Remuneration Code Disclosure

Altavista Investment Management UK LLP

The Firm is a Remuneration Code Proportionality Tier 4 Firm and has applied the rules appropriate to its Proportionality Tier. The Managing Partner is responsible for the Firm’s remuneration policy, and remuneration awarded to individuals is determined by the Managing Partner. Any variable remuneration is based on both individual and Firm performance and is adjusted in line with relevant capital and liquidity requirements of the Firm.
The Managing Partner has determined the Code Staff as at 31 March 2012 to be the two members of the LLP, both of whom are engaged in the Firm’s business of Investment Management. With only two individuals falling into the definition of Code Staff, the Firm considers that publishing data on remuneration (even in aggregate form) would breach the privacy of those individuals and be in breach of their data protection rights.
The Managing Partner will revisit these decisions as and when additional staff is added to the Firm.