Glenernie
Capital
MODERN SLAVERY STATEMENT
Introduction
Glenernie Capital Ltd (“Glenernie”) has made the following statement on modern slavery and human trafficking pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”).
The Act sets out a range of measures on how modern slavery and human trafficking should be dealt with in the UK to combat modern slavery from occurring in business supply chains and organisations.
Business and Organisation Structure
Glenernie Capital Ltd is an investment manager which is authorised and regulated by the UK Financial Conduct Authority (“FCA”) to undertake investment management activities on behalf of its clients, which are a range of collective investment schemes classified as Alternative Investment Funds (AIFs) under the EU Alternative Investment Fund Managers Directive (“AIFMD”).
Our policy
Glenernie firmly believes in operating its business in an ethical manner and with high standards of integrity as expected of an FCA regulated entity. We are opposed to the use of any supply chains and services which may involve slavery, human trafficking or forced labour. To the best of our knowledge we believe this is not the case, but in the unlikely event that anything of this nature is identified then we reserve the right to take the necessary action, which includes a duty to notify the UK Home Office and termination of the relevant contract.
Supply Chain Review and Due diligence
Glenernie does not deal in manufactured items, hard goods, and it does not have offices in any developing countries, nor does it purchase any goods from developing countries.
Our review has concluded that the services we provide and the supply chains which are used by Glenernie are highly unlikely to involve any human trafficking or slavery.
As entities involved in investment management Glenernie only has a limited supply chain, and this involves the use of reputable service providers.
Risk Assessment
From Glenernie’s review of its existing supply chain and service providers we believe the perceived level of risk is low.
Controls and Review Process
Glenernie uses only reputable service providers and suppliers. As part of its on-boarding process we will review any supplier and request information on their hiring process and working practices. We will also confirm with the potential supplier our strict prohibition on the use of any supply chains and services which may involve slavery, human trafficking or forced labour. Glenernie will undertake periodic reviews of its suppliers where it appears there is a potential risk involving a service provider.
This statement will be reviewed annually and where necessary this will be updated to reflect any changes in our practices regarding the use of supply chains and services that could be impacted.
Staff Awareness and Training
All Glenernie staff are aware of our policy especially those who are specifically involved in the on-boarding of any suppliers. If there are any concerns, then these may be reported to senior management at Glenernie in accordance with our Whistleblowing Policy.
Approval
This statement has been approved by the Glenernie Governance & Risk Committee on 5 December 2023.
Signature:
Name: Andrew Nunneley
Title: Chief Executive Officer
Date: 5 December 2023
PRIVACY NOTICE
Introduction
Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Glenernie Capital Ltd (the “Investment Manager”) and Glenernie Capital Management Limited (the “Agent”, and collectively with the Investment Manager and their respective affiliates, the “Glenernie Group”), and Glenernie Long/Short Fund Ltd, Glenernie Long/Short Fund LP, and Glenernie Long/Short Master Fund Ltd (collectively, the “Funds” and each, a “Fund”, and together with the Investment Manager and Agent, “we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former investors in the Funds, as applicable. Capitalized terms used but not defined herein have the meanings assigned to them in the Offering Memorandum of the relevant Fund, as may be supplemented, updated or modified from time to time (the “Memorandum”).
References to “you” or an “investor” in this Privacy Notice mean any investor who is an individual, or any individual connected with an investor who is a legal person, as applicable.
Who to Contact About This Privacy Notice
This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). The Funds and the Glenernie Group are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that each Fund and the Glenernie Group (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal information.
Please contact our Compliance Officer on +44 (0) 207 747 0200 or by writing to the following address Glenernie Capital Ltd, Smithson Plaza, 13th Floor, 25 St James’s Street, London SW1A 1HA, United Kingdom, with any questions about this Privacy Notice or requests with regards to the personal data we hold.
