MIFIDPRU 8 Disclosure

Hudson Bay Capital UK LLP

MIFIDPRU 8 Public Disclosures

For the period 1 January 2025 to 31 December 2025

Introduction

Hudson Bay Capital UK LLP (“the Firm”) is authorised and regulated by the UK Financial Conduct Authority (“FCA”) as a MiFIDPRU Investment Firm. This disclosure is in accordance with the FCA’s rules and guidance contained within the FCA’s prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”); specifically, chapter 8 of MIFIDPRU, which requires firms to make disclosures related to the Firm’s remuneration policy and practices.

This public disclosure document has been prepared based on the audited financial statement of the Firm for the financial period 1 January to 31 December 2025.

Overall approach

The Firm operates out of the UK exclusively as a sub-investment manager for its parent company, Hudson Bay Capital Management LP (“the Parent Firm”).

The Firm’s main business activity is sourcing and identifying investment opportunities through fundamental research, often informed by a variety of sources including, but not limited to, general investment experience, proprietary models, publications, research providers, experts and peer networks.

The overall approach for remuneration is driven largely by the Parent Firm’s fiduciary obligations to investors within the funds managed, which complement the Firm’s own obligations to operate a remuneration policy within the rules and regulations laid out in the FCA’s remuneration rules and guidance.

The Firm uses the four principles below to guide its remuneration practices:

Principle 1: Promotion of sound risk management

This includes ensuring the Firm’s remuneration practices encourage risk awareness, prudent risk taking and responsible business practices.

Principle 2: Avoid incentivising excessive risk-taking

Remuneration practices at the Firm, in particular those in relation to variable compensation, should avoid the incentivisation of excessive and potentially Firm-harming, risks.

Principle 3: Alignment with the Firm’s long-term interests

Consideration of the Firm’s overall business strategy, long-term objectives and interests form a critical part of all remuneration-based decisions. The Parent Firm and the Firm share a series of group-wide values designed to ensure there is a consistent long-term view of the environment the Parent Firm wishes to create for all its employees.

Principle 4: Regards for the Firm’s capital position

Both fixed and variable remuneration need to consider the Firm’s regulatory capital base and be subject to stress testing and budgeting disciplines to ensure future regulatory capital requirements are not compromised.

Governance

The Firm’s governing body is the UK FCA Management Body (“the Management Body”). The Management Body has approved a separate remuneration policy detailing information contained in this disclosure.

As of 31st December 2025, the Management Body has determined that, given the low complexity of the Firm’s operations and overall size of the Firm, a separate, standalone remuneration committee is not required. The Management Body has oversight of remuneration decisions and is assisted internally, by finance and human-resource specialists and externally, by legal and financial advisers.

The Management Body routinely conducts assessments of the roles and activities performed by individuals for the Firm to determine those individuals who amount to a material risk taker (“MRT”) as defined in the FCA handbook. The assessment is conducted at onboarding and at least annually by internal specialists and supported by external advisers. As of 31st December 2025, the Management Body identified two employees defined as an MRT and therefore subject to this disclosure.

Summary of remuneration

The Firm’s total compensation approach comprises fixed and variable remuneration broken out as follows:

Discretionary bonus awards, for the majority of the Firm’s employees, are based on a combination of financial and non-financial criteria:

Financial criteria

Includes, amongst other things, an assessment of the overall performance of the Firm’s parent and affiliates (“the Group”), the Firm’s contribution to the overall performance of the Group and the individual’s performance both in terms of their business unit and an individual’s contribution to these key measures.

Non-Financial criteria

These include the individual’s compliance with the Firm’s policies and procedures, risk guidelines and compliance policies.

The Firm has certain employees, including some members of the UK limited liability partnership, whose variable compensation criteria are more closely aligned to the performance of their own strategies at the end of the financial year. For any MRTs subject to the Firm’s remuneration policy, the variable portions of the remuneration detailed above are subject to contractual clawback clauses. The Firm does not currently operate a deferred remuneration plan as it is not subject to “extended” remuneration requirements under the MIFIDPRU rules.

Quantitative Disclosures

Under MIFIDPRU rules, the Firm is required to provide quantitative information in relation to:

• Its own funds requirements; and
• Aggregate total remuneration of its MRTs

As the Firm has only identified two MRTs for the year to 31st December 2025, it has determined that it would be inappropriate, as per MIFIDPRU rule 8.6.8(7)(b), to disclose certain information in relation to MRT remuneration.

Own Funds Requirement

The Firm calculates its own funds requirements as a non-SNI firm in accordance with MIFIDPRU 4.3

The Firm’s own funds threshold requirement is £6,612k derived from the FOR.

Own Funds: Main Features of Own Instrument Issued by the Firm

The Firm’s own funds consist of common equity tier 1 capital only (“CET 1”). The CET 1 instruments issued by the Firm consist of LLP member’s equity capital.