SCR Investments Ltd - Limited company accounts 18.2

REGISTERED NUMBER: 07392266 (England and Wales)

Strategic Report, Report of the Director and

Financial Statements for the Year Ended 30 September 2018

for

SCR INVESTMENTS LTD

Page

Company Information

1

Strategic Report

2

Report of the Director

3

Report of the Independent Auditors

5

Statement of Income and Retained Earnings

7

Statement of Financial Position

8

Statement of Cash Flows

9

Notes to the Statement of Cash Flows

10

Notes to the Financial Statements

11

DIRECTOR:

Ms R Y Palmer

SECRETARY:

SPM SERVICES LTD

REGISTERED OFFICE:

SPM House

Rear of No 2

Glenthorne Road

London

N11 3HT

REGISTERED NUMBER:

07392266 (England and Wales)

AUDITORS:

Williams Chartered Accountants

67 Park Royal Road

London

NW10 7JJ

The director presents her strategic report for the year ended 30 September 2018.

REVIEW OF BUSINESS

SCR Investments Ltd is authorised by the Financial Conduct Authority to advise on and arrange investment business.

Due to the global market condition, the company's turnover has been comparatively low this year.

The company continues to look for opportunities both in the UK and overseas, particularly targeting Asia and Australia

for expansion. Therefore, the director still expects that the company will grow its business both in its core market and

new markets and this will lead to improvement in the company's financial results and significant growth in all the key

performance indicators of client numbers, client deposits and trade volumes.

PRINCIPAL RISKS AND UNCERTAINTIES

As a service provider the director considers that the key financial risk exposures faced by the company relate to credit

risk and the need to maintain sufficient liquidity to satisfy regulated capital requirements and working capital needs. The

company does not take trade positions which expose it to material price risk nor does it have a material exposure to

foreign exchange movements.

The company's financial risk management objectives are therefore to minimise the key financial risks through having

clearly defined terms of business with counter parties and stringent credit control over transactions with them and regular

monitoring of cash flow and management accounts to ensure regulatory capital requirements are not breached and the

company maintains adequate working capital. The company has robust AML and Compliance policies.

Development and Performance

The company will continue to expand its activities and remains optimistic for the foreseeable future.

Key Performance indicators

Kep Performance indicators are turnover of £35,034 and loss for the year of £18,454. At the year end the firm had net

assets of £108,186.

ON BEHALF OF THE BOARD:

Ms R Y Palmer - Director

25 January 2019

The director presents her report with the financial statements of the company for the year ended 30 September 2018.

PRINCIPAL ACTIVITY

The principal activity of the company in the year under review was that of arranging deals in securities and

bonds,managing and advising on investment funds.

DIVIDENDS

No dividends will be distributed for the year ended 30 September 2018.

FUTURE DEVELOPMENTS

The directors are confident about the company's progress and believe the company is well placed to make further

progress during the coming year

DIRECTOR

Ms R Y Palmer held office during the whole of the period from 1 October 2017 to the date of this report.

FINANCIAL INSTRUMENTS

In the ordinary course of business, the company is exposed to a number of risks, the most significant of which are

market, credit, liquidity and operational risk. The company regards the monitoring and controlling of risk as a

fundamental part of the management process.

Risks and uncertainties

The company's operations are exposed to financial risks including credit, currency fluctuation and liquidity risks. Credit

risk exists as the company does not receive its fees immediately after the deals are arranged or when investment advices

are provided.

Currency risk exists in the form of deals arranged with currencies other than pounds sterling, and are paid in those

currencies which fluctuate during the year.

Liquidity risk is minimised as the company has to closely monitor its expenditure and capital requirements. Six monthly

management accounts are prepared and cost control is also maintained. The directors monitor the company's liquidity

needs on a daily basis. The company's liquidity is supported by the directors' loans.

More detailed explanation of the risks to which the company is exposed, and its strategy for managing these risks is

included in the Pillar 3 disclosure which is shown on pages 17 to 19 of the financial statements.

STATEMENT OF DIRECTOR'S RESPONSIBILITIES

The director is responsible for preparing the Strategic Report, the Report of the Director and the financial statements in

accordance with applicable law and regulations.