Please note that the Administrator and the Prime Brokers and Custodians work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, they, from time to time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and therefore as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by the Administrator, the Prime Brokers and Custodians or any other service provider of the Funds, you may also contact the relevant service provider directly at the address specified in the Directory section of the Memorandum or by visiting their websites.
The Types of Personal Data We May Hold
The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.
How We Collect Personal Data
We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) recording and monitoring of telephone conversations with you.
We also may receive your personal information from third parties or other sources, such as our affiliates, the Administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.
How We May Use Personal Information
We may process your personal data for the purposes of administering the relationship between you and us (including subscription acceptance, communications and reporting), marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies).
We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:
- processing is necessary to perform our obligations under the Fund Documents;
- we are required to comply with a legal or regulatory obligation applicable to us; or
- we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.
What Are The Consequences Of Failing To Provide Personal Information
Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription in the applicable Fund being rejected or your Shares or Interests becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
How We May Share Personal Data
We may disclose information about you to our affiliates, service providers (including the Administrator), or other third parties to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.
It may also be necessary, under anti-money laundering and similar laws, to disclose information about you to facilitate the establishment of trading relationships for the Fund with the Prime Brokers and Custodians, executing brokers or other trading counterparties.
We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.
We may also disclose information you provide to us pursuant to a joint marketing arrangement (i.e., an arrangement between non-affiliated financial companies that together market financial products or services to you). Our joint marketing partners may include companies such as Pelham Capital Ltd, and Pelham Global Financials Ltd.
Retention Periods and Security Measures
We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of your investment in the applicable Fund and for a minimum of five years after a redemption or withdrawal, as applicable, of your investment, or liquidation of the applicable Fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.
We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.
Monitoring of Communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.
Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)
For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.
We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about the Fund’s investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at +44 (0) 207 747 0200. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes.
You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.
Additional Information under the EU General Data Protection Regulation
You may have certain rights under EU General Data Protection Regulation (“GDPR”) in relation to our processing of your personal data and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.
A complaint in respect of the Investment Manager may be made to the Information Commissioner’s Office in the United Kingdom.
Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the GDPR (“Third Countries”). In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. We may also be required to transfer your personal information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.
Rev. January 2024
UK STEWARDSHIP CODE STATEMENT
UK Stewardship Code Disclosure
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Glenernie Capital Ltd (“Glenernie”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.
The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. On 24 October the FRC published the revised 2020 Stewardship Code that became effective from 1 January 2020. The 2020 Code comprises a set of 12 “apply and explain” Principles.
The aim of the Code is to enhance the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.
The FRC defines ‘stewardship’ as ‘the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.’ Glenernie acknowledges the Law Commission’s finding that effective stewardship should take into account environmental, social and governance (ESG) factors in investment-decisions, where these are financially material. ESG factors that may not have a material financial impact in the next earnings quarter may still have a material financial impact over years. Asset owners and asset managers that invest in line with clients’ and beneficiaries’ interests and investment time horizon would be expected to take these long-term impacts into account. Market quality can be improved by greater transparency and by holding companies to account more effectively through active stewardship. In higher quality markets, companies will be less inclined to pursue strategies that produce immediate results, at the expense of delivering longer term value through investment in innovation. Note that Glenernie’s investment strategy has a long-term investment horizon of two to five years or more.
The 2020 Code Principles are:
1. Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
2. Signatories’ governance, resources and incentives support stewardship.
3. Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first
4. Signatories identify and respond to market-wide and systemic risks to promote a well-functioning financial system.
5. Signatories review their policies, assure their processes and assess the effectiveness of their activities.
6. Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.
7. Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.
8. Signatories monitor and hold to account managers and/or service providers.
9. Signatories engage with issuers to maintain or enhance the value of assets.
10. Signatories, where necessary, participate in collaborative engagement to influence issuers.
11. Signatories, where necessary, escalate stewardship activities to influence issuers.
12. Signatories actively exercise their rights and responsibilities.
Glenernie supports the objectives underlying the Code in the performance of its investment activities. Glenernie’s investment team carries out deep dive fundamental investment analysis of its investee companies, which may involve engaging with company management on specific issues. Glenernie’s investment strategy has an investment objective of delivering superior risk adjusted returns, primarily by taking long and short positions with an investment horizon of two to five years, investing in equities, derivatives and indices.
