FCA disclosure requirements
Previously referred to as Pillar 3 Disclosure Requirements
As at 31 March 2022
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.
2.1 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.