Company law requires the director to prepare financial statements for each financial year. Under that law the director

has elected to prepare the financial statements in accordance with United Kingdom Generally Accepted Accounting

Practice (United Kingdom Accounting Standards and applicable law), including Financial Reporting Standard 102 'The

Financial Reporting Standard applicable in the UK and Republic of Ireland'. Under company law the director must not

approve the financial statements unless she is satisfied that they give a true and fair view of the state of affairs of the

company and of the profit or loss of the company for that period. In preparing these financial statements, the director is

required to:

-	select suitable accounting policies and then apply them consistently;

-	make judgements and accounting estimates that are reasonable and prudent;

-	state whether applicable accounting standards have been followed, subject to any material departures disclosed and explained in the financial statements;

-	prepare the financial statements on the going concern basis unless it is inappropriate to presume that the company will continue in business.

The director is responsible for keeping adequate accounting records that are sufficient to show and explain the

company's transactions and disclose with reasonable accuracy at any time the financial position of the company and

enable her to ensure that the financial statements comply with the Companies Act 2006. She is also responsible for

safeguarding the assets of the company and hence for taking reasonable steps for the prevention and detection of fraud

and other irregularities.

STATEMENT AS TO DISCLOSURE OF INFORMATION TO AUDITORS

So far as the director is aware, there is no relevant audit information (as defined by Section 418 of the Companies Act

2006) of which the company's auditors are unaware, and she has taken all the steps that she ought to have taken as a

director in order to make herself aware of any relevant audit information and to establish that the company's auditors are

aware of that information.

ON BEHALF OF THE BOARD:

Ms R Y Palmer - Director

25 January 2019

Opinion

We have audited the financial statements of SCR Investments Ltd (the 'company') for the year ended 30 September 2018

which comprise the Statement of Income and Retained Earnings, Statement of Financial Position, Statement of Cash

Flows and Notes to the Statement of Cash Flows, Notes to the Financial Statements, including a summary of significant

accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and

United Kingdom Accounting Standards, including Financial Reporting Standard 102 'The Financial Reporting Standard

applicable in the UK and Republic of Ireland' (United Kingdom Generally Accepted Accounting Practice).

In our opinion the financial statements:

-	give a true and fair view of the state of the company's affairs as at 30 September 2018 and of its loss for the year then ended;

-	have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice; and

-	have been prepared in accordance with the requirements of the Companies Act 2006.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law.

Our responsibilities under those standards are further described in the Auditors' responsibilities for the audit of the

financial statements section of our report. We are independent of the company in accordance with the ethical

requirements that are relevant to our audit of the financial statements in the UK, including the FRC's Ethical Standard,

and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit

evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Conclusions relating to going concern

We have nothing to report in respect of the following matters in relation to which the ISAs (UK) require us to report to

you where:

-	the director's use of the going concern basis of accounting in the preparation of the financial statements is not appropriate; or

-

the director has not disclosed in the financial statements any identified material uncertainties that may cast significant doubt about the company's ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from the date when the financial statements are authorised for issue.

Other information

The director is responsible for the other information. The other information comprises the information in the Strategic

Report and the Report of the Director, but does not include the financial statements and our Report of the Auditors

thereon.

Our opinion on the financial statements does not cover the other information and, except to the extent otherwise

explicitly stated in our report, we do not express any form of assurance conclusion thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing

so, consider whether the other information is materially inconsistent with the financial statements or our knowledge

obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or

apparent material misstatements, we are required to determine whether there is a material misstatement in the financial

statements or a material misstatement of the other information. If, based on the work we have performed, we conclude

that there is a material misstatement of this other information, we are required to report that fact. We have nothing to

report in this regard.

Opinion on other matters prescribed by the Companies Act 2006

In our opinion, based on the work undertaken in the course of the audit:

-	the information given in the Strategic Report and the Report of the Director for the financial year for which the financial statements are prepared is consistent with the financial statements; and

-	the Strategic Report and the Report of the Director have been prepared in accordance with applicable legal requirements.

Matters on which we are required to report by exception

In the light of the knowledge and understanding of the company and its environment obtained in the course of the audit,

we have not identified material misstatements in the Strategic Report or the Report of the Director.

We have nothing to report in respect of the following matters where the Companies Act 2006 requires us to report to you

if, in our opinion:

-	adequate accounting records have not been kept, or returns adequate for our audit have not been received from branches not visited by us; or

-	the financial statements are not in agreement with the accounting records and returns; or

-	certain disclosures of director's remuneration specified by law are not made; or

-	we have not received all the information and explanations we require for our audit.

