Please carefully read this important information before entering this website. It contains legal and regulatory notices relevant to the information contained on this website. Please ensure that you select the correct jurisdiction and investor type classifications, as this will appropriately tailor the website content for you.
You should not rely on the views and information on the site when making investment decisions. The information contained in this website is not intended as an offer or solicitation for the purchase or sale of any financial instrument.
The content of this website has been prepared by Algebris (UK) Limited (“Algebris”) on the basis of information sources and analysis believed to be reliable as at either the time such content was posted in the website or otherwise at the date disclosed. Views and Opinions are Algebris’ only and may change. Algebris is under no obligation to update such information, and Algebris’ views and opinions may change. Algebris uses all reasonable skill and care to ensure information is accurate. However, errors or omissions may occur that are outside of our control, such as unauthorised access to this internet service, or the effects of machine, software or operator error or malfunction in connection with data transmission.
Under no circumstances should any part of this website be construed as an offering or solicitation of any offer, and any investment in the products referred to on this website should only be made on the basis of the relevant prospectus. Any reference to individual investments should not be taken as a recommendation to buy or sell. Any performance reports should be read in conjunction with the full text and definitions of the relevant fund prospectus. To the fullest extent permitted by law, Algebris accepts no liability for any loss or damage which may arise from the access to, use of, or reliance on the content of or information contained on, this website.
Otherwise than as specifically set out, the information on this website must in no circumstances be copied, reproduced or redistributed in whole or in part. You may download or print copies of some of the documentation contained on this website for your own private use only, provided that you do not change any copyright, trademark or other proprietary notices. All intellectual and other property information contained in this website shall continue to be held by us and no rights of any kind in it shall pass to you. This website is reserved exclusively for non-US persons and should not be accessed by any person in the United States.
Nothing in this site should be construed as being personal financial advice. Algebris does not offer investment advice.
Past performance is not a guide to future performance and may not be repeated. The value of shares can go down as well as up and is not guaranteed. Changes in rates of exchange may also cause the value of shares to fluctuate. Because of this, an investor is not certain to make a profit on an investment and may lose money.
The information contained herein is not intended to provide, and should not be relied upon for accounting, legal or tax advice or investment recommendations. You should consult your tax, legal, accounting or other advisors about the issues discussed herein. A potential investor expressing an interest to invest in the transaction will be provided with a prospectus and subscription agreement (together, the “Fund Documents”) for the investment and an opportunity to review the documentation relating to the investment. Prospective investors must review the Fund Documents, including the risk factors, before making a decision to invest and should rely only on the information contained in the Fund Documents in making their investment decision.
Links to other Web Sites:
On this web site you may be offered automatic links to other non-Algebris web sites which we hope you will be interested in. These links are provided only as convenience. Algebris does not accept any responsibility for the content of those web sites or your use or inability to use such web sites, the owners of which do not necessarily have any link, commercial or otherwise, with Algebris. The inclusion of any link does not imply affiliation, sponsorship, endorsement, verification or monitoring or approval by Algebris of any information contained in any non-Algebris web site. You should also be aware that the terms and conditions of such web site and the web site’s statement relating to the collection and use of your personal information may be different from those applicable to your use of this web site.
Company and regulatory details:
Algebris (UK) Limited
1 St. James’s Market
London SW1Y 4AH
T +44 (0)203 196 2450
Registered in England and Wales No. 10308570
Algebris (UK) Limited is Authorised and Regulated by the Financial Conduct Authority
Recording of calls:
Telephone calls to Algebris or any Algebris group entities may be recorded or monitored.
Terms & Conditions
3. Algebris grants to you a limited, personal license to access the Site and to access and download the Contents, but only for your own use. You may not use, reproduce, distribute or display any portion of the Site for any other purpose, including, without limitation, any commercial purpose.
4. Except for a single temporary copy in a single computer’s memory or another fair use under applicable copyright laws, the information contained herein may not otherwise be used (not copied, performed, distributed, rented, sublicensed, altered, stored for subsequent use, etc., in whole or in part, in any manner) without Algebris’ express prior written consent. You may use the Site and the Contents for lawful purposes only. Algebris reserves all rights not expressly granted herein, including the right to terminate your use of the Site without notice.
5. Investing in securities carries certain risks, and Algebris shall not be responsible for any investment losses incurred in reliance on information provided on the Site. Advice from your own financial advisor is strongly recommended. The information and design of the Site are owned by Algebris and/or its service providers.
6. The Site contains copyrighted material, trademarks and service marks, and other proprietary information, including, but not limited to, text, software and graphics, that are owned by Algebris, which reserves all rights in the Contents, and/or by third parties. You agree not to reproduce, distribute, sell, broadcast, publish, publicly display, retransmit, disseminate, circulate, create derivative works from, or commercially exploit the Site or the Contents without the express written consent of Algebris. In addition, you are not permitted to alter, obscure, or remove any copyright, trademark, or other notices that are included in connection with the Site.
7. You agree to access the Contents and the Site manually, by request, and not automatically, through the use of a program, or by other means. You agree not to take any action, alone or with others, that would interfere with the operation or security of the Site, to alter the Site in any way, or to impede others’ access to and freedom to enjoy and use the Site as made available by Algebris.
