Bluetrain Capital Limited (FRN: 1011322)
Disclosure dated as of: September 2026
For the financial period as of: 31 December 2025
Overview and summary
Bluetrain Capital Limited (“Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”) as a Full-scope Alternative Investment Fund Manager (“Full-scope AIFM”) and categorised by the FCA as a Collective Portfolio Management Investment firm (“CPMI firm”).
Because of its MiFID Top-Up permissions as a CPMI firm, the Firm is subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) Handbook.
For the purposes of MIFIDPRU, the Firm has been classified as a small non-interconnected firm (“SNI firm”).
The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.
This Public Disclosure Document has been prepared based on the audited financials as of 31 December 2025, covering the financial period 1 July 2024 to 31 December 2025.
The Firm pursues a low-net barbell strategy comprised of Global Risk Arbitrage (Arbitrage) and Equity Long/ Short (ELS) and seeks to achieve superior risk adjusted returns with low correlation to major indices and with a focus on alpha generation.
Remuneration arrangements
The Firm has adopted a remuneration policy and procedures that comply with the requirements of 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 remuneration 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 Firm’s Board of Directors is directly responsible for the 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.
The Firm does not benefit from exceptional government intervention.
The Firm’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categorised as either fixed or variable remuneration.
Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non- revocable and not dependent on performance.
Variable remuneration is based upon staff members performance or, in exceptional cases, other conditions.
Performance reflects the long-term performance of the staff member, as well as performance in excess of the staff member’s job description and terms of employment; and
Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit.
The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and that, generally, the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.
The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.
Quantitative Remuneration
All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded.
As an SNI firm, and in accordance with MIFIDPRU 8.6.8, the Firm is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.
For the reportable 18-month period ending 31 December 2025:
