Background to the Firm

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’.

Investment & Portfolio Consultants Limited is not a member of a UK Consolidation Group and does not have an Investment Firm Consolidation Waiver deducting Material Holdings under (GENPRU 2 Annex 4).

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 and Risk Assessment (ICARA) 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 ICARAP 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 non-collection

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.