Responsibilities of director

As explained more fully in the Statement of Director's Responsibilities set out on pages three and four, the director is

responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and

for such internal control as the director determines necessary to enable the preparation of financial statements that are

free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the director is responsible for assessing the company's ability to continue as a

going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of

accounting unless the director either intends to liquidate the company or to cease operations, or has no realistic

alternative but to do so.

Auditors' responsibilities for the audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from

material misstatement, whether due to fraud or error, and to issue a Report of the Auditors that includes our opinion.

Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs

(UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are

considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic

decisions of users taken on the basis of these financial statements.

A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting

Council's website at www.frc.org.uk/auditorsresponsibilities. This description forms part of our Report of the Auditors.

Use of our report

This report is made solely to the company's members, as a body, in accordance with Chapter 3 of Part 16 of the

Companies Act 2006. Our audit work has been undertaken so that we might state to the company's members those

matters we are required to state to them in a Report of the Auditors and for no other purpose. To the fullest extent

permitted by law, we do not accept or assume responsibility to anyone other than the company and the company's

members as a body, for our audit work, for this report, or for the opinions we have formed.

Denver Dias FCA (Senior Statutory Auditor)

for and on behalf of Williams Chartered Accountants

67 Park Royal Road

London

NW10 7JJ

25 January 2019

TURNOVER

3

35,034

136,550

Cost of sales

18,546

71,326

GROSS PROFIT

16,488

65,224

Administrative expenses

52,120

63,071

(35,632

)

2,153

Other operating income

4

16,758

-

OPERATING (LOSS)/PROFIT and

(LOSS)/PROFIT BEFORE TAXATION

(18,874

)

2,153

Tax on (loss)/profit

8

(420

)

420

(LOSS)/PROFIT FOR THE FINANCIAL YEAR

(18,454

)

1,733

Retained earnings at beginning of year

66,640

64,907

RETAINED EARNINGS AT END OF YEAR

48,186

66,640

CURRENT ASSETS

Debtors

9

358,108

234,316

CREDITORS

Amounts falling due within one year

10

249,922

107,676

NET CURRENT ASSETS

108,186

126,640

TOTAL ASSETS LESS CURRENT LIABILITIES

108,186

126,640

CAPITAL AND RESERVES

Called up share capital

11

60,000

60,000

Retained earnings

48,186

66,640

SHAREHOLDERS' FUNDS

108,186

126,640

The financial statements were approved by the director on 25 January 2019 and were signed by:

Ms R Y Palmer - Director

Cash flows from operating activities

Cash generated from operations

1

(142,328

)

(133,450

)

Tax paid

(420

)

(2,067

)

Net cash from operating activities

(142,748

)

(135,517

)

Cash flows from financing activities

Amount introduced by directors

144,209

140,278

Amount withdrawn by directors

(1,461

)

(5,958

)

Net cash from financing activities

142,748

134,320

Decrease in cash and cash equivalents

-

(1,197

)

Cash and cash equivalents at beginning of year

2

-

1,197

Cash and cash equivalents at end of year

2

-

-

1.	RECONCILIATION OF (LOSS)/PROFIT BEFORE TAXATION TO CASH GENERATED FROM OPERATIONS

30.9.18

30.9.17

£

£

(Loss)/profit before taxation

(18,874

)

2,153

Increase in trade and other debtors

(123,372

)

(132,124

)

Decrease in trade and other creditors

(82

)

(3,479

)

Cash generated from operations

(142,328

)

(133,450

)

2.	CASH AND CASH EQUIVALENTS

The amounts disclosed on the Statement of Cash Flows in respect of cash and cash equivalents are in respect of

these Statement of Financial Position amounts:

Year ended 30 September 2018

30.9.18

1.10.17

£

£

Year ended 30 September 2017

30.9.17

1.10.16

£

£

Cash and cash equivalents

-

1,197

1.	STATUTORY INFORMATION

SCR Investments Ltd is a private company, limited by shares, registered in England and Wales. The company's

registered number and registered office address can be found on the Company Information page.

The company's business address is 53 Davies Street, London, W1K 5JH.

The presentation currency of the financial statements is the Pound Sterling (£) and is rounded to the nearest

pound.

