# MIFIDPRU 8 DISCLOSURES *Annual disclosure of risk management objectives and policies, own funds and requirement and remuneration* *policies and practices, to meet the regulatory disclosure requirement set out in MIFIDPRU 8. This report covers* *the financial position as at 30th September 2025, as extracted from the audited financial statements of Benefit* *Street Partners Limited at that date.* ## 1 INTRODUCTION ### 1.1 ABOUT BENEFIT STREET PARTNERS LIMITED AND REGULATORY FRAMEWORK Benefit Street Partners Limited (“BSP Ltd” or “the Company”), formerly known as Alcentra Limited, is a wholly owned subsidiary of BSP Asset Management Limited ("BSPAML" or the "Parent"), formerly known as Alcentra Asset Management Limited, which is an indirect wholly owned subsidiary of Franklin Resources, Inc. ("Franklin"). Effective 26th January 2026, the Company changed its name from Alcentra Limited to Benefit Street Partners Limited, and the Parent’s name was changed to BSP Asset Management Limited as part of a broader global rebrand aligning all of Franklin’s private credit businesses. This report covers the financial position as at 30th September 2025, as extracted from the audited financial statements of Benefit Street Partners Limited at that date, while all other disclosures in relation to governance of the Company are stated as at 22 May 2026 (“the disclosure date”). The Company provides investment management and related services to investors globally, through investment products focused on sub-investment grade debt-capital markets in Europe, as part of the wider Franklin corporate group. The Company adopts, leverages and contributes to Franklin’s wider strategy, values, policies, procedures and approach to community engagement. Franklin's corporate values are reflected throughout the organisation. BSP Ltd is authorised and regulated by the Financial Conduct Authority ("FCA") and, as a non-SNI MIFIDPRU investment firm, it is subject to MIFIDPRU rules, including the requirement to disclose the below information annually: 1. Risk management objectives and policies – MIFIDPRU 8.2 2. Governance Arrangements - MIFIDPRU 8.3 3. Own funds – MIFIDPRU 8.4 4. Own funds requirement – MIFIDPRU 8.5 5. Remuneration policies – MIFIDPRU 8.6 ### 1.2 COMPANY OVERVIEW Benefit Street Partners Limited provides investment management and related services to investors globally through investment products that include open-ended funds, closed-ended funds and separately managed accounts. Since inception, the Company has evolved its product mix and offers a broader platform with an all- -encompassing sub-investment grade credit suite of products. BSP Ltd offers solutions for Senior Secured Loans, High Yield Bonds, Direct Lending, Special Situations, Structured Credit and Multi-Strategy Credit. The Company’s core strategy is to deliver risk-adjusted returns to its global institutional and intermediary investors in line with the long-term goals of its investors, while being committed to fostering lasting partnerships through transparency and outstanding service. ## 2 RISK MANAGEMENT OBJECTIVES AND POLICIES The Company’s Board of Directors (the “Board”) is focused on ensuring the Company embeds an effective Risk Management Framework, consisting of 1. Corporate Risk Management and 2. Investment Risk Management. ### a) Risk Appetite Statement Risk is a fundamental characteristic of the Company’s business and is inherent in every transaction undertaken. As such, the Company’s approach to risk taking and how it considers risk relative to reward directly impacts its success. Therefore, the Company has established limits on the level and nature of the risk that it is willing and able to assume in achieving its strategic objectives and business plan. The Company’s Risk Appetite Statement, which is set by the Board, serves this purpose and guides its decision- making processes, including how it pursues its business strategy and the method by which it manages risk and determines whether the risk position is within appetite. BSP Ltd is committed to ensuring all business activities are conducted with a clear understanding of the risks, maintaining a robust risk management framework, delivering excellence, ensuring transparent disclosure, and treating customers fairly, and meeting the expectations of major stakeholders, including clients, shareholders, ### 2.1 STATEMENT OF RISK APPETITE ### 2.2 RISK MANAGEMENT FRAMEWORK Through its responsibility to ensure effective internal risk management, the Board ensures that a robust Risk Management Framework is embedded within the business and that effective escalation channels exist to ensure any issues are identified and remediated. There are two key pillars of BSP Ltd’s Risk Management Framework: 1. Corporate Risk Management - risk management of the risks inherent in the operational activities of the Company; 2. Investment Risk Management - risk management of the client funds. ### 3 RISK MANAGEMENT PROCESS AND CONTROLS #### 3.1 RISK AND CONTROL SELF-ASSESSMENT The Risk and Control Self-Assessment (“RCSA”) is the Company’s primary operational risk and control identification and assessment tool. #### 3.1.1 KEY RISK INDICATORS Key Risk Indicators are in-place to monitor residual risk levels against risk appetite. ### 4 GOVERNANCE ARRANGEMENTS ### 4.1 CORPORATE STRUCTURE Benefit Street Partners Limited is a wholly owned subsidiary of BSP Asset Management Ltd which is an indirect wholly owned subsidiary of Franklin Resources, Inc. ### 4.2 THE BOARD OF DIRECTORS The Board embraces good practice in corporate governance and is charged with the responsibility for providing oversight of the activities and internal controls within the Company. | Director | Position | Other Directorships Held | | --- | --- | --- | | Catherine Bevan | Co-Head of BSP Ltd and Head of Structured Credit | Two | | Daire Wheeler | Co-Head of BSP Ltd and Head of European Liquid Credit | Two | | Henry Schoch | Chief Accounting Officer | None | ### 5 OWN FUNDS Maintaining sufficient regulatory own funds reserves is monitored and managed by the Board. #### 5.1 OWN FUNDS COMPOSITION BSP Ltd’s own funds are exclusively of Common Equity Tier 1 capital (CET1). | OF1 : Composition of regulatory own funds,in GBP thousandsAs at 30 September 2025 | | | | | --- | --- | --- | --- | | Ref | Item | Amount£’000s | Source based onbalance sheet in theaudited financialstatements | | 1 | Own funds | 84,081 | | | 4 | Fully paid up capital instruments | 25,659 | Balance sheet, page 18 | | 6 | Retained earnings | 58,422 | Balance sheet, page 18 | #### 5.2 RECONCILIATION OF OWN FUNDS TO AUDITED FINANCIAL STATEMENTS The following table provides a full reconciliation of the CET1 as at 30 September 2025. | | | | | | | --- | --- | --- | --- | --- | | | | a | b | c | | As at 30 September 2025 | | Balance sheet as inaudited financialstatements£'000s | Underregulatoryscope ofconsolidation | Cross-referenceto template OF1 | | Total Assets | 272,314 | | | | | Total Liabilities | 188,233 | | | | | Total Shareholders' equity | 84,081 | | | | ### 6 OWN FUNDS REQUIREMENTS MIFIDPRU 8.5 requires investment firms to disclose an own funds requirement as set out under MIFIDPRU 4.3.1. 1) Permanent minimum requirement (