BBPLC Board Remuneration Committees. Variable remuneration awards for 2025 were based on risk, performance and affordability factors relevant for those entities. Information on the remuneration of BBPLC MRTs is included in Appendix B of the 2025 BBPLC Pillar 3 Report, including explanations of the Barclays Group’s approach to performance management and how managers consider risk, control and conduct issues arising within all areas of the organisation. These mechanisms ensure that any issues found within BISL are factored into the performance ratings and pay outcomes for those individuals who provide services to BISL.

The BBPLC 2025 Pillar 3 Report also provides further information on the entity’s approach to remuneration of employees (including BBPLC MRTs), including:

- The Barclays Group Remuneration Philosophy.
- The different components of remuneration, together with the categorisation of those remuneration components as fixed or variable.
- The financial and non-financial performance criteria used across the firm to determine remuneration outcomes.
- The framework and criteria used for ex-ante and ex-post risk adjustment of remuneration, including how the firm considers current and future risks when adjusting remuneration and how malus and clawback are applied.
- The policies and criteria applied for awards of guaranteed variable remuneration and severance payments.
- The approach to deferral of variable remuneration.
- The different forms in which fixed and variable remuneration are paid.

The BISL Board Remuneration Committee annually reviews the Barclays Group Reward Policy and its implementation approach to determine their suitability for any individual who may provide services to BISL, and is provided with information to satisfy itself that the structure of remuneration for BISL MRTs is in line with applicable regulatory requirements.

### Remuneration of BISL MRTs in respect of the financial year
BISL MRTs are those staff of the Barclays Group whose professional activities could have a material impact on BISL’s risk profile, which includes the members of the BISL Board, the members of the BISL Executive and Risk Committees and Senior Managers of BISL. A total of 15 individuals were BISL MRTs in 2025.

The following tables set out remuneration disclosures for individuals identified as BISL MRTs for 2025. In the tables, the terms below mean:

- ‘Senior Management’ means those individuals who are members of the BISL Board or BISL Executive Committee, excluding the Non-Executive Directors of BISL.
- ‘Other MRTs’ means BISL MRTs excluding those MRTs included in Senior Management.

No guaranteed variable remuneration award or severance payments were awarded to BISL MRTs in 2025.

One BISL MRT benefitted from the exemption for individual MRTs set out in SYSC 19G.5.9R in 2025. In line with the exemption under MIFIDPRU 8.6.8R, the fixed and variable remuneration of the individual benefiting from the exemption in SYSC 19G.5.9R is not disclosed so as not to lead to the disclosure of information about that one individual.

# Remuneration awarded for the financial year (all figures are in £m except for ‘Number of staff’)

| | | Senior Management | Other MRTs |
| --- | --- | --- | --- |
| 1 | Number of staff | 10 | 5 |
| 2 | Total fixed remuneration | 5.8 | 1.0 |
| 3 | Total variable remuneration | 5.1 | 0.5 |
| 4 | Of which: cash-based | 2.5 | 0.3 |
| 5 | Of which: deferred | 1.5 | 0.1 |
| 6 | Of which: shares or equivalent ownership interests | 2.6 | 0.2 |
| 7 | Of which: deferred | 1.5 | 0.1 |
| 8 | Of which: share-linked instruments or equivalent non-cash instruments | — | — |
| 9 | Of which: deferred | — | — |
| 10 | Of which: other instruments | — | — |
| 11 | Of which: deferred | — | — |
| 12 | Of which: other forms | — | — |
| 13 | Of which: deferred | — | — |
| 14 | Total Remuneration | 10.9 | 1.5 |

# Deferred remuneration (all figures are in £m)

| | | Deferred and retained remuneration | Total amount of deferred remuneration awarded for previous performance periods | Of which due to vest in the financial year | Of which vesting in subsequent financial years | Amount of performance adjustment made in the financial year to deferred remuneration that was due to vest in the financial year | Total amount of deferred remuneration awarded before the financial year actually paid out in the financial year$^{1}$ |
| --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | Senior Management | 8.5 | 2.0 | 6.5 | — | 2.3 | |
| 2 | Other MRTs | 0.7 | 0.1 | 0.6 | — | 0.1 | |

$^{1}$ This represents the values when vesting and hence includes any changes of value of deferred remuneration due to the changes of prices of instruments.