Terms of Use

Persons who access the material made available by Walleve Capital, LLC ("WC") at its website ("Website") agree to the following terms:

Use of the Website

The entire content of this Website is subject to copyright with all rights reserved. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link to or use for any public or commercial purpose the Website or any of its contents without the prior written permission of WC. You may download contents of the Website for personal and non-commercial use, provided that you do not modify or alter such contents in any way, nor delete or change any copyright or trademark notice indicated on the Website. WC reserves and maintains complete title and full intellectual property rights for any contents downloaded from the Website, and no such title or intellectual property rights shall vest or be transferred in any way to you. All trademarks, logos, service marks, trade dress, slogans, copyrighted designs or other brand features of WC or its affiliated entities are owned by WC and may only be used pursuant to an explicit license agreement with WC.

Informational Only; No Offer of Securities

The Website is for informational purposes only and is not intended to be and should not be construed as an offer to sell, or the solicitation of an offer to buy, any interest in any entity or other investment vehicle. If such an investment opportunity should become available, a confidential private offering memorandum outlining such investment opportunity would be provided to you, and the information on the Website would be qualified in its entirety by reference to all of the information, including without limitation the risk factors, in the confidential private offering memorandum.

Certain Risks

Commodity futures and options trading involves substantial risk of loss and is not for everyone. An investment in any investment vehicle described, if made available, should be regarded as highly speculative in nature and could result in the loss of all of the capital invested. Investment in any investment vehicle described on the Website is intended only for experienced and sophisticated investors who could afford such a loss. The high degree of leverage that is often obtainable in futures and options trading can work against you as well as for you. The use of leverage can lead to large losses as well as gains. Past performance is not necessarily indicative of future results.

Disclaimer of All Warranties

THE SITE IS PROVIDED “AS IS” AND “AS AVAILABLE.” WC DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, OF ANY KIND WITH RESPECT TO THE SITE INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT OF INTELLECTUAL PROPERTY AND OTHER PROPRIETARY RIGHTS. WITHOUT LIMITING THESE GENERAL DISCLAIMERS, WC DOES NOT WARRANT THE AVAILABILITY, ACCURACY, COMPLETENESS, TIMELINESS, FUNCTIONALITY, RELIABILITY, SEQUENCING OR SPEED OF DELIVERY OF THE SITE OR ANY PART OF THE CONTENT.

Limits of Liability

IN NO EVENT WILL WC OR ANY OF ITS AFFILIATES, SUBSIDIARIES, CONTENT PROVIDERS, PREDECESSORS, SUCCESSORS OR ASSIGNEES OR THEIR RESPECTIVE CONTROL PERSONS, AGENTS OR EMPLOYEES (“WC PARTIES”) BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE OR CONSEQUENTIAL DAMAGES, HOWEVER CAUSED, ARISING OUT OF THIS TERMS OF USE, THE SITE OR ANY INABILITY TO ACCESS OR USE THE SITE. THE LIABILITY OF THE WC PARTIES IS LIMITED, EVEN IF ONE OR MORE OF SUCH PARTIES HAS BEEN ADVISED OF THE POSSIBILITY OF THE DAMAGES YOU SUFFER OR IF ANY REMEDY YOU HAVE FAILS OF ITS ESSENTIAL PURPOSE. THIS DISCLAIMER OF LIABILITY APPLIES TO ANY AND ALL DAMAGES OR INJURY, INCLUDING THOSE CAUSED BY ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DELETION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE FAILURE, THEFT, DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF OR USE OF ANY ASSET, WHETHER FOR BREACH OF CONTRACT, TORTIOUS BEHAVIOR, NEGLIGENCE OR UNDER ANY OTHER CAUSE OF ACTION.

Linked Websites

When you access certain links on the Website, you will leave the Website. WC is not responsible for any of the websites linked to the Website and does not endorse or accept any responsibility for the content of such websites nor the products, services or other items offered through such websites.

Information Collected; Privacy

WC does not collect information about you or your use of the Website through your use of the Website or use cookies on the Website. WC’s policy is to comply with the privacy legislation within each jurisdiction in which the WC operates.

Local Restrictions

The Website is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) the publication or availability of the Website is prohibited. Persons in respect of whom such prohibitions apply must not access the Website. By accessing any page of this website, you agree to be bound by the terms above and represent that you are free to access it without violating any law to which you may be subject. If you do not agree to the terms above, it is your responsibility to exit the Website.

Stewardship Code Disclosure Statement [UK only]:

Under Rule 2.2.3R of the Financial Conduct Authority’s Conduct of Business Sourcebook, Walleve Capital UK Limited (“WCUK”) is required to disclose the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (“the Code”) or, where it does not commit to the Code, to explain its approach. The Code is voluntary, and sets out a number of principles relating to engagement with UK listed companies. WCUK principally provides portfolio management and ancillary services across a number of asset classes and markets, following a number of diversified strategies. As a result, much of its investment activity relates to assets other than UK listed equities, and for the portion of investment focused on equities, exposure may not be taken directly. As such, opportunities for engagement with UK listed companies is limited, and the provisions of the Code are not viewed as materially relevant to WCUK’s investment strategy. Therefore, WCUK has chosen not to commit to the Code at this time.