The extent to which Glenernie would expect to engage and influence change will depend on the specific situation, and in particular the amount its clients own of the investment relative to the investments overall share capital. Engagement may focus on matters such as: capital structure, strategy and operations, financial performance, risks and opportunities. Glenernie also retains the discretion to exit an investment if engagement has been or is likely to be unsuccessful.
Overall, while Glenernie supports the objectives of the Code and believes in adhering to the highest standards of corporate governance and due diligence when making investment decisions on behalf of its investors, Glenernie does not believe that it would be appropriate to formally commit itself to one set of principles at this time, given the number of international initiatives that are being developed or are in the process of being adopted, for example to cater for ESG.
Glenernie views transparency, integrity and accountability as a part of the infrastructure of a responsible business, and a necessary requirement for it to meet its regulatory obligations as an FCA regulated investment manager.
Glenernie will continue its observation of the Stewardship Code as well as other initiatives that have been proposed. Although Glenernie has not made an application to become a signatory of the Stewardship Code, Glenernie and its staff have a fiduciary duty to act in the best interests of its clients, by following the highest legal, ethical and professional standards in its business, and Glenernie is fully aware of the objectives of stewardship as set out in the Code. Glenernie will continue to monitor it status against these objectives, and it may decide to review its position and make an appropriate disclosure at that time.
This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time.
For any questions regarding this disclosure statement please email compliance@pelhamcapital.com.
REMUNERATION CODE DISCLOSURE
The Firm’s Governance & Risk Committee is responsible for setting and implementing the remuneration policy. There is no independent remuneration committee given the scope, nature, and the size of the business.
The Firm is required to disclose in its annual report, the total remuneration paid by Glenernie Capital Ltd to its employees that are deemed Remuneration Code Staff. The Firm defines Remuneration Code Staff as senior management and members of staff whose actions have a material impact on the risk profile of the Firm, or the Alternative Investment Funds (AIFs) managed by the Firm. Although the Firm is subject to the AIFMD Remuneration Code (“the Code”), it has applied proportionality and dis-applied various provisions of the Code where relevant.
Performance related remuneration is based on a range of factors. Generally, Fund Managers can expect to receive a proportion of any crystallised performance fees generated by the AIFs they manage. Performance fees have High Water Marks (HWM), so they are only generated once underlying Fund investors have achieved a positive absolute return. In addition, at the Firm level other factors including the overall profitability of the firm and various financial and non-financial performance factors, such as the development of the business and long-term sustainability may be considered. At an individual level, non-financial factors such as adherence to the Firm’s culture and risk management framework, and compliance with the compliance policies and procedures, staff handbook and code of ethics may also be considered.
The Firm has only one business area, investment management, so all remuneration disclosed in our audited financial statements is from this business area.
PILLAR 3 RISK DISCLOSURE
YEAR ENDED 31 December 2021
Introduction
Glenernie Capital Ltd (“Glenernie/the Firm”) is required by the FCA to disclose information relating to the capital it holds and each material category of risk it faces.
The FCA framework consists of three “Pillars”:
- Pillar 1 sets out the minimum capital requirements that companies need to retain to meet their credit, market and operational risk;
- Pillar 2 requires companies to assess whether their Pillar 1 capital is adequate to meet their risks and is subject to annual review by the FCA;
- Pillar 3 requires companies to develop a set of disclosures which will allow market participants to assess key information about its underlying risks, risk management controls and capital position. These disclosures are seen as complimentary to Pillar 1 and Pillar 2.
The disclosures below are the required Pillar 3 disclosures. The disclosures do not apply to the funds managed by Glenernie, which are exposed to different risks.
