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Cobens Group Limited – MIFIDPRU 8 Disclosure Statement

Introduction

The Financial Conduct Authority’s (“FCA”) Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Cobens Group Limited ( “the Firm”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out the public disclosure rules and guidance with which the Firm must comply.

The Firm is classified under MIFIDPRU as a small and non-interconnected investment firm (“SNI MIFIDPRU investment firm”). As such, MIFIDPRU 8 requires the Firm to disclose information regarding its remuneration policy and practices.

The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture, and to assist stakeholders in making more informed decisions about their relationship with the Firm. This document has been prepared by Cobens Group Limited in accordance with the requirements of MIFIDPRU 8 and has been approved by the Board. All figures are as at the 28th December 2025 financial year-end.

Remuneration Policy and Practices – Qualitative Disclosure

As an SNI MIFIDPRU investment firm, the Firm is subject to the basic requirements of the MIFIDPRU Remuneration code (SYSC 19G).
The purpose of the remuneration requirements is to:

  • promote effective risk management in the long-term interests of the Firm and its clients;
  • ensure alignment between risk and individual reward;
  • support positive behaviours and a healthy firm culture; and
  • discourage behaviours that can lead to misconduct and poor customer outcomes.

The Firm recognises that remuneration is a key component in attracting, motivating and retaining competent staff as well as achieving high levels of performance and productivity. It is committed to delivering good outcomes to clients. ‘Staff’ is broadly defined as employees of the Firm itself.
The Firm provides a combination of fixed and variable remuneration. Fixed remuneration is determined by an individual’s professional experience, role and organisational responsibilities. It is permanent, predetermined, non-discretionary, non-performance-based, non-revocable, and typically comprises salary, pension contributions, medical cover, annual leave and other applicable benefits.

Variable remuneration is considered on a quarterly basis and is approved by Senior Management where appropriate. Awards are determined with reference to a range of financial and non-financial performance measures, including the quality of advice provided, compliance with regulatory requirements, conduct and individual performance. Employees performing advising roles may have a greater proportion of their total remuneration linked to variable remuneration than employees in non-advising roles, reflecting the nature of their responsibilities.

Overall, fixed remuneration represents a greater proportion of total remuneration than variable remuneration.

Governance and Oversight

The Firm’s management body is responsible for setting and overseeing the implementation of the remuneration policy and practices. The management body reviews the remuneration policy annually and is approved by the Board.

The remuneration policy is reviewed at least annually and forms part of the Firm’s wider governance framework. The most recent review was completed alongside the annual Internal Capital Adequacy and Risk Assessment (ICARA), which was approved by the Board on 30th June 2026.The ICARA process concluded that the remuneration policy promotes sound and effective risk management, aligns with the firm’s business strategy and risk profile, and does not create incentives that may conflict with the firm’s ability to meet its Overall Financial Adequacy Rule (OFAR).