2.	ACCOUNTING POLICIES

Basis of preparing the financial statements

These financial statements have been prepared in accordance with Financial Reporting Standard 102 "The Financial Reporting Standard applicable in the UK and Republic of Ireland" and the Companies Act 2006. The financial statements have been prepared under the historical cost convention.

Revenue recognition

Revenue is recognised as the difference between the sell and buy tickets issued during the year on deals arranged

for clients and on trade date basis. Revenue also includes management fee received on funds managed and is

based on fund performance.

Taxation

Taxation for the year comprises current and deferred tax. Tax is recognised in the Income Statement, except to

the extent that it relates to items recognised in other comprehensive income or directly in equity.

Current or deferred taxation assets and liabilities are not discounted.

Current tax is recognised at the amount of tax payable using the tax rates and laws that have been enacted or

substantively enacted by the statement of financial position date.

Deferred tax

Deferred tax is recognised in respect of all timing differences that have originated but not reversed at the

statement of financial position date.

Timing differences arise from the inclusion of income and expenses in tax assessments in periods different from

those in which they are recognised in financial statements. Deferred tax is measured using tax rates and laws that

have been enacted or substantively enacted by the year end and that are expected to apply to the reversal of the

timing difference.

Unrelieved tax losses and other deferred tax assets are recognised only to the extent that it is probable that they

will be recovered against the reversal of deferred tax liabilities or other future taxable profits.

Foreign currencies

Assets and liabilities in foreign currencies are translated into sterling at the rates of exchange ruling at the

statement of financial position date. Transactions in foreign currencies are translated into sterling at the rate of

exchange ruling at the date of transaction. Exchange differences are taken into account in arriving at the

operating result.

Turnover

The turnover and profit before taxation are attributable to arranging deals in securities, bond management and

advising on investment funds.

3.

TURNOVER

The turnover and loss (2017 - profit) before taxation are attributable to the one principal activity of the company.

An analysis of turnover by class of business is given below:

30.9.18

30.9.17

£

£

Profit from deals

35,034

136,550

35,034

136,550

4.	OTHER OPERATING INCOME

30.9.18

30.9.17

£

£

Other income

16,758

-

This income represents refund for some of the expenses made by Acamas Strategic investments management Ltd

.

5.	EMPLOYEES AND DIRECTORS

There were no staff costs for the year ended 30 September 2018 nor for the year ended 30 September 2017.

30.9.18

30.9.17

£

£

Director's remuneration

-

-

6.	OPERATING (LOSS)/PROFIT

The operating loss (2017 - operating profit) is stated after charging/(crediting):

30.9.18

30.9.17

£

£

Foreign exchange differences

(6,930

)

6,003

-

4,500

7.	AUDITORS' REMUNERATION

30.9.18

30.9.17

£

£

Fees payable to the company's auditors for the audit of the company's financial statements

4,740

4,500

8.

TAXATION

Analysis of the tax (credit)/charge

The tax (credit)/charge on the loss for the year was as follows:

30.9.18

30.9.17

£

£

Current tax:

UK corporation tax

(420

)

420

Tax on (loss)/profit

(420

)

420

9.

DEBTORS: AMOUNTS FALLING DUE WITHIN ONE YEAR

30.9.18

30.9.17

£

£

Trade debtors

5,259

28,671

SCR Investments Pty Ltd

88,667

29,429

Global Prime Partners

181,023

94,362

Aether Capital LLC

79,980

79,098

Tax

420

-

Prepayments

2,759

2,756

358,108

234,316

10.

CREDITORS: AMOUNTS FALLING DUE WITHIN ONE YEAR

30.9.18

30.9.17

£

£

Tax

-

420

Directors' loan accounts

240,698

97,950

Accrued expenses

9,224

9,306

249,922

107,676

11.	CALLED UP SHARE CAPITAL

Allotted, issued and fully paid:

Number:

Class:

Nominal

30.9.18

30.9.17

value:

£

£

60,000

Ordinary Shares

1

60,000

60,000

12.	DIRECTOR'S ADVANCES, CREDITS AND GUARANTEES

The following advances and credits to a director subsisted during the years ended 30 September 2018 and

30 September 2017:

30.9.18

30.9.17

£

£

Ms R Y Palmer

Balance outstanding at start of year

(97,950

)

36,370

Amounts advanced

1,462

5,958

Amounts repaid

(144,209

)

(140,278

)

Amounts written off

-

-

Amounts waived

-

-

Balance outstanding at end of year

(240,697

)

(97,950

)

13.	RELATED PARTY DISCLOSURES

Included in debtors is an amount of £88,667 (2017: £29,429) owed by SCR Investments Pty Ltd, a limited

company based in Austalia of which R Y Palmer is a director and controlling shareholder. The balance is interest

free and repayable on demand. A management fees of £18,218 (2017: £71,006) was paid to the same company.