Glenernie Overview
Glenernie operates as a discretionary investment manager solely to professional clients. Glenernie is authorised and regulated by the Financial Conduct Authority (the “FCA”) and is classified as a Collective Portfolio Management Investment Firm. It is a Full Scope UK AIFM of non-EEA AIFs and undertakes activities which result in the Firm being categorised as a BIPRU limited licence firm by the FCA for capital purposes. This Pillar III disclosure fulfils the Firm’s obligation to disclose to market participants key pieces of information on Glenernie’s capital, risk exposures and risk assessment processes.
The Governing Body of Glenernie, the Governance & Risk Committee, has the daily management and oversight responsibility. It generally meets quarterly and is composed of the CEO/CIO, the Chief Operating Officer/Chief Financial Officer/Chief Risk Officer, and the Compliance Officer.
The Governance & Risk Committee (“GRC”) is responsible for the entire process of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the GRC decides Glenernie’s risk appetite or tolerance for risk and ensures that Glenernie has implemented an effective, ongoing process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed. Senior Management is accountable to the GRC for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of Glenernie. It is the responsibility of the Compliance Officer and Chief Risk Officer to report on the effectiveness of the mitigating controls to the GRC which retains ultimate responsibility for ensuring these are effective.
Capital Resources and Requirements
Capital Resources
Pillar 1
As of 31 December 2021, Glenernie on a solo basis held regulatory capital resources of £842,468, comprised solely of core Tier 1 capital.
Glenernie is not required to calculate an operational risk charge for its Pillar 1 requirement under applicable exemptions. As a Collective Portfolio Management Investment Firm, Glenernie’s capital requirements are the greater of:
- Its base capital requirement of €125,000;
- The sum of its market and credit risk requirements; and
- Its fixed overhead requirement.
As of 31 December 2021, Glenernie’s Pillar 1 capital requirement was £216,228. The Firm does not hold any equities, other than those considered immaterial, does not have a trading book, and does not undertake any form of securitisation.
The Firm’s capital resources requirement consists of its fixed overhead requirement and not the total of the credit risk and market risk requirements. Therefore, disclosures relating to credit and market risk are considered to be immaterial.
Satisfaction of Capital Requirements
Pillar 2
Glenernie has adopted the “Structured” approach to the calculation of its Pillar 2 Minimum Capital Requirement as outlined in the Committee of European Banking Supervisors Paper, 27 March 2006 which takes the higher of Pillar 1 and 2 as the ICAAP capital requirement. It has assessed Business Risks by modeling the effect on its capital planning forecasts and assessed Operational Risk by considering if Pillar 2 capital is required after considering the adequacy of its mitigation.
Since Glenernie’s Internal Capital Adequacy Assessment Process (ICAAP or Pillar 2) process has not identified capital to be held over and above the Pillar 1 requirement, the capital resources detailed above are considered adequate to continue to finance Glenernie over the next year. No additional capital injections are considered necessary and Glenernie expects to continue to be profitable.
Risk Management
Glenernie 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 of the Firm is overseen by the GRC.
As risks are identified within the business, appropriate controls are put in place to mitigate these and compliance with them is monitored on a regular basis. The frequency of monitoring in respect of each risk area is determined by the significance of the risk. Glenernie does not intend to take any risks with its own capital, and portfolio risk is closely monitored by the CIO and the COO/CRO. The results of the compliance monitoring performed is reported to the GRC by the Compliance Officer.
Operational Risk
Glenernie places strong reliance on the operational procedures and controls that it has in place to mitigate risk and seeks to ensure that all personnel are aware of their responsibilities in this respect.
Glenernie has identified a number of key operational risks. These relate to disruption of the office facilities, system failures, trade failures and failure of third-party service providers. Appropriate policies are in place to mitigate against these risks, including appropriate insurance policies and business continuity plans.
