Legal Documents

Privacy, Terms and Conditions

•   This website contains proprietary information. The contents, and any opinions on information, advisory and products it contains, may not be modified, sold, or otherwise provided, in whole or in part, to any other person or entity without JCI Capital Ltd written permission. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into, store, archive or in any other way use for any public or commercial purpose this site or any of the content without prior written permission of JCI Capital Ltd.

•   This website is intended for general information purposes. Any opinions on investment products contained herein are not intended to convey any guarantees as to the future investment performance of these products.

•   Under no circumstances should any material at this site be used or considered as an offer to sell or a solicitation of any offer to buy an interest in any security or investment managed by JCI Capital Ltd or its affiliates or any other product or service to any person in any jurisdiction, nor should it serve as the basis for any investment decision.

•   In addition to the information herein contained, one investor considering the products and services analysed should carry out his own due diligence, should carefully study the account forms, disclosure documents and/or risk disclosure statements which are provided directly by the asset management companies, banking or brokerage counterparties.

•   Past performance is no indication of future performance, and nothing on this Site should be interpreted to state or imply otherwise. The value of investments may fall as well as rise and investors may not get back the full amount invested.

•   This website may contain information that has been obtained from other sources. JCI Capital Ltd gives no representations or warranties as to the accuracy of such information, and accepts no responsibility or liability (including for indirect, consequential or incidental damages) for any error, omission or inaccuracy in such information.

•    In this website you may find addresses or hyperlinks leading out of this Website. The existence of any such links shall not constitute an endorsement, representation or warranty of such link. Users are advised that information on hyperlinked or referred-to websites is neither investigated nor analysed by JCI Capital Ltd. No warranty or representation, express or implied, is given as to the accuracy or completeness of such information.

•   JCI Capital Ltd reserves the right to change the terms, conditions, and notices under which this site is offered.

•   Opening this website shall not render the user a customer of JCI Capital Ltd nor shall JCI Capital Ltd owe such users any duties or responsibilities as a result thereof.

•   The Terms and Conditions of this website are without prejudice to any contractual terms you may enter into with us, which will take precedence over the Terms and Conditions of this website

•   Any use of this website shall be subject to UK law.

Web Disclaimer

The use of this website is subject to the following terms of use:

  • The material in the website is directed solely at Eligible Counterparties and Professional clients (as defined by the rules of the Financial Conduct Authority). The material is not directed at, may not be suitable for and should not be relied on by retail clients. By accessing the relevant pages you acknowledge that you are not a retail client.
  • Investments and foreign exchange can go up as well as down and involve the risk of loss. Past performance will not necessarily be repeated in the future.
  • The content of the pages of this website is for your general information and use only. It is subject to change without notice. The information contained in this website is believed to be reliable but no warranty or representation, expressed or implied, is given as to their accuracy or completeness
  • Your use of any information or materials on this website is entirely at your own risk, for which JCI Capital Limited shall not be liable. None of the services or investments referred to in this website is available to persons resident in any country where the provision of such services or investments would be contrary to local law or regulation. If you choose to use this website it is your sole responsibility to ensure you comply with any local laws and regulations and to seek legal advice if you are uncertain as to what these are.
  • Unless indicated otherwise, all information and images are the property of JCI Capital Limited.  By using the pages of this website, and/or by reading the material within it, you agree that you will use the information only for your internal business purposes and that you will not otherwise download copy, transmit or distribute in any way any of this material in whole or in part. All intellectual and other property information shall remain the property of JCI Capital Limited and no rights in it shall be transferred to you.
  • Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence. Any dispute arising from the use of this website is governed by English law.
  • From time to time this website may also include links to other websites, however these links are provided for your convenience to provide further information. JCI Capital Limited has no responsibility for the content of the linked website(s).
  • Trading futures, options or contracts for differences involves the risk of loss. You may lose more than the amount originally invested and, in respect of these products as well as other products traded on margin, you may have to pay more later. You should not invest in such products unless you are satisfied that they are suitable for you. It could be some time before you see a return on your investment. Changes in the rates of exchange between currencies may cause your investment/the income to go down or up. If you have any doubts as to the suitability of these investments you should seek financial advice.

JCI Capital Limited is authorised and regulated by the Financial Conduct Authority (FRN: 536817).

