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.

Jim Henwood

Co-Founder

Since Co-Founding Haibun (now Titan Alternatives) Jim has proficiently driven all aspects of the firm’s operations, successfully developing the systems and controls required for Titan Alternatives to meet its regulatory and legal requirements.

With the firm’s focus firmly on providing efficient client servicing, Jim has also built the proprietary client reporting system and continues to refine the internal procedures to ensure the firm controls its affairs responsibly and effectively.

Jason Rungasamy

Co-Founder

Jason is a Co-Founder and has heavily influenced the company’s growth, successfully leading a number of bespoke private company fundraises.

Having worked within the financial services sector for over 20 years, he has gained the experience, knowledge, and insight to provide professional clients with relevant and beneficial assistance with their personal finances. Jason’s expertise lies in securing clients’ financial well-being and providing investment opportunities that sophisticated investors can consider as part of a diversified portfolio.

Stuart Knight

Co-Founder

Since co-founding Haibun Wealth Limited, now Titan Alternatives, Stuart has been instrumental in the development of the firm and its standing in this specialised market.

Working within private client wealth management since 1998, he has catered for clients occupying significant roles across various financial institutions. Stuart’s expertise is fund research, gaining allocations to leading hedge funds and providing investment opportunities for sophisticated investors.

Matthew Cureton

Co-Founder

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.

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

Factsheet

Titan Active MPS

Factsheet

Titan ACUMEN MPS

Factsheet

Titan Passive MPS

Factsheet

Welcome to Titan Alternatives

This site is intended for Professional Clients, Self-certified Sophisticated Investors, and High-Net-Worth Individuals only.

Please read our Terms of Use and the important disclosure below before proceeding.

This Website is published solely for informational purposes and has no regard to the specific investment objectives, financial situation, or particular needs of any person.

Information contained on this website details the services and products of Titan Alternatives Limited and is intended for persons in the UK who qualify as Professional Clients, Sophisticated Investors, or High-Net-Worth Individuals. Promotion of the products and services by Titan Alternatives Limited is restricted to these investor types. If you are not able to qualify as one of these investors, please disregard the website.

Any reference made to past performance is not a reliable indicator of future results. The investment products promoted by Titan Alternatives Limited are not mainstream retail products. They are generally higher risk and require a longer investment term. You may get back less than you invest. Tax relief referred to may be subject to change and will depend on an investor’s individual circumstances.

Titan Alternatives Limited recommend that investors seek specialist tax or financial advice before investing. Titan Alternatives Limited does not provide tax or financial advice and the information on this website should not be construed as such.

A number of rules and protections which would otherwise apply to you will not apply if you accept to be treated as a Professional Client, Sophisticated Investor, or High Net Worth Individual.

Please click below links for rules on client classification:

Professional Client

Self-Certified Sophisticated Investor

High-Net-Worth Individual

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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