Investment & Portfolio Consultants Limited Pillar 3 Disclosure and Policy for the period 1st July 2020 – 30th June 2021

Introduction

Regulatory Context

The Pillar 3 disclosure of Investment & Portfolio Consultants Limited (“the Firm”) is set out

below as required by the FCA’s “Prudential Sourcebook for Banks, Building Societies and

Investment Firms” (BIPRU) specifically BIPRU 11.3.3 R. This is a requirement which stems

from the UK’s CRDIII implementing Regulations which represented the European Union’s

application of the Basel Capital Accord. The Firm is no longer formally subject to CRD but

remain subject to the UK’s implementation Regulations of CRD prior to CRDIV. The

regulatory aim of the disclosures is to improve market discipline.

Frequency

The Firm will be making Pillar 3 disclosures at least annually. The disclosures will be as at

the Accounting Reference Date (“ARD”), 30th June.

Media and Location

A summary disclosure will be published on IPC’s website and the full disclosure will be

available on request from IPC’s Compliance Officer.

Verification

The information contained in this document has not been audited by the Firm’s external

auditors, as this is not a requirement, and does not constitute any form of financial

statement and must not be relied upon in making any judgement on the Firm.

Materiality

The Firm regards information as material in disclosures if its omission or misstatement

could change or influence the assessment or decision of a user relying on that information

for the purpose of making economic decisions. If the Firm deems a certain disclosure to

be immaterial, it may be omitted from this Statement.

Confidentiality

The Firm regards information as proprietary if sharing that information with the public

would undermine its competitive position. Proprietary information may include

information on products or systems which, if shared with competitors, would render the

Firm’s investments therein less valuable. Further, the Firm must regard information as

confidential if there are obligations to customers or other counterparty relationships

binding the Firm to confidentiality. In the event that any such information is omitted, we

shall disclose such and explain the grounds why it has not been disclosed.

Summary

The CRD, to which the Firm remains subject as a consequence of the UK CRDIII

implementing Regulations, have three pillars; Pillar 1 deals with minimum capital

requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process (“ICAAP”)

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undertaken by a firm and the Supervisory Review and Evaluation Process through which the

Firm and Regulator satisfy themselves on the adequacy of capital held by the Firm in relation

to the risks it faces and; Pillar 3 which deals with public disclosure of risk management

policies, capital resources and capital requirements.

The regulatory aim of the disclosure is to improve market discipline.

The Firm is a MiFID Investment Management Firm. It provides a number of investment

services including management, advice and brokerage. The Firm does not hold client money

or assets. The Firm’s greatest risks have been identified as business and operational risk.

The Firm is required to disclose its risk management objectives and policies for each

separate category of risk which include the strategies and processes to manage those risks;

the structure and organisation of the relevant risk management function or other

appropriate arrangement; the scope and nature of risk reporting and measurement systems;

and the policies for hedging and mitigating risk, and the strategies and processes for

monitoring the continuing effectiveness of hedges and mitigants.

The Firm has assessed business and operational risks in its ICAAP and set out appropriate

actions to manage them.

The Firm has an operational risk framework (described below) in place to mitigate

operational risk. The Firm’s main exposure to credit risk is the risk that fees cannot be

collected and as some fees are paid in advance or linked to transactions the risk of noncollection

is low. Therefore, the overall credit risk is considered low. The Firm holds all

cash and performance fee balances with banks assigned high credit ratings.

Market Risk exposure has been assessed by the Firm and is limited to the Firm’s exposure

to foreign currency exchange rate risk and hence to any assets held on the Firm’s Balance

Sheet denominated in a foreign currency. The Firms Reporting Currency is GBP and all

foreign currency assets are converted into GBP where possible on a regular basis.

Background to the Firm

Background

The Firm is incorporated in the UK and is authorised and regulated by the FCA as a MiFID

Investment Management Firm. The Firm’s activities give it the BIPRU categorisation of a

‘BIPRU Firm’.

Only Investment & Portfolio Consultants Limited is covered by the ICAAP as the Firm is

not a member of a UK Consolidation Group.

The Firm is a BIPRU Investment Firm without an Investment Firm Consolidation Waiver

deducting Material Holdings under (GENPRU 2 Annex 4).