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Turcan Connell is a Scottish Partnership regulated by The Law Society of Scotland. Registered office Princes Exchange, 1 Earl Grey Street, Edinburgh, EH3 9EE.
Turcan Connell Asset Management Limited is authorised and regulated by the Financial Conduct Authority, reference number 550227. Registered office Princes Exchange, 1 Earl Grey Street, Edinburgh, EH3 9EE.
Saltire Trustees International Trust Services is the trading name of Saltire Trustees (Overseas) Limited, which is regulated by the Guernsey Financial Services Commission and which holds a fiduciary license under The Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2000. Registered office Borough House, Rue Du Pré, St Peter Port, Guernsey, GY1 1EF.
Saltire Fiduciaire Sàrl is regulated by Association Romande des Intermédiaires Financiers (ARIF). Registered office; Rue de Villereuse 22, 1207 Genève, Switzerland.
VT Turcan Connell Balanced Fund, VT Turcan Connell Income Fund and VT Turcan Connell Absolute Return Fund are the available funds of V T Turcan Connell Investment Funds an Investment Company with Variable Capital (ICVC) authorised by the FSA, reference number 190667. Turcan Connell Asset Management Limited is the Investment Manager for the VT Turcan Connell Investment Funds. Valu-Trac Investment Management Limited is the Authorised Corporate Director for the funds.
Governance Structure of the Turcan Connell Group
The Partners of Turcan Connell are committed to high standards of governance in relation to our own business. We wish to ensure that we have in place structures and processes which are robust and effective. The Partnership meets on a monthly basis and the Partnership has overall responsibility for the strategic direction of the Turcan Connell Group. At these monthly meetings, the Partnership receives detailed reports on the financial and operational performance of all aspects of the Group's activities. Douglas Connell is Senior Partner and chairs the Partnership. He is also Chairman of Turcan Connell Asset Management (TCAM), the wholly owned subsidiary company of the Turcan Connell Partnership. Ian Clark is the Managing Partner of Turcan Connell and is responsible for the day to day operations of the Partnership. Alex Montgomery, as well as being a Partner of Turcan Connell, is Chief Executive Officer of Turcan Connell Asset Management and has executive responsibility for the overall management of TCAM. The Turcan Connell Group has the benefit of advice and support from two non-executives – Ed Murray and Lesley Knox.
Information provided on this site and any opinions expressed are for general use and not personal to your circumstances, nor are they intended to provide specific legal or financial advice. No information on this site should be viewed as an offer or recommendation to dispose of or acquire any investment or undertake any specific transaction. If you are unsure as to the suitability of any investment you should contact a financial planner who will provide tailored advice.
All information provided is based on our understanding of current legislation which is subject to change.
You should remember that the value of investments and the income derived from them may fall as well as rise and you may not get back the full amount you invest. Past performance is not a guide to future performance. Taxation is based on individual circumstances and is subject to change.
Conflicts of Interest Policy Summary
Turcan Connell Asset Management Limited's policy is to avoid any conflicts of interest between itself and its associates on one hand and its clients on the other. In the event of such a conflict arising, it will always put the interests of the client first.
If there is a conflict between two or more clients, the company will act in the most fair and equitable way it can. For example, client orders for the same security will be dealt with in the order they are received, except in exceptional circumstances, such as when an aggregated order may be in the best interest of clients.
If you would like to see a copy of the full Conflicts of Interest Policy please click here.
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Pillar 3 Disclosure
Turcan Connell Asset Management as at 31st March 2013
The Pillar 3 disclosure of Turcan Connell Asset Management Limited (“the Company”) 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 follows the introduction of the Capital Requirements Directive (“CRD”) which represents the European Union’s application of the Basel Capital Accord. The regulatory aim of the disclosures is to improve market discipline.
The Company will be making Pillar 3 disclosures annually.
Media and Location
The disclosure will be published on our website.
The information contained in this document has not been audited by the Company’s external auditors and does not constitute any form of financial statement and must not be relied upon in making any judgement on the Company.
The Company 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 Company deems a certain disclosure to be immaterial, it may be omitted from this Statement.
The Company 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 Company’s investments therein less valuable. Further, the Company must regard information as confidential if there are obligations to clients or other counterparty relationships binding the Company 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.
We have made no omissions on the grounds that it is proprietary or confidential.
The Company is incorporated in the UK and is authorised and regulated by the FCA as an Investment Management company. The Company’s activities give it the BIPRU categorisation of a “limited licence BIPRU investment firm” and a “BIPRU 125K” firm.
1. Risk management objectives and policies
Risk Management Objective
The Company’s general risk management objective is to develop governance structures and systems and controls to mitigate risk to a level that does not require the allocation of material Pillar 2 Capital.
The Board of Turcan Connell Asset Management Limited is the governing body ultimately responsible for the risk management regime. The Board has authorised the Risk and Compliance Committee (comprised of Non-Executive Directors and the Chief Executive Officer) to investigate any activity as to the risks which are deemed appropriate to accept and those which are unacceptable and should be eliminated or mitigated. The committee report to the Board on the quality of internal policies, disciplines, controls, processes and monitoring procedures in place to deal with risk, making recommendations for improvements where applicable significant internal control failures that have occurred.
Risk within the Company is managed by use of the following:
- regular reviews by the CEO, Compliance Director;
- taking a conservative approach to risk;
- identifying risks and recording them in the ICAAP;
- reviewing the ICAAP at least annually at meetings of the Board;
- The Company undertakes scenario Analysis and Stress Tests on the most significant risks. This informs the Company how risks are likely to behave and what, if any, impact there is likely to be to our balance sheet and
- an internal control framework with risk scoring to govern processes and procedures and to mitigate risks.
