Pillar 3 Disclosure
Pillar 3 Risk Disclosure Statement
Cameron Hume Limited (“the Company”) is required to disclose information relating to the capital it holds and each category of risk it faces in order to assist users of its accounts and to encourage market discipline. These disclosures aim to provide information on the risk exposures faced by the Company and the risk assessment process it has put in place to monitor these. These disclosures are complementary to the Company’s Capital Resources Requirement (CRR) calculation (Pillar 1) and the internal review of its capital adequacy (Pillar 2).
The Pillar 3 disclosure document has been prepared by the Company in accordance with the requirements of BIPRU 11 and is verified by the board of the Company (“the board”). All figures unless otherwise stated are as at 30 September 2020 and are based on the Company audited annual accounts to 30 September 2020.
This Pillar 3 disclosure will normally be updated on an annual basis after the 30 September year-end and published as soon as practical when the audited annual accounts are finalised. Disclosures will be made at other dates if appropriate.
The Company has made no omissions on the grounds that information is immaterial, proprietary or confidential.
The firm maintains capital resources as follows:
|Capital||30 September 2020/£’000|
|Tier 1 Capital||1,441|
|Tier 2 Capital||0|
|Tier 3 Capital||0|
|Deductions from Tier 1 and 2||0|
|Total Capital Resources||1,441|
Note: no innovative tier one capital is held
The capital resources detailed above are considered adequate to continue to finance the Company. The Company continues to invest capital to grow the business further and will consider further capital injections as and when necessary.
The Company has established a risk management process to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the board. The Head of Compliance has responsibility for the implementation and enforcement of the Company’s risk principles. The Company has a comprehensive policy framework governing: enterprise risk management; liquidity risk; credit risk; information security; business continuity; customer relationship management; sourcing; regulatory and compliance risk; and all employment-related matters. These policies are formally approved and then reviewed annually for effectiveness by the board and are maintained by the Head of Compliance. This system of internal control seeks to provide reasonable, and not absolute, assurance against material misstatement or loss.
The Company operates to a formal planning and review cycle which includes periodic formal reassessment of the risk control matrix, compliance with SYSC requirements and the ICAAP. Monthly management accounts are reviewed by the Company’s Management Committee and the adequacy of the Company’s capital resources is reviewed on a monthly basis. Budget re-forecasts are considered by the board twice annually and the Company’s strategic plan is updated and reviewed annually.
Updates on compliance monitoring and operational issues are made to the Management Committee and the board on a regular basis.
The main credit risk to which the Company is exposed is in respect of its debtors. The Company aims to deal with a small number of large institutional clients and undertakes Know Your Customer (KYC) and credit-checking processes as part of its client take-on process.
The credit control process is operated by a director of the Company and any significant outstanding balances are identified and reported to the board on a monthly basis as part of the review of management accounts.
The Company has a limited number of credit exposures relating to its investment management business. Trade and other receivables are 100% risk weighted as per BIPRU 3.4.52 . Cash and cash equivalent assets are zero risk weighted as per BIPRU 3.4.129.
The Company holds no trading book positions and is therefore not exposed to market risk.
The Company does not fall within the scope of the liquidity risk requirements of COLL and the relevant risk is therefore that the Company, although solvent, either does not have available sufficient financial resources to enable it to meet its obligations as they fall due, or can secure such resources only at excessive cost.
Company policy is to maintain a positive cash balance at all times, taking into account the forecast future expenditure of the Company. Capital subscriptions are planned to allow maintenance of a positive cash balance. (1)
The directors consider this general policy to be an effective method of managing liquidity risk:
• the financial performance of the Company has been close to budget for the four years of trading, suggesting that the financial obligations of the Company are well understood and planned; and
• the Company has maintained positive cash balances to date and has been able to meet all of its obligations as they fall due.
The Company reviews its risk control matrix on a six-monthly basis. Risks are categorised according to likelihood and impact. The Company has no appetite for risks that are either: high impact and at least “unlikely”; or “likely” and at least medium impact. Mitigating strategies are developed and the formal updates consider: existing and new risks; mitigating strategies; and actions.
The Company’s revenue is reliant on its ability to win and retain new investment mandates. The most significant risk for the Company is therefore that it fails to win sufficient new mandates or to retain existing mandates and, consequently, under-trades. This risk is mitigated by the Company holding significant levels of capital to allow the Company to continue to operate as a going concern in the event of a period of under-trading.