Credit Risk
The main credit risk to which the Glenernie is exposed is in respect to the failure of its debtors to meet their contractual obligations. The majority of Glenernie’s receivable is related to its investment management activities. Glenernie believes its credit risk exposure is limited, since Glenernie’s revenue is ultimately related to management fees received from the funds for which it performs discretionary investment management activities. These management fees are drawn throughout the year from the funds managed. Other credit exposures include bank deposits and office rental deposits.
Glenernie undertakes periodic impairment reviews of its receivables. All amounts due to Glenernie are current and none have been overdue during the year. As such, due to the low risk of non-payment from its counterparties, management is of the opinion that no provision is necessary. A financial asset is overdue when the counterparty has failed to make a payment when contractually due. Impairment is defined as a reduction in the recoverable amount of a fixed asset or goodwill below its carrying amount.
Glenernie has adopted the standardised approach to credit risk, and therefore follows the provision within BIPRU 3 standardised credit risk of the FCA handbook. Glenernie applies a credit risk capital component of 8% to its non-trading book risk weighted exposure. As Glenernie does not make use of an external credit rating agency, it is obligated to use a risk weight of 100% to all non-trading book credit exposures, except cash and cash equivalents which are held by investment grade entities and currently attract a risk weighting of 20%.
The table below sets forth the Glenernie’s credit exposures and corresponding capital resource requirements as of 31 December 2021:
| Solo Basis | Credit Exposure | Risk Weighted Exposure |
| National Governments | £ | £ |
| Tangible fixed assets | £5,671 | £5,671 |
| Due from affiliates – within 3 months | £ | £ |
| Due from affiliates – after 3 months | £ | £ |
| Cash at bank | £1,722,154 | £344,431 |
| Prepayments | £15,728 | £15,728 |
| Other | £175,948 | £175,948 |
| ————— | ———— | |
| Total | £1,919,501 | £541,778 |
| ========= | ======= | |
| Credit Risk Capital Component (8% of risk weighted exposure) | £43,342 |
Market Risk
Glenernie holds no trading book positions on its own account. All cash bank accounts are in GBP or USD and all advisory fee income is paid in GBP or USD, and Glenernie can convert USD into GBP at any point so the Firm’s exposure to foreign currency risk is not significant. Since the settlement of debtor balances take place without undue delay, the timing of the amount becoming payable and subsequently being paid is such that it is not considered to present a material risk to Glenernie. Glenernie has excluded Market risk on the basis that it is not considered a material risk.
Remuneration Code
Glenernie has adopted a remuneration policy and procedures that comply with the requirements of chapter C of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (SYSC), as interpreted in accordance with the FCA’s guidance publication entitled “General Guidance on Proportionality: The Remuneration Code (SYSC 19C) & Pillar 3 Disclosures on Remuneration (BIPRU 11)” and subsequent items of guidance issued by the FCA, including its document entitled “Frequently Asked Questions on the Remuneration Code”.
As a BIPRU limited license firm, Glenernie falls within proportionality level 3. Glenernie has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the GRC sets, and oversees compliance with Glenernie’s remuneration policy, including reviewing the terms of the policy at least annually.
As at 31 December 2021, Glenernie currently sets the variable remuneration of its staff in a manner which considers individual staff performance, and the financial performance of Glenernie. Individual staff performance includes a review of non-financial factors, which covers adherence to Glenernie’s Compliance Policies and Procedures, Code of Ethics, Staff Handbook and other applicable regulations such as the FCA Individual Conduct Rules. As permitted for Glenernie falling within proportionality level 3, Glenernie takes into account the specific nature of its own activities (including the fee-based nature of its revenues) in conducting any ex-ante risk adjustments to awards of variable remuneration, and given the nature of its business, it has disapplied the requirement under the Remuneration Code to make ex-post risk adjustments.
In conjunction with the GDPR, the small size and complexity of the business means that the Firm does not feel it appropriate to publish the aggregate remuneration data, as this is felt to be disproportionately invasive to the privacy of the small number of staff employed by the Firm.