2. Capital Resources
The company is a BIPRU 125k Limited Licence Firm because it does not deal for its own account or underwrite issues on a firm commitment basis. It manages individual portfolios and it holds client money. A BIPRU firm must maintain at all times capital resources equal to or in excess of the base requirement (€125,000). The variable requirement for a BIPRU Limited Licence Firm is the higher of the credit risk capital requirement and the market risk capital requirement, or the fixed overheads requirement (i.e. one quarter of the firm’s relevant fixed expenditure). For the Company, the variable requirement is the fixed overheads requirement. A BIPRU firm must maintain at all times capital resources equal to or in excess of the variable requirement.
At the accounting reference date, the Company held the following capital position:
Tier 1 capital resources £2,005,802
Tier 2 capital resources £ -
Tier 3 capital resources £-
Total capital resources £2,005,802
Pillar 1 minimum £1,539,673
Combined Pillar 1 and Pillar 2 £1,539,673
Surplus Capital resources £466,129
Full detail of the Company’s capital resource is disclosed in the annual accounts.
3. Principal risks and scenarios
The principal risks to the financial position of the business and the severity and probability of impact are discussed below together with steps that could be taken to mitigate these issues. These risks are analyzed between the following categories:
- Credit Risk
- Market Risk
- Interest Rate Risk
- Securitisation Risk
- Operational Risk
For its Pillar 1 regulatory capital calculation of Credit Risk, under the credit risk capital component the Company has adopted the Standardised approach (BIPRU 3.4) and the Simplified method of calculating risk weights (BIPRU 3.5).
Non-payment of invoices
The Company issues invoices to Financial Planning clients and there is always the risk that they may not pay the fees charged. The incidence of unpaid fees within the Financial Planning area of the business is very low historically.
The investment management fees are payable in arrears and the risk of default is low as these are charged against the funds under management and on a basis agreed and documented in advance.
The Company does not itself take positions in shares or other instruments and therefore is not subject to Market Risk.
Interest Rate Risk
The only Interest Rate Risk is in relation to the Company’s funds on deposit. Any impact on the Company is limited and is regarded as negligible.
There is no Securitisation Risk in the business of the Company as none of its activities uses securitisation. There is no packaging of assets for on-sale or similar activities.
Operational risk is defined as the risk of loss arising from inadequate or failed internal processes, people and systems or from external events, including legal risk. The company is aware that operational risk can never be eliminated, but seeks to minimise the probability and impact of operational events.
The company’s business areas manage this risk through applicable controls and loss mitigation techniques, including use of insurance. These activities include a balance of policies, procedures and internal controls to ensure compliance with laws and regulations. Further assurance is provided by the company’s compliance department.
The operational risk policy incorporates a review of the company’s risk matrix by the Risk & Compliance Committee. The company has implemented a risk and control assessment by the Compliance department through discussion with Directors and relevant managers. This scores risk events as to probability and impact as well as evaluating the design and performance of controls that have been put in place to mitigate that risk. The results of the assessment are included within the risk matrix framework.
We have not identified credit risk exposure classes or the minimum capital requirements for market risk as we believe that they are immaterial.
The FCA's Remuneration Code ("the Code") applies to certain individuals' total remuneration, both fixed and variable.
The Company falls within the FCA's fourth proportionality tier and as such this disclosure is made in line with the requirements for a Proportionality Tier 4 firm.
The Company's policy is designed to ensure that it complies with the Code and therefore that its compensation arrangements:
- are consistent with and promote sound and effective risk management;
- do not encourage excessive risk taking;
- include measures to avoid conflicts of interest; and
- are in line with the Company's business strategy, objectives, values and long-term interests.
Application of the requirements
The Company is required to disclose certain information on at least an annual basis regarding its remuneration policy and practices for those staff whose professional activities have a material impact on the risk profile of the Company. This disclosure is made in accordance with the Company's size, internal organisation and the nature, scope and complexity of its activities.
Summary of information on the decision-making process:
- The Company's policy has been agreed by senior management in accordance with the Code's principles.
- The Company has in place an independent remuneration committee, the members are all Non-Executive Directors and considered independent.
- The Company's policy will be reviewed as part of an annual process or following a significant change to the business requiring an update to its internal capital adequacy assessment.
- The Company's ability to pay bonuses is based on the performance of the Company overall and is based on the Company's actual results for the year in question adjusted for any need to retain resources to meet regulatory capital requirements or for business development.
Summary of how the Company links between pay and performance
The Company's remuneration policy is linked to the performance of the Company as a whole, each department and of individual employees. Individuals are rewarded on an assessment based on their contribution to the overall strategy and achievement of the business taking into account factors including, where appropriate:
- Investment management.
- Client interaction including business development.
- Overall performance, reliability and effectiveness.
Aggregate remuneration of Code Staff
For the year ending 31st March 2013 there were 14 Code Staff (as defined below).
Aggregate remuneration expenditure in respect of Code Staff was £0.68m.
Remuneration expenditure was divided between fixed and variable remuneration as follows:
Fixed remuneration £0.66m
Variable remuneration £0.02m
(Fixed remuneration consists of base salaries only while variable remuneration consists of bonus payments)
Remuneration Code staff comprises categories of staff including senior management, risk takers, staff engaged in control functions excluding CF30’s (i.e. CF1 – 29) and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the company's risk profile.