The directors of the Company note the requirement of BIPRU 2.2.46 to hold additional capital to mitigate any weakness in the overall control environment. The directors do not consider that any additional capital needs to be held for this reason. With specific reference to BIPRU 2.2.46:
1. The directors note the general obligation under SYSC to take appropriate practical responsibility for their Company’s arrangements and that the Company must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems, SYSC 1.2 (G). In particular the requirements to have: robust governance arrangements, SYSC 4.1.1 (R); business continuity provisions, SYSC 4.1.6 (R); personnel with the skills, knowledge and expertise necessary for the discharge of their responsibilities SYSC 5.1.1 (R); and to have effective processes to identify, manage, monitor and report the risks to which it is or might be exposed SYSC 7.1.1 (G). The Company performs and documents an annual review of compliance with all SYSC requirements.
2. The financial results of the Company are properly approved by the board in a timely fashion. The executive directors of the Company monitor the management accounts on a monthly basis.
3. The Company always considers and where required acts on internal and external information on the business and control environment, including the outcomes of compliance monitoring reviews, external security reviews, all mandate compliance breaches and near misses, audit management letter points and the outcome of its own internal monitoring processes.
A number of the Company’s policies relate specifically to operational matters and provide the framework for the management of operational risk: the employee handbook; compliance manual; information security policy; business continuity policy; health and safety and fire policies; and sourcing policy.
The Company has put in place a number of insurances to mitigate operational risks: professional indemnity and directors and officers liability cover (placed in the London market through JLT Specialty Ltd); and a comprehensive office policy.
The Company has a comprehensive business continuity framework and conducts on-going diligence on the business continuity arrangements of critical outsourcing partners.
Operational risks are covered in the preparation and review of the Company’s risk control matrix and to the extent that these can be identified as such, they are valued and reported separately. There are no net operational risks outside of the Company’s stated appetite.
Regulatory and Compliance Risk
Regulatory and compliance risk is the risk that a change in the laws and regulations will materially affect the firm’s business or markets in which it operates. The Company actively monitors and implements changes as required to enable it to meets its on-going regulatory obligations.
Fixed Overhead Requirement
The Company’s Pillar 1 capital resources requirement is determined by its Fixed Overhead Capital Requirement (FOR) determined in accordance with GENPRU 2.1.53. The Company monitors the FOR on a monthly basis with reference to the three month forward rolling forecast of non-variable expenditure. The variable costs deducted when calculating the FOR are variable professional fees, marketing costs and discretionary staff bonuses.
The Company’s ICAAP methodology is designed to capture the key risks faced by the Company under Pillar 2. The ICAAP is reviewed at least every six months and the annual update is formally adopted by the board. The ICAAP also considers the Company’s longer term capital outlook across a range of scenarios and is integrated into the Company’s annual budgeting and financial planning process.
The findings of the most recent ICAAP analysis are:
• the CRR for the financial year-ended 30 September 2021 is determined by the fixed overhead requirement (FOR) and is projected to be £550k;
• after consideration of the risk matrix at Q4 2020 and the projected costs of an orderly wind-down of the Company, the directors believe that the Company should aim to maintain Pillar 2 capital of £700k, leading to an overall ICAAP of £1,250k; and
• the business plan forecasts an adequate level of capital resources throughout the financial year-ended 30 September 2021.
Remuneration Code Disclosure
The Company is a BIPRU limited licence firm and as such falls under proportionality level three as defined by the FCA. Accordingly:
• the board currently acts as the remuneration committee of the Company; and
• disclosures are made under BIPRU 11.5.18R.
All remuneration decisions, including: initial salary; subsequent salary reviews; and incentive payments are determined by the board. Variable remuneration is subdivided into short- and long-term incentives with the absolute sum to be awarded and the considerations supporting such awards being at the sole discretion of the board.
Generally, the factors considered by the board in making remuneration decisions will be:
• market rate, with reference to individuals previous employment and more general market data sourced from the Company’s HR and recruitment consultants;
• Company performance;
• investment performance (for portfolio management staff);
• individual performance with respect to documented individual role descriptions, objectives and the agreed Company competencies;
• compliance with Company policies and procedures; and
• the Company’s capital resources with respect to both the capital resources requirement and the working capital requirements.
The Company has made provision for long term incentive payments that are deferred for a period of time (subject to satisfactory performance, conduct and on-going employment), thereby encouraging appropriate risk-taking and alignment to the strategy and long-term success of the business.
Quantitative Remuneration Data
|Business Area||Aggregate compensation expense year-ended 30/9/2020/£’000|
|Operations/Sales & Marketing||250|
|Code Staff||Aggregate compensation expense year-ended 30/9/2020/£’000|
(1) It is possible at any point that the requirement to hold capital in accordance with the Company’s ICAAP may become more onerous than the requirement to maintain liquid working capital. To date, the contribution of the value of illiquid assets to overall capital resources has meant that the preservation of liquid working capital has been the more onerous requirement.