Registered Office: 44 Davies Street, 1st floor Brookfield House, London W1K 5JA. Registered in England & Wales (Company Number 7372983);     T: +44 (0)207 297 6700;   VAT No. GB 114182449

Extended Cookie Policy

Cookies consist of portions of code installed in the browser that assist the Owner in providing the service according to the purposes described. Some of the purposes for which the Cookies are installed may also require the User’s consent.

Activity strictly necessary for the functioning of the service

This Application uses Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of the same, for example in relation to the distribution of traffic.

Activity regarding the saving of preferences, optimization, and statistics

This Application uses Cookies to save browsing preferences and to optimize the User’s browsing experience. Among these Cookies are, for example, those to set the language and the currency or for the management of first party statistics employed directly by the Owner of the site.

Other types of Cookies or third-party tools that might use them

Some of the services listed below collect statistics in aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.

If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

he services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data collected: Cookies and Usage data.

Place of processing: US – – Privacy Policy – Opt Out

Displaying content from external platforms

This type of services allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Maps widget (Google Inc.)

Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Interaction with external social networks and platforms

This type of services allow interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

AddThis (Addthis Inc.)

AddThis is a service provided by Clearspring Technologies Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Twitter Tweet button and social widgets (Twitter, Inc.)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

Google+ +1 button and social widgets (Google Inc.)

The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy

How can I manage the installation of Cookies?

In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing them. Through the browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that might possibly have saved the consent for the installation of Cookies by this website. It is important to note that by disabling all Cookies, the functioning of this site may be compromised. Users can find information about how to manage Cookies in their browser at the following addresses: Google ChromeMozilla FirefoxApple Safari and Microsoft Windows Explorer.

In the case of services provided by third parties, Users can exercise their right to withdraw from the tracking activity by utilizing the information provided in the third party’s privacy policy, by clicking the opt-out link – if provided – or by contacting the third party.

Notwithstanding the above, the Owner informs that Users may take advantage of: Your Online Choices. This service allows Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of this resource in addition to the information provided in this document.

Data Controller and Owner

JCI Capital Limited 78 Brook Street W1K 5EF London – United Kingdom

Since the installation of third party Cookies and other tracking systems through the services used within this Application can not be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, consult the privacy policy for the respective third party services listed in this document.

Given the objective complexity linked to the identification of technologies based on Cookies and their very close integration with the operation of the web, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies themselves and any possible use of them – for example, by a third party – carried out through this site.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.


The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.


Small piece of data stored in the User’s device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies. This privacy policy relates solely to this Application.

Scope of the Best Execution Obligation

JCI Capital Limited (the Firm) must take all sufficient steps to obtain the best possible result when executing, placing or transmitting client orders on behalf of a client [or when dealing on a request for quote basis (“RFQ”)], taking into account the execution factors (as defined below) (“best execution”).

The regulatory duty to provide best execution extends to Professional Clients only when their order or RFQ relates to a MiFID II financial instrument and the Firm is executing on behalf of such clients.

The Firm will not owe best execution where it has correctly categorised a client as an Eligible Counterparty (generally or for a particular type of product or transaction). The Firm is not permitted to deal with Retail Clients and therefore its best execution arrangements are not applicable to such persons.

The Firm will apply best execution in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of MiFID II financial instruments.

The Firm will provide best execution where it determines that the client is relying on the Firm to protect its best interests in relation to the pricing or other aspects of an order placed with the Firm (“legitimate reliance”). The Firm will assess legitimate reliance having regard to factors such as which party initiates the transaction, questions of market practice and the existence of a convention to “shop around”, the relative levels of price transparency within a market and the information provided by the Firm and any agreement reached. If the Firm determines that the client is not legitimately relying on the Firm then best execution will not apply.

In so far as the Firm receives specific instructions from a client as to how to execute a transaction, best execution will not apply as the Firm will instead follow those instructions to the extent possible. In such circumstances, the Firm will be deemed to have satisfied its best execution obligation, but only in respect of that part or aspect of the order to which the client instructions relate. To the extent that there are other parts or aspects of the order for which the Firm has not received specific instructions from the client, the Firm will apply its best execution arrangements as detailed in this Summary.

The Firm’s commitment to obtain the best possible result for its clients does not mean that it owes any fiduciary or other responsibilities over and above the specific regulatory obligations placed upon the Firm or as may be otherwise contracted between the Firm and its clients through terms of business or otherwise.

