REMUNERATION CODE DISCLOSURE

Laven Advisors LLP

(the “Firm”)

2011

The Firm is authorised and regulated by the Financial Services Authority (the “FSA”) as a BIPRU limited licence firm and as such the FSA’s Remuneration Code applies to it. In line with its requirements, the management committee of the Firm has approved and implemented a remuneration policy for the Firm.

The remuneration policy of the Firm is set by the management committee of the limited liability partnership and follows the terms of the limited liability partnership agreement of the Firm. Only members are remunerated by the Firm through profit share entitlements. No other form of compensation is paid by the Firm.

Individual remuneration is always linked to the long term performance of the Firm. If the Firm does not succeed, individuals do not receive variable remuneration. All the members receiving remuneration from the Firm are committed to the long term success of the business and this is considered the most important criteria in assessing variable remuneration.

The members of the Firm are eligible for variable remuneration which is awarded once a year. The members’ entitlements are set out in the limited liability partnership agreement as a percentage of net profits however; these entitlements are subject to a risk adjustment process. Prior to any variable remuneration being awarded by the Firm, an assessment of the following criteria is made:

• Current and future liabilities of the Firm are examined to ensure the Firm continues to be able to meet its liabilities as they fall due; and
• Sufficient financial resources are retained in the Firm to promote long-term growth of the business.

The Firm has only one business area, investment advisory. For the financial year ending 30 April 2011, the partners retained their profit shares in the Firm and made no drawings.

The Firm is regarded as a proportionality Tier 4 firm. As such, the remuneration disclosure has been prepared with the FSA’s guidance on proportionality for Tier 4 firms in mind.