The Company’s investing policy is focused primarily on companies operating within the financial services and associated markets.  Within that over-arching strategy, the Company applies the following criteria in reaching an investment decision. 

Stage of development 

Usually (but not necessarily) investee businesses will have been operating for a number of years.  The investee business may not yet have achieved profitability. 

Investment approach 

The Company may take either minority or majority equity positions in investee companies. Investments may be passive or involve an active role in the strategic and operational development of the business, depending on the nature of the opportunity. 

Where appropriate, the Company may seek to take a controlling interest in an investee company. The level of ownership and degree of involvement will be determined by the Board on a case-by-case basis. 

Geographical focus 

The Company does not apply strict geographical restrictions to its investment activities. While the Company expects that many of its investments may have a connection to the United Kingdom or Europe, it may also invest in businesses based in other jurisdictions where the Board considers there to be a compelling strategic or financial rationale. 

Sector focus 

The Company mainly focuses on investments within the financial services sector, targeting businesses that demonstrate strong growth potential, innovative financial solutions, and scalable business models. Primary areas of interest include fintech, asset management, insurance, and banking, with an emphasis on companies that leverage technology to enhance efficiency, accessibility, and financial inclusion. 

Corporate status 

The Company may invest in both private and publicly traded companies. In the case of private companies, there is no requirement for a public listing and investments may be structured with a range of potential exit strategies 

Investment instruments 

The Company will generally expect to make investments in the form of equity.  It will also consider investing in loan stock which is convertible (usually at the Company’s option) into equity shares. The Company’s investments will rarely be in the form of pure debt. 

Investments will usually be in the form of cash but may also take the form of an issue of new ordinary shares in the Company. 

Holding period 

The Company does not apply a fixed holding period to its investments. The timing of any realisation will depend on the specific circumstances of each investment and the Board’s assessment of how best to maximise value for shareholders. 

Accordingly, investments may be held over the short, medium or longer term as appropriate. 

The Directors intend to re-invest the proceeds of disposals in accordance with the Company’s investing policy unless, at the relevant time, the Directors believe that there are no suitable investment opportunities in which case the Directors will consider returning the proceeds to shareholders in a tax efficient manner. 

Number and size of investments 

There is no limit on the number of projects into which the Company may invest except the capacity of the Company’s investment team to appraise and monitor them. Similarly, the monetary quantum of each investment is a factor of the funds available to the Company at the point of investment. Both the number and size of investments will therefore vary according to the Company’s human and monetary resources. Each of these will be referred to in the Company’s annual and interim reports. As investments are made and new promising investment opportunities arise, further funding of the Company may be required to enable the Company to make further investments. 

The Company will seek to pursue a balanced portfolio of an even mixture of early stage, pre-liquidity event and liquid investments. While the aim is to have the portfolio split fairly evenly between the different stages of liquidity, there will be no set criteria for the proportion of the portfolio which will be represented by each investment type. 

The size and percentage ownership of each investment will vary depending on the opportunity and the Company does not impose any fixed limits on its level of ownership in an investee company.  

Opportunistic investments 

The Company may, from time to time, invest in opportunities which fall outside its core focus where the Board considers there to be a compelling value opportunity. The size and nature of such investments will be determined by the Board having regard to the Company’s overall portfolio and investment strategy.  

Follow-on investments in existing investment portfolio 

In addition, the investing policy will enable the Company to make, where the Board deems appropriate, follow-on investments in the Company’s investment portfolio which was in place as at March 2025 prior to the change in focus to financial services and which predominately are companies in the disruptive technology sector. 

Investment appraisal 

In order to mitigate investment risk, the Directors will carry out a thorough appraisal of each potential investment. This appraisal may include site visits, analysis of financial, legal and operational aspects of each investment opportunity, meetings with management, risk analysis, review of corporate governance and anti-corruption procedures and, where the Directors see fit, the seeking of third party expert opinions and valuation reports.  

Nature of returns 

It is anticipated that returns to the Company will be delivered through a combination of capital gain, dividend income and interest on convertible loans. 

The Company’s level of involvement in its investee companies, including whether it seeks board representation, will depend on the nature of the investment and the level of ownership. In those instances where it is felt desirable and appropriate for the Company to appoint a director, the fee earned from any such post held by a director or employee of the Company would be payable to the Company and form part of the return earned by the Company on its investment. 

Cash held by the Company pending investment, reinvestment or distribution will be managed by the Company and placed on deposit with banks so as to protect the capital value of the Company’s cash assets. The Company may, where appropriate, enter into agreements or contracts in order to hedge against interest rate or currency risks. 

Review of investing policy 

The Directors will keep the investing policy under continuous review and will make and announce any non-material changes or variations as may be appropriate.  Any material change or variation to the investing policy will be subject to the prior approval of shareholders.