Execution Factors

In complying with its regulatory obligation to obtain the best possible result when executing, placing or transmitting client orders on behalf of a client, the Firm will take into account the following factors when determining its execution arrangements (the “execution factors”):

  • Price (price at which the financial instrument is executed);
  • Speed (time it takes to execute a client order);
  • Likelihood of execution and settlement;
  • Size of the Order (in particular, how the size of the order affects the price of execution);
  • Costs (for example, execution and settlement fees);
  • Nature of the transaction (how the particular characteristics of the order may affect how best execution is achieved); and
  • Any other consideration relevant to the efficient execution of the order, including whether it is executed on a regulated market, multilateral trading facility or organised trading facility (each a “trading venue”) or over-the-counter (“OTC”).

The variety of execution factors that are taken into account and their order of relative priority will be determined by the Firm on a transaction by transaction basis.

It is the general policy of the Firm that the most important execution factor for its Professional Clients is the price at which the relevant financial instrument is executed. However, there may be circumstances where the primary execution factors vary and another factor, such as the likelihood of execution and settlement or the time it takes to execute a client order, becomes the most important execution factor and is given precedence over price.

Execution Criteria

When executing a client order, the Firm will take into account the following criteria for determining the relative importance of the execution factors (the “execution criteria”):

  • The characteristics of the client, including the categorisation of the client which will always be professional;
  • The characteristics of the client order;
  • The characteristics of the financial instruments that are the subject of that order; and
  • The characteristics of the execution venues to which that order can be directed.

The Firm will apply the execution factors and criteria in a number of different ways, depending on the type of instrument involved, its liquidity and the role played by the Firm.

For fixed income instruments that are considered liquid, the Firm will seek best price on the market and will execute the trade with the client at the best price. In relation to fixed income instruments that are considered to be less liquid the firm may consider an OTC transaction to be the most appropriate form of execution or may also look to source niche counterparties. [In all cases, if the firm considers that after due enquiry it is able to offer a better price than is available at the relevant time on the market, it may execute the trade with the client.]

Execution Venues

Having regard to the execution factors and criteria, the Firm may use one or more of the following venue types when executing client orders:

  • regulated markets
  • organised trading facilities or multilateral trading facilities
  • other exchanges that are not regulated markets
  • systematic internalisers
  • the Firm’s trading desks’ principal positions

The Firm will not discriminate between execution venues when choosing an execution venue on behalf of a client. However, it is the general policy of the Firm that it will seek to execute orders directly with regulated markets through direct market arrangements. A list of Direct Market Access providers that may be used by the Firm is set out towards the end of this Summary.

Notwithstanding the above, and taking into account the execution factors and criteria, the Firm may use other execution venues when executing client orders.

Execution outside of a trading venue

The Firm may execute all or part of a client order outside of a trading venue. The Firm is required to obtain its clients’ consent in order to do so, which consent has been outlined in the terms of business.

Limit Orders

The FCA’s rules require that where you have given the Firm a limit order for shares admitted to trading on a regulated market or MTF that is not immediately executed under prevailing market conditions, the Firm must make that unfulfilled limit order public immediately unless you expressly instruct us otherwise. We have framed our terms of business such that our clients are presumed to have instructed us not to make their unfulfilled limit orders public unless they tell us otherwise, as we believe the Firm’s ability to exercise discretion as to when and how unfulfilled limit orders are made public helps it to achieve the best possible result for its clients.

Order Handling and Aggregation

Order handling

When carrying out client orders, the Firm is required to:

  • ensure that orders executed on behalf of clients are promptly and accurately recorded and allocated; and
  • carry out otherwise comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise (COBS 11.3.2AEU).

Aggregation and allocation of client orders

The Firm may carry out a client order (i.e. execute an order on behalf of a client or transmit client orders to other entities for execution) or a transaction for own account in aggregation with another client order (i.e. combine a client order or transaction for own account with another client order) provided it is satisfied that:

  • it is unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any client whose order is to be aggregated;
  • it is disclosed to each client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order; and

Where the Firm aggregates a client order with a transaction for own account and the aggregated order is partially executed, it will allocate the related trades to the client in priority to the firm, (COBS 11.3.10AEU).

Corporate Finance

Most corporate finance activity, such as underwriting and advisory services, does not involve the Firm executing, placing or transmitting client orders on behalf of a client, in which best execution does not apply.

