Regulation

SAB Securities Limited

Pillar 3 Disclosure (Unaudited)

For the year ended 31 October 2025

1. Disclosure Policy and Regulatory Framework

This Pillar 3 disclosure is prepared in accordance with the UK Investment Firms Prudential Regime ("IFPR"), as implemented through the Financial Conduct Authority ("FCA") Prudential sourcebook for MiFID Investment Firms ("MIFIDPRU"). It is produced in compliance with the public disclosure requirements set out in MIFIDPRU 8.

The purpose of this disclosure is to provide information on SAB Securities Limited’s ("SAB" or the "Firm") risk management framework, capital adequacy, liquidity position, and governance arrangements, thereby promoting market discipline and transparency.

This disclosure is published annually and is aligned with the Firm’s audited financial statements for the year ended 31 October 2025. The information contained herein is unaudited and does not form part of the Firm’s statutory financial statements.

Information is considered material if its omission or misstatement could influence the economic decisions of users. Where information is deemed immaterial, it may be omitted in line with the proportionality principles of IFPR.

2. Background to the Firm

SAB Securities Limited is authorised and regulated by the Financial Conduct Authority. The Firm operates as an investment advisory and securities broking business, providing regulated services to professional and intermediate clients.

The Firm does not deal on own account, does not operate a trading book, and does not engage in underwriting or market making activities. Its business model is intentionally conservative and proportionate to its size, nature, and complexity.

For prudential purposes, SAB is classified as a non-Small and Non-Interconnected (non-SNI) investment firm on the basis that it holds client money.

3. Governance, Risk Management and ICARA

3.1 Governance Framework

The Firm operates within the Senior Managers and Certification Regime ("SM&CR"). Responsibility for risk management, capital adequacy, liquidity, and regulatory compliance rests with the Board and senior management. Governance arrangements are proportionate and designed to ensure clear accountability, effective oversight, and timely escalation of material risks.

3.2 ICARA Process

In accordance with IFPR requirements, SAB has implemented an Internal Capital and Risk Assessment ("ICARA") process. The ICARA replaces the previous ICAAP framework and is designed to ensure compliance with the Overall Financial Adequacy Rule ("OFAR").

The ICARA process:

• identifies material harms that could arise from the Firm’s ongoing operations or from an orderly wind-down;

• assesses the adequacy of own funds and liquid assets relative to those risks; and

• considers recovery and wind-down planning.

The ICARA is forward-looking, proportionate, and integrated into the Firm’s business planning and governance processes. It is reviewed at least annually and approved by the Board. The most recent ICARA was approved in December 2025.

3.3 Material Risks and Harms

The principal material risks identified through the ICARA include:

• Business and concentration risk, arising from a relatively small client base;

• Operational risk, including systems, process, and human error;

• Regulatory and compliance risk, mitigated through governance oversight and external professional support;

• Reputational risk, particularly in relation to client service and complaint handling; and

• Liquidity and capital risk, mitigated through maintaining capital and cash balances materially above regulatory minima.

The Firm has concluded that existing controls, together with its capital and liquidity resources, are sufficient to mitigate these risks.

4. Capital Adequacy

4.1 Own Funds Requirement

Under MIFIDPRU, the Firm’s Own Funds Requirement ("OFR") is the higher of:

• the Permanent Minimum Requirement ("PMR");

• the Fixed Overheads Requirement ("FOR"); and

• the applicable K-Factor Requirement.

As the Firm holds client money, its PMR is £150,000.

Based on its business model and activities, the PMR represents the binding constraint and therefore determines the Firm’s Own Funds Threshold Requirement ("OFTR").

4.2 Capital Resources

As at 31 October 2025, the Firm held capital resources comprised entirely of Common Equity Tier 1 ("CET1") capital.

• CET1 capital: approximately £277,165

• OFTR: £150,000

• Capital surplus: approximately £127,165

The Firm has no Additional Tier 1 or Tier 2 capital instruments.

The Board is satisfied that the Firm maintains own funds materially in excess of its regulatory requirements.

5. Liquidity Adequacy

The Firm is subject to the Basic Liquid Assets Requirement under MIFIDPRU. Liquid assets are held predominantly in cash deposits with regulated credit institutions and qualify as core liquid assets.

The Firm sets its liquid assets threshold requirement as the higher of:

• the amount required to support an orderly wind-down; and

• the amount required to support ongoing operations.

As at 31 October 2025, the Firm’s cash balances significantly exceeded its basic and threshold liquidity requirements. The Board is satisfied that the Firm is resilient to short-term liquidity shocks.

6. Stress Testing and Recovery Planning

As part of the ICARA process, SAB conducts stress testing over forward-looking financial projections. Stress scenarios include:

• a one-off material cost shock;

• sustained increases in overheads; and

• a downturn in trading activity and revenue.

The results of these stress tests indicate that the Firm would remain able to meet its own funds and liquidity requirements under severe but plausible conditions.

Where thresholds are approached or breached, recovery actions are available, including the injection of additional capital by shareholders.

7. Wind-Down Planning

The Firm has prepared a documented wind-down plan designed to ensure an orderly and solvent exit from the market, should that become necessary. The plan assumes:

• cessation of new business;

• orderly management and transfer or closure of client positions;

• continued compliance with client money and regulatory obligations; and

• transparent communication with the FCA and stakeholders.

The Fixed Overheads Requirement is used as the primary wind-down trigger, consistent with the Firm’s ICARA assessment. The Firm estimates that an orderly wind-down could be completed within approximately two months at a modest cost, which is fully covered by existing capital and liquidity resources.

The Board has concluded that the Firm could execute a wind-down without causing undue harm to clients, markets, or counterparties, and without reliance on external funding.

8. Remuneration

The Firm is subject to the IFPR Remuneration Code set out in SYSC 19G. Remuneration policies are designed to promote sound and effective risk management and to avoid incentives that could encourage excessive risk-taking.

Given the size and nature of the Firm, the Remuneration Code is applied proportionately. The Firm does not operate complex variable remuneration structures, and no deferred remuneration, retention instruments, or performance adjustment mechanisms are considered necessary.

During the year, remuneration was paid in respect of investment advisory and arranging services. No remuneration was paid to identified risk takers as defined under IFPR.

9. Conclusion

The Board considers that SAB Securities Limited maintains a robust, proportionate, and effective prudential framework. The Firm holds capital and liquid assets materially above regulatory requirements and has appropriate arrangements in place to manage risks, withstand stress scenarios, and execute an orderly wind-down if required.

This disclosure has been approved by the Board and is published in accordance with MIFIDPRU 8.

Approved by the Board of Directors

Date: 31st October 2025