Shareholders Rights Directive Disclosure Statement [UK only]:

Under Rule 2.2B.5.R of the Financial Conduct Authority’s Conduct of Business Sourcebook, Walleve Capital UK Limited (“WCUK”) is required to disclose whether it has an engagement policy in relation to issuers of investments traded on a regulated market or comparable overseas markets, or, where it does not comply with such requirements, to disclose why it has chosen not to do so. WCUK has chosen not to have an engagement policy for the reasons described. WCUK’s investment strategies covers a variety of asset classes and markets globally, including volatility, fundamental equities, quant and tactical strategies. For the portion of investments focused on equities, exposure is not typically taken on an activist investor basis. Therefore, an engagement policy has limited applicability to WCUK’s investment strategy given the limited opportunity to exercise stewardship. Were stewardship issues to arise, WCUK would take a consistent approach to engagement with issues and their management in all jurisdictions it invests, and in that regard, WCUK has policy on proxy voting. WCUK will keep this approach under periodic review.

Complaints Policy [UK only]:

If you are dissatisfied with an aspect of the services as provided by Walleve Capital UK Limited, you may write to: The Compliance Department, Walleve Capital UK Limited, Moss House, 15-16 Brooks Mews, London, W1K 4SD or contact compliance-EMEA@walleyecapital.com.

UK Privacy Notice:

This privacy notice tells you what to expect Walleve Capital UK Limited (“WCUK”) to do with personal information.

Contact details

Post: Walleve Capital UK Limited, 15-16 Brook's Mews, London, W1K 4DS.

Email: Compliance-EMEA@walleyecapital.com

What information we collect, use, and why

In order to assess employment opportunities, WCUK needs to process certain personal information. This may include your name, contact details, education details, employment history, education history, right to work information, details of any criminal convictions (e.g. Disclosure Barring Service results), tax and bank account information, and security clearance details. To provide current or prospective investors with information about Walleve, it may be necessary for us to process certain personal information such as names, telephone numbers and email addresses, and personal identification documents you may supply in order to confirm your identity.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure - You have the right to ask us to delete your personal information.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing - You have the right to object to the processing of your personal data.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice. Our lawful bases for collecting or using personal information include:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

Where we may get personal information from

• Directly from you.
• CCTV footage at our offices (for safety and security purposes).
• Publicly available sources.
• Previous employment.
• Third parties, such as credit reference agencies.

How long we keep information

We will hold personal information in accordance with our record retention protocol, and for the longest of the following periods:

• As long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us;
• The length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
• Any retention period that is required by law; or
• If WCUK believes in good faith that the law or other regulation requires us to preserve the information (for example, in relation to obligations to tax authorities or in connection with anticipated litigation).

Who we share information with

Others we may share personal information with include:

• Entities within the Walleve group.
• Professional or legal advisors.
• Regulatory authorities.
• Organisations we’re legally obliged to share personal information with.

Sharing information outside the UK

Due to the global nature of our business, personal information may be transferred outside of the UK. Where WCUK transfers personal data outside of the UK, it seeks to ensure a similar degree of protection is afforded by ensuring personal data is transferred only to persons outside the UK in the following circumstances:

• To persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
• To persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the UK government.
• In other circumstances the law may permit us to otherwise transfer your personal data outside of the UK.

Cookies and related technologies

Our website uses Google Analytics which collects information about how visitors use our website through the use of their cookies. We may use the information to help us improve our website and services. Information is collected in anonymous form, including where visitors have come to the site from and the pages they visited. By continuing to browse our website and/or use our services, you are agreeing to this privacy policy.

Contact us

If you have questions about this notice, you may contact us using the contact details above. If you have concerns about our use of information, you may also have the right to make a complaint to the Information Commissioner. For further instructions, please visit https://ico.org.uk.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

MIFIDPRU 8 Public Disclosure

Walleve Capital UK Limited

Reporting period: 1 January 2024 – 31 December 2024

Publication date: September 2025

1  Overview & Summary

This document sets out the public disclosures required under Chapter 8 of the Prudential Sourcebook for MiFID Investment Firms (“MIFIDPRU”). Walleve Capital UK Limited (“WCUK” or the “Firm”) is authorised and regulated by the Financial Conduct Authority and, for prudential purposes, is classified as a small non-interconnected (“SNI”) investment firm.

These disclosures relate to the Firm’s most recent financial year ended 31 December 2024, and have been approved for publication by the Firm’s governing body on 30 September 2025.

The Firm provides portfolio management services to Walleve Capital LLC (“Walleve US”). Walleve US is the Firm’s sole client, and parent entity.

2  Remuneration arrangements (MIFIDPRU 8.6)

The Firm has adopted remuneration policies and practices that comply with chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (‘SYSC’). In accordance with MIFIDPRU 8.6.2, the Firm makes the following qualitative disclosures:

• The Firm’s remuneration policies and practices are reviewed annually to ensure they are appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the Firm.
• The governing body is responsible for the Firm’s overall remuneration policy.
• The Firm ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all staff.

Key characteristics of the Firm’s remuneration policy are summarised below:

• Fixed pay is typically based on role requirements, experience, seniority and responsibility, and is designed with the goal of attracting and retaining the appropriate caliber of employee.
• Variable remuneration is typically based upon an employee’s individual performance and contribution.

As an SNI firm, and in accordance with MIFIDPRU 8.6.8, Walleve Capital UK Limited is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration. For the performance year ending 31 December 2024:

Total fixed remuneration awarded £ 6,149,206
Total variable remuneration awarded £ 11,869,396