However, depending upon the nature of the engagement, the Firm may execute, place or transmit client orders on behalf of a client in a corporate finance context, for example where the Firm is engaged to:

  • build a strategic stake or acquire a target company;
  • facilitate a share buy-back; or
  • sell a significant shareholding.

in which case best execution will apply.

Execution factors in a corporate finance context

Most corporate finance transactions are unique. The means that the Firm’s general policy of identifying price as the most important execution factor is less likely to apply and other execution factors, such as likelihood of execution and settlement and speed of execution are likely to be the most important execution factors, depending on the particular characteristics and context of each transaction.

Execution venues in a corporate finance context

Corporate finance transactions tend to involve the acquisition or sale of larger blocks of shares and often involve additional complexities which limit the choice of execution venues available to the Firm, such as the need for secrecy, the requirements of the market abuse regime (or other appropriate standards of market conduct) in the particular circumstances and, where/if relevant, compliance with the Takeover Code or similar rules. Moreover, there is no formalised market or settlement infrastructure for OTC transactions. The Firm’s choice of execution venue may therefore be further limited where there is only one venue where it can execute a transaction.

When selling shares or debt, the general policy of the Firm is to choose to build a book or negotiate a private placement with identified investors (or the client may expressly instruct the Firm to do so). In these circumstances, the third party investment firms involved (trading proprietary or agency positions) will constitute the execution venue. Alternatively, the Firm may choose to use the block trade facility of an investment exchange.

Client Consent

The Firm’s clients will be deemed to have provided implied consent to the content outlined in this Summary when they instruct the Firm to act on their behalf in relation to an order.

Monitoring and Review

At least annually, the Firm will review its best execution arrangements and policy to ensure their ongoing effectiveness. The review will include consideration of whether the Firm could obtain better results for its clients if it was to:


  • include additional or different execution venues or brokers;
  • assign a different relative importance to the execution factors;
  • modify the process by which execution venues or brokers are selected;
  • modify any other aspects of its best execution arrangements and policy.


The Firm will also review its execution arrangements and policy whenever a material change occurs that could affect its ability to obtain the best possible result, on a consistent basis, for its clients (for example, a significant market event or material change to the Firm’s business model that could impact the parameters of the Firm’s best execution arrangements such as the execution factors specified above). Clients will be notified of any material changes to the Firm’s order execution arrangements or policy through publication of an updated version of this Summary [on the Firm’s website].


Annual Publication of Top 5 Execution Venues and Brokers

Each year the Firm will publish [on its website] data on its top execution venues and brokers used to obtain the best result for its clients, in respect of each class of financial instruments. Such data will include:

the top five execution venues in terms of trading volumes (the number of financial instruments traded times price for each transaction, cumulated for the year), where the Firm executed client orders in the preceding year, together with information on the quality of execution obtained; and

the top five brokers in terms of trading volumes to which the Firm transmitted or placed client orders for execution in the preceding year, and information on the quality of execution obtained.



List of DMA providers

Market Hub (Banca IMI SpA)
Trade Web
Market Access


Regulatory Context

The Pillar 3 disclosure of JCI Capital Limited (“the Firm”) is set out below as required by the Capital Requirement Regulation Art. 431et seq. This is a requirement, which stems from Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on Prudential requirements for Credit Institutions and Investment Firms and amending Regulation (EU) No 648/2012 (“Capital Requirement Regulation”, “CRR”) which represented the European Union’s application of the Basel Capital Accord. The regulatory aim of the disclosures is to improve market discipline.

The Firm is a €730k full scope IFPRU investment firm and it is authorised and regulated by the FCA (registration number 536817 and registered since 19 April 2011.



The Firm will be making Pillar 3 disclosures at least annually. The disclosures will be as at the Accounting Reference Date (“ARD”).


Media and Location

The document will be uploaded on the Firm website.



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.



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.



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.


The CRR, to which the Firm is subject to, has three pillars; Pillar 1 deals with minimum capital requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process (“ICAAP”) 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 an IFPRU broker, investment management firm and principal trader. It acts as agent and principal. 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 Company does not extend credit to third parties. The market risk system monitors suitability risk in relation to advisory and managed client mandates. All managed customers have their own settlement and custody arrangements and he Company only executes transactions on their behalf.

The Firm has assessed business and operational risks in its ICAAP and set out appropriate actions to manage them.