14.	ULTIMATE CONTROLLING PARTY

R Y Palmer is the ultimate controlling party holding 100% of the shares in the company.

15.	APPENDIX TO THE FINANCIAL STATEMENTS

Pillar 3 disclosure

Disclosure Policy

The Pillar 3 rules in BIPRU 11 set out the need for firms to have a formal disclosure policy. In accordance with

the rules of the Financial Conduct Authority ("FCA") SCR Investments Limited('SCR') will disclose the

information set out in BIPRU 11 (the Pillar 3 rule) on at least an annual basis. In accordance with BIPRU

11.3.3(2) this disclosure has been assessed by SCR's Board of Directors to comprehensively convey the firm's

risk profile to market participants.The Pillar 3 disclosure will be made in the firm's annual report and accounts.

SCR may omit information it deems as immaterial, in accordance with the rules. Materiality is based on the

criterion that the omission or misstatement of any information would be likely to change or influence the decision

of a reader relying on that information. Accordingly, where SCR has considered an item to be immaterial it has

not been disclosed. SCR has implemented a policy for assessing the appropriateness of its market disclosures,

including their verification and frequency.

In addition, if the required information is deemed to be proprietary or confidential then SCR may take the

decision to exclude it from the disclosure. In the Firm's view, proprietary information is that which, if it were

shared, would undermine its competitive position. Information is considered to be confidential where there are

obligations binding the Firm to confidentiality with our customers, suppliers or counterparties. Where

information is omitted for either of these reasons this is stated in the relevant section of the disclosure, along with

the jurisdiction.

Introduction

SCR is authorised and regulated by the FCA and as such is subject to minimum regulatory capital requirements.

The Firm is categorised by the FCA, for capital purposes, as a limited licence firm. It is an investment

management firm; it has no trading book exposures. The Firm is not required to prepare consolidated reporting

for prudential purposes.

The FCA's current prudential regime can be split into three "pillars":

" Pillar 1 - prescribes the minimum capital requirements that authorised firms need to hold. This is the higher of

€50K; quarter of the firms annual adjusted expenditure (the Fixed Overheads Requirement); or the sum of the

firm's prescribed Credit risk and Market risk.

" Pillar 2 -requires firms to analyse the risks to the business and then consider whether the risks are mitigated to

an appropriate standard. If the firm feels that the risks are not adequately mitigated then they should allocate

capital against those risks. Stress and scenario tests are conducted to ensure that the processes, strategies and

systems are comprehensive and robust and that the allocation of capital is sufficient.

" Pillar 3 - requires firms to develop a set of disclosures which will allow market participants to assess key

information about the Firm's underlying risks, risk management controls and capital position.

The minimum requirement as set for this category of firm, which €50,000, determines SCR Capital Resources

Requirement as this is greater than the Fixed Overheads Requirement or the sum of its credit and market risk

exposure.

The Firm is a Limited Company and its capital arrangements are as follows:

£   's

Permanent Share capital 60

Audited retained profits 48

-------

Permanent Share capital and other reserves 108

====

The main features of the Firm's Capital Resources Requirement are as follows:

Capital Item £'000s

Tier 1 capital less innovative tier 1 capital 108

Total tier 2, innovative tier 1 and tier 3 capital 0

Deductions from tier 1 and tier 2 capital 0

Total capital resources, net of deductions 108

Risk Management

Due to the size, nature, scale and complexity of the Firm, there is no independent risk management function. The

Director of the Firm determine the business strategy and risk appetite along with the risk management policies

and procedures. An identification of risks to the Firm is considered and the Firm's resultant exposure is assessed

after the application of both management and mitigation of these risks. Furthermore, the Firm then conduct a

series of stress tests and scenario analyses on these risks to determine the effect they would have on the firm.

