FCA Disclosure Requirements

FCA disclosure requirements

Previously referred to as Pillar 3 Disclosure Requirements

As at 31 March 2022

1. Introduction

1.1 Purpose and Scope

This document presents the FCA Disclosure Requirements (previously referred to as the Pillar 3 disclosures) for Titan Asset Management Ltd (‘TAM’ or ‘the Firm’) which is authorised and regulated by the Financial Conduct Authority (‘FCA’). From 1st January 2022, TAM has been regulated under the FCA’s new Investment Firm Prudential Regime (‘IFPR’) as an SNI MiFID investment firm. Previously it was regulated as a BIPRU €50K investment firm in accordance with the FCA’s GENPRU and BIPRU rules and the relevant sections of the Banking Consolidation Directive and Capital Adequacy Directive. These disclosures are prepared on an annual basis solely for the purposes of complying with the FCA rules at MIFIDPRU 8 for SNI investment firms. It requires TAM to publicly disclose certain details about its remuneration arrangements. As at 31st March 2022 TAM is relying on the FCA’s transitional provision at TP 12.8(2) R to apply BIPRU 11.5.18R to BIPRU 11.5.20R regarding its disclosure of remuneration policy and practices for those categories of staff whose professional activities have a material impact on its risk profile.

1.2 FCA Disclosure Policy

The disclosures have not been audited and do not form part of the annual audited financial statements of the Firm. However, they are subject to internal review and verification and are approved by TAM’s Board of Directors. TAM’s disclosures are considered to be appropriate to its size and internal organisation, and to the nature, scope and complexity of its activities. The Firm may consider it appropriate to publish updated disclosures more frequently should a significant change in business or operating environment require this.

2. Remuneration

2.1 Policy and Governance

TAM has established a remuneration policy in accordance with the FCA’s Remuneration Code, which is the responsibility of the Board. The aim of the remuneration policy and governance framework is to establish, implement and maintain remuneration policies, procedures, governance and practices that:

  • are in line with the business strategy, and the sustained, long-term performance of the Firm;
  • neither encourage, nor reward risk taking outside the Board’s appetite; and
  • promote sound and effective risk management.

The Remuneration Policy is approved by the Board. TAM’s Staff Committee is responsible for all aspects of staffing, including the remuneration of senior staff. The committee ensures that the remuneration arrangements comply with the Remuneration Policy and that staff rewards support the strategic aims of the business, its corporate culture and approach to risk management.

2.2 Link between Pay and Performance

Remuneration at TAM is comprised of fixed pay and variable, performance-related pay. Fixed pay refers to the employee’s base salary. This forms the core element of pay and reflects the individual’s role and position within the Firm. Variable, performance related pay refers to discretionary bonus payments. The Firm considers both individual and firm level performance as factors to determine bonus payments. For the purposes of these remuneration disclosures the Board have identified four staff who have a material impact on the risk profile of the Firm; for the financial year to 31 March 2022, the total remuneration for these staff was £273,794.

Our funds have moved

The previous Titan Asset Management funds have now moved to a new site and trading entity, Titan Investment Solutions. Titan Asset Management now holds the MPS only.

Titan Sustainable MPS


Titan Active MPS




Titan Passive MPS


Paul Hunt


Paul Hunt is a proven business leader and entrepreneur with over 30 years’ experience and track record of scaling businesses across multiple sectors. Hunt is highly experienced in business turnarounds, strategic planning and creating a positive people culture geared for success.

David Chandler

Portfolio Assistant

David is responsible for providing operational support to the fund managers. David has passed the CFA UK IMC and graduated in 2018 with a degree in Economics and Business Management from the University of Sheffield.

James Peel, CFA

Portfolio Manager – ESG

James is a Portfolio Manager at Titan Asset Management and is responsible for Titan’s approach to sustainable investing. He previously worked as a researcher at the British Chamber of Commerce in Taipei. James graduated in 2018 from the University of St Andrews, where he studied economics. He is a CFA charter holder and has passed the CFA UK Investment Management Certificate (IMC), the CFA UK Certificate in ESG Investing, and the CFA UK Certificate in Climate and Investing (CCI).

Jonah Levy, CFA

Portfolio Manager – Physicals

When not collecting various minerals and mining memorabilia, Jonah can be found managing the physical allocations at Titan Asset Management. Prior to Titan he worked at Tavistock Wealth for 3 years, having previously gained experience in Holland at an oil brokerage, and in London at an energy trading house. Jonah is a CFA charter holder, having graduated from St. Andrews University with an MA in Management and Economics.

Alex Livingstone, CFA

Head of Trading – FX & ETFs

Alex is responsible for the ETF trading and FX strategy at Titan Asset Management and has executed over £5 billion of trades during his prior 4 years at Tavistock Wealth. Alex also assists in the wider portfolio management of the CIP specialising in technical analysis and risk management. He is a CFA charter holder and holds an BSc in Retailing, Marketing and Management from Loughborough University.

Sekar Indran, CFA

Senior Portfolio Manager – Equities

Sekar is responsible for managing the team’s equity investments. He helped expand the investment proposition over five years at Tavistock Wealth and continues this role at Titan Asset Management. Sekar has prior financial services experience at Barclays and Allianz. He is a CFA charter holder and holds a BSc degree in Industrial Economics from the University of Nottingham.

John Leiper, MSc, CFA, FDP, CFTe

Chief Investment Officer

John Leiper is the Chief Investment Officer of Titan Asset Management and carries direct responsibility for all investments in the Centralised Investment Proposition (CIP) at the firm. John has 15 years’ experience in financial markets having previously worked in a variety of roles at RBS, Morgan Stanley, Credit Suisse and Tavistock Wealth. John Leiper is a CFA and FDP charter holder and a member of the Society of Technical Analysts. He holds a BSc degree in Economics from Warwick University and an MSc degree in Economic History from the London School of Economics.

Matthew Cureton


Matthew has been an intrinsic part of Haibun (now Titan Alternatives) since its formation. As a Co-Founder, he has focused on developing relationships with clients, providers, and companies seeking funding.

Matthew’s personal involvement with the fund-raising activities at Titan Alternatives starts at the very beginning of each journey.

Incorporating the due diligence process, meeting with the various management teams, and visiting companies on site, to then being involved with the marketing documents, hosting presentations, and facilitating the investments for clients. Matthew also continues to monitor and report on the investment throughout its life, which has included him taking on Non-Executive Directorships or observer roles on various company boards.

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Titan Alternatives Limited is an Appointed Representative of Sturgeon Ventures LLP FRN 452811, who are authorised and regulated by the Financial Conduct Authority (FCA) and entered on the Financial Services Register with FRN 974252

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