The Firm does not outsource any major business related operational function. Its IT infrastructure and IT support services are outsourced. In addition, the Firm relies on specialist external advisers for a number of matters, with a view to minimising operational risk. The Firm has an operational risk framework (described below) in place to mitigate operational risk.

Market Risk exposure has been assessed by the Firm Market risk arises principally through proprietary trading activity. The Firm has in place risk management procedures including a designated limit per trader which, when amalgamated, equals the total Firm limit. The Firm’s risk allocation and appetite is discussed at board meetings (or earlier as required). Periodic/daily reporting of all positions against the trading limits are communicated to the Chief Financial Officer.

The Firm’s Reporting Currency is GBP and all foreign currency assets are regularly converted into GBP on the basis of its needs.

Background to the Firm


The Firm is incorporated in the UK and is authorised and regulated by the FCA as an IFPRU Firm. This is due to the firm being authorised to deal as principal, and place instruments on a non-firm commitment basis and on a commitment basis and gives the Firm the category of an IFPRU 730K firm.

The ICAAP covers the Firm only. The Firm is a Solo regulated entity.

Article 435

Disclosure: Risk Management Objectives and Policies

Risk Management Objective

The Firm has a risk management objective to develop systems and controls to mitigate risk to within its risk appetite.

Governance Framework

The Board of Directors is the Governing Body of the Firm and has the oversight responsibility. It meets monthly and as at 31 December 2017 it was composed of:

  • Roberto Colapinto
  • Flavio De Paulis
  • Daniele Pinci

The Board of Directors has oversight of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Governing Body decides the Firm’s risk appetite or tolerance for risk and ensures that the Firm 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 Board of Directors for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of the Firm. 

Risk Framework

Risks are managed as set out below.

Operational Risk

The Firm undertakes robust risk identification and scoring exercises across the Firm, this Risk Appetite Statement translates into the acceptance of risks rated L or below. Any risk rated M or H is deemed to be unacceptable to the Company, deemed to be outside of the Firm’s Risk Appetite and must be addressed as a priority to ensure that it is able to receive a L rating. Any risk rated M must be addressed as a priority to ensure that it is able to receive an L rating or have Pillar 2 capital allocated.

Market Risk

As a €730k full scope IFPRU investment firm, the Firm has a Trading Book in respect of its intra-day bond positions. In addition there are Non-Trading Book Exposures, i.e. to Foreign Currency held on deposit and assets or liabilities held in Foreign Currency, such as Debtors, on the Firm’s Balance Sheet.   The Firm’s appetite for Market Risk is low (no overnight positions are held) and, for the purposes of Pillar 2, is assumed to be that calculated at Pillar 1.

Credit Risk

As a €730k full scope IFPRU investment firm, the Firm acts as principal, manages investments and neither holds client money nor assets nor lends money, and is, therefore, not exposed to Credit Risk in its traditional sense. The Firm’s exposure to Credit Risk is the risk of failed trades, that commissions cannot be collected and the exposure to banks where revenue is deposited. The Firm’s Credit Risk Appetite is low so the Firm only deals with regulated market makers and holds all cash with banks assigned high credit ratings. Credit Risk, for the purpose of Pillar 2, is assumed to be that calculated at Pillar 1.

Disclosures concerning Board of Directors

  • Number of directorships (excluding those held in respect of FIRM) held by members of Board of Directors as at 31 December 2017

The number of outside directorships held by members of the Board of Directors is as follows:

  • Roberto Colapinto – three
  • Responsibility and Information Flow on risk to Board of Directors

As at 31 December 2017, The Board of Directors has oversight of the Firm’s risk management, with monthly reporting to the Board of Directors.

Article 437

Disclosure: Own Funds

The Firm is an IFRU Full Scope Firm. Tier 1 Capital comprises of share capital and audited reserves.



Tier 1 Capital and Total Capital  



Article 438

Disclosure: Capital Requirements

The Firm 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.


The ICAAP assessment is reviewed by the Board of Directors and amended where necessary, on a yearly basis or when a material change to the business occurs. The Credit and Risk Committee reviews the ICAAP document to the Governing Body of the Firm which reviews and endorses the risk management objective each quarter or when a material change to the business occurs at the same time as reviewing and signing off the ICAAP document.

Internal Ratings Based Approach

The Firm does not adopt the Internal Ratings Based Approach.

