MIFIDPRU & Remuneration Code Disclosures

Background

This is the disclosure made in accordance with the UK Financial Conduct Authority (FCA) The Prudential sourcebook for MiFID Investment Firms (MIFIDPRU). The rules in MIFIDPRU provide that as a Small Non-Interconnected firm (SNI) we must disclose the matters set out below. the firm may omit one or more of the required disclosures if it believes that the information is immaterial.  Unless stated as otherwise, all figures contained in this disclosure are based on the firm’s audited annual reports for the year ending 31st March 2022.

Frequency

These MIFIDPRU disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of the firm’s annual Report & Accounts.

Verification

The information contained in this disclosure has not been audited by our firm’s external auditors and does not constitute any form of financial statement.

Publication

Our firm’s MIFIDPRU disclosure reports are published on our website.

 

Risk management objectives and policies

Our risk management policy reflects the FCA requirement that we must manage a number of different categories of risk. These include: liquidity, credit, market, interest rate, business and operational risks.

 

Liquidity risk

The firm manages all cash and borrowing requirements to maximise potential interest income whilst ensuring the firm has sufficient liquid resources to meet the continued operating needs of the business. This is supported by a robust budgeting and forecasting process which has the full involvement of the senior management team.

 

Credit risk

The main credit risk for the firm relates to advisory fees, being the risk that a client does not pay amounts due for services provided. This risk is mitigated by the low number of clients in respect of which amounts are due at any one time. The risk of non payment is also reduced due to the nature of the clients as they i.e. they are typically wealthy individuals.

The firm’s revenues include annual management charges received from clients based on a percentage of client assets under management. These charges are made directly to the clients’ portfolios, and therefore the credit risk relating to this income is minimal.

 

Interest rate risk

The firm does not have any bank loans.

 

Business risk

The firm’s business risk assessment principally takes the form of a fall in assets under management following a market downturn that leads to lower management fees, although other risks such as loss of advisers and systems failures are also considered. To mitigate our business risk, we regularly analyse various different economic scenarios to model the impact of economic downturns on our financial position.

 

Operational risk

Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.

Major sources of operation risk include: outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.

The firm operates a robust risk management process which is regularly reviewed and updated with details being provided to all staff. The firm’s Compliance Oversight is responsible for the periodic reviews and recommending any changes to the Board.

All senior management will bear responsibility for internal controls and the management of business risk as part of their accountability to the board.

Individuals are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their line manager.

The Compliance Oversight will provide the board with regular reports on all significant risk issues.

 

Other risks

The firm operates a simple business model. Accordingly, many of the specific risks identified by the FCA do not apply.

 

Remuneration Code Disclosure

The firm is subject to the MIFIDPRU Remuneration Code. For the year ending 31st March 2022 relevant remuneration was as follows:

Fixed Remuneration                      £2,675,353

Variable Remuneration                 £     34,800

Our remuneration policy is provided as a pdf document.