If necessary, SCR would allocate extra capital to the relevant risk, as per the Pillar 2 requirement: this has not

been deemed necessary. This process is conducted at Board Meetings which are held on a quarterly basis and the

relevant policies and procedures are updated where necessary.

The Director has identified Concentration Risk, Key Person Risk and Regulatory Risk as the main areas of risk

to which the firm is exposed.

Concentration Risk is carried by SCR due to a lack of diversification in its client base. This is managed by a

number of means. Controls have been implemented, such as investor lock-in periods ensuring business viability.

There are mechanisms which have been put in place to maintain investor transparency; however the nature of the

relationship between SCR and its clients is such that it is highly unlikely that termination will occur.

Key Person Risk is mitigated by a 'four eyes' approach adopted to ensure seamless succession of the business

should one of the Directors be unavailable. In addition, there will be a minimum of two investment managers

acting on behalf of SCR to ensure a continuation of the investment function.

Regulatory Risk is mitigated through a layered, consultative approach. The firm operates within a tight system of

controls and checks, such checks include the appointment of external legal advisors and the implementation of a

Compliance Monitoring Programme. The firm has also engaged the services of Robert Quinn, a specialist

regulatory consultancy.

The Firm has concluded that its Tier 1 capital is sufficient to cover its Pillar 1 and Pillar 2 requirements.

Disclosures: Remuneration Background

During the year the board reviewed the remuneration policy in light of the rules and guidance contained in the

FCA Remuneration Code ("the Code") published in December 2010. The Code itself implements remuneration

rules required by the Capital Requirements Directive ("CRD 3") and the Financial Services Act 2010.

While some firms are within the scope of the Code, the proportionality principle contained in the Code rules

requires the Company to comply with the Code only in a way and to the extent that is appropriate to its size,

internal organisation and the nature, the scope and the complexities of its activities. The company falls within the

lowest level of Code categorisation (Tier 4), which means that it is not required to comply with some of the

prescriptive rules set out in the Code such as deferral and retained shares.

The company is also aware of its CRD III disclosures on remuneration requirements and will be publishing the

relevant information on its website in due course

In fixing the remuneration packages for current and future financial years the Directors have the following in

mind:

- The need to attract, retain and motivate staff and Directors of the quality required;

- What comparable companies are paying, taking into account relative performance; and

- Pay and employment conditions elsewhere in the company.

At present the Directors have not drawn any remuneration or benefits from the company.

The FCA defines Remuneration Code Staff ("Code Staff") in SYSC 19A.3.4 as senior management, risk takers,

staff engaged in control functions and any employee receiving total remuneration that takes them into the same

remuneration bracket as those detailed above, whose professional activities have a material impact on the firm's

risk profile.

Application

Based on the Firm's profile the firm is classified as a Proportionality Tier Four investment firm ("Tier Four

Firm") and adopted a proportioned approach to the remuneration policy. The firm's individual needs have been

considered on an ongoing basis and where appropriate applied certain provisions in accordance with FCA and

CEBS/EBA guidance. The Managing Board will review any provisions which have been applied on at least an

annual basis, to ensure that it continues to be appropriate.

Information concerning the decision-making process

Due to the size of the Firm, it is not appropriate to have a separate remuneration committee. Instead this function

is undertaken by the Managing Board. This will be kept under review and should the need arise, the Firm will

consider amending this arrangement to provide greater independent review.

The Managing Board of SCR Investments Ltd is responsible for ensuring that the remuneration policy is

developed to align with its risk tolerance. No external consultants assisted in this review. Any person with a

question regarding the policy or disclosures made under this policy should refer to the CEO who is a Member of

the Managing Board.

Information on the link between pay and performance

The pay and benefits for the executive Directors would be determined by Ragen Palmer taking into account

individual performance and market conditions.

The basic salaries of the Directors would be reviewed annually and when a change of responsibility occurs. No

Remuneration and Benefits were paid for the year ending 30 September 2018.

Based on the profile of the Firm, it is considered that the firm has one business area, investment management and

the Directors, as Code Staff, have responsibilities that typically fall within job titles FCA guidance indicated

would suggest Ragen Palmer is a senior personnel whose role impacts the risk profile of the Firm.

As such, to comply with the FCA disclosure requirement BIRPU 11.5.18 R (6) and (7), it is disclosed, as per the

audited accounts of the Firm, that the total Director's Remuneration and benefits for the year ended 30 September

2018 was nil.