Article 439

Disclosure: Exposure to Counterparty Credit Risk

Counterparty credit risk is the risk that the counterparty to a transaction could default before the final settlement of the transaction’s cash flows.

For derivatives, counterparty credit risk arises primarily from unsettled security, commodity and foreign exchange transactions with a contractual settlement or delivery lag that is longer than the lesser of the market standard for the particular instrument or five business days (long settlement transactions).

The process for approving a counterparty’s risk exposure limit is guided by core credit policies, procedure and standards; experience and judgement of credit risk professional and the amount of credit risk. Credit risk is monitored on a daily basis versus limits and any issues are escalated to risk and business management as appropriate.

The firms does not engage in any credit derivative trading, hence no collateral or credit reserve are required. Furthermore, as the firm trades only intraday with no overnight exposures there is no wrong-way risk exposures.


All credit exposures are measured the mark-to-market method.

The firm does not have any credit derivative hedge.

Article 440

Disclosure: Capital buffers

This disclosure is not in force as at 31 December 2017.

Article 441

Disclosure: Indicators of Global Systemic Importance

This disclosure is not applicable as we are not a Global Systemic Important Institution

Article 442

Disclosure: Credit Risk Adjustments

Credit risk adjustments to exposure to trading counterparties are reviewed on a monthly basis by reference to the age of the exposure and the rating of the counterparty together with the company’s internal assessment of the counterparty (which is calculated by public domain information).

Any asset which is over 6 months past due is considered fully impaired unless there are mitigating circumstances. However, no such balances existed at the balance sheet dated and the company considers that there is no assets where such a provision is needed for amounts past due for a shorter period or for any other probable loss except for small non-trading balances.

Counterparties are generally the within the EU and US and large established institutions with significant market presence.

Article 443

Disclosure: Unencumbered Assets

All assets are unencumbered

Article 444

Disclosure: Use of ECAIs

Article 445

Disclosure: Exposure to Market Risk

The Firm has adopted the Trading Book and Non Trading Book (Articles 325-377) approach to its Pillar 1 capital calculation. Market risk exposure is calculated as follows.


Article 92(3) b requirements for trading book business

Item Own fund Requirement
Position risk nil
Large exposures which exceed limits in Arts 395-401 nil
Total nil


Article 92(3) c requirements

Item Own fund Requirement
Foreign Exchange Risk 20,00
Settlement Risk 10,00
Commodities Risk Nil
Total 30,00


The Firm does not hold securitisation positions and therefore there is no Specific Interest Rate Risk to disclose,

Article 446

Disclosure: Operational Risk

The Firm uses the Basic Indicator Approach as set out in Articles 315-316 to calculate its Operational Risk Own Funds Requirement.

Item Own fund Requirement
Operational Risk £408,000


Article 447

Disclosure: Exposures in Equities not Included in the Trading Book

This disclosure is not required as the Firm does not have a Non-Trading Book Exposure to Equities.

Article 448

Disclosure: Exposure to Interest Rate Risk on Positions not Included in the Trading Book

Although the Firm has substantial cash balances on its Balance Sheet, there is currently no significant exposure to Interest Rate fluctuations.

Article 449

Disclosure: Exposure to Securitization Positions

This disclosure is not required as the Firm does not Securitise its assets.

Article 450

Disclosure: Remuneration Policy

The Firm is a Remuneration Code Proportionality Level 3 Firm and has applied the rules appropriate to its Proportionality Level. The Governing Body is responsible for the Firm’s remuneration policy and generally meets on monthly basis. All variable remuneration is adjusted in line with capital and liquidity requirements.

The Firms classifies senior managers and those staff whose professional activities have a material impact on the Firm’s activities as Remuneration Code Staff. The Firm has not paid a severance payment to a Remuneration Code Staff. The total number of Remuneration Code Staff is 16. The aggregate remuneration paid the Remuneration Code Staff during the previous 12 months was £1,5k. No remuneration was awarded in the form of shares or share linked instruments or similar type of instruments to Remuneration Code Staff.

Total remuneration during the financial year to 31 December 2017 was £1,5K. No member of staff has been awarded a total remuneration of €1m or more.

   Aggregate Quantitative Remuneration by Senior Management and other Remuneration Code Staff




Senior Management (SIF) [xxx}
Other Remuneration Code Staff nil


Total 715