8. The Site and the Contents are provided on an “as is” basis. Algebris and any other providers of the information expressly disclaim all warranties of any kind, express or implied, including, without limitation, any warranty of accuracy, merchantability, fitness for a particular purpose, or non-infringement. Although the information provided to you on the Site is obtained or compiled from sources we believe to be reliable, Algebris cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you or otherwise used on the Site for any particular purpose.
9. Algebris is not responsible for information on any third-party web site that is referred in, or accessible or connected by hyperlink to, the Site. If you access any third-party web site through the Site, or otherwise, you do so at your own risk. Hyperlinks to or from the Site do not constitute third-party endorsement of, sponsorship by or affiliation with us.
10. Neither Algebris, nor any of its members’ respective affiliates, directors, officers or employees, nor any third party vendor will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure, malfunction or interruption of the Site or any portion of it, or resulting from the act or omission of any other party involved in making the Site or the data contained therein available to you, or from any other cause relating to your access to, inability to access, or use of the Site or the Contents, whether or not the circumstances giving rise to such cause may have been within the control of Algebris or of any vendor providing software or services support. Neither Algebris nor any of its members’ respective affiliates, shareholders, officers, employees, agents or representatives shall be liable for any indirect, incidental, exemplary, punitive, special or consequential damages arising out of or relating to the Site, the use of or inability to use the Site, or the Contents, even if such party has been advised of the possibility of such damages. In particular, Algebris will not be liable for any loss or damage caused by your reliance on information obtained through the Site.
11. Use of the Site shall be governed by and construed in accordance with the laws of the England and Wales.
Cookies used by our websites
• Do not store any personally identifiable information about you or information such as passwords.
• Do not (and cannot) allow us to access other information stored on your computer.
• Do not store any information about you that others could understand, or in any way compromise your security.
• Do allow us to monitor the number of people using our websites and monitor their activities.
• Do allow us to see how people arrive at our site (e.g. search for ‘Algebris Investments’ on a search engine, or click on an email we have sent).
• Do allow us to gather technical information about people using our websites, such as their geographic location and the type of web browsers they are using.
• Do allow us to display adverts on other websites, to people who have previously accessed our websites. We cannot identify individuals to whom adverts may be displayed.
• Do allow us to display content on our websites more relevant to you and your preferences based on the information we hold and your behaviour on our websites.
• Do allow our websites to recall certain settings and preferences to make using our website easier. We cannot identify what your individual preferences or settings are.
Types of cookie used on our websites
Session cookies are temporarily stored on the user device and are deleted when the browser is closed. On Algebris’ website they are used to remember data that is useful for the browsing session, such as language settings.
Persistent cookies unlike session cookies, they don’t disappear at browser closure, but are stored until they expire on a specific date or after a set period of time. On Algebris website they are used to remember the jurisdiction selection and they are set to expire after 24 hours.
Third party cookies are released and installed on the user device by third party services used. Third party services include, but are not limited to Google Analytics, Google Maps, YouTube, and a number of news providers such as The Financial Times and Bloomberg.
How we classify the cookies we use
We use a system of classification developed by the International Chamber of Commerce. This allows us to classify the different types of cookies which we use on our websites and provide you with more information about why we use them.
Strictly necessary cookies are cookies that are essential in providing specific services you have requested from us. For example remembering information you have entered such as your jurisdiction and language settings when you navigate to different pages in a single web browsing session.
Performance cookies aim to improve our websites by collecting information about how you use our website. For example:
• Counting the number of visitors and how they move around our websites.
• Understanding what interests our users so that we can deliver the content and level of service you expect from us.
• Helping us to improve our websites by measuring errors experienced by users of our websites.
• Testing different designs or content on our websites.
Functionality cookies will typically be set because of an action you have taken on our websites but may also be set in the delivery of other services. For example saving preferences when using interactive share charts.
Promotional cookies collect information about your browsing in order to deliver promotions relevant to you and your interests as well as your IP address in order to determine your geographic location and for fraud filtering. They are usually placed by third party advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers.
These organisations do this in order to provide you with targeted adverts more relevant to you and your interests. This type of advertising can include targeting you based on what pages of our site you have visited and online behavioural advertising based on your browsing history.
We may from time to time use this type of cookie on our websites to deliver promotions relevant to you. Promotional cookies may also be used to limit the number of times you see a promotion as well as help measure the effectiveness of the promotion.
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). The cookies used by Google Analytics are third party cookies referred to above, and help our websites analyse how you use the site. The information generated by the cookie about your use of our websites (including your IP address) will be transmitted to and stored by Google. Google will use this information to provide us with reports on website activity and other services relating to website activity. For more information about how Google uses your data please see Google’s Privacy & Terms.
Managing your cookies
Most web browsers allow you to manage cookies via the browser settings. For example you may choose to delete existing cookies, prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie or disable cookies altogether.
You can use the following links to find out more about managing these settings in your browser. If your browser is not listed below you can normally use the ‘Help’ functionality on your browser to find out about how it handles cookies.
• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web
• Cookie settings in iOS
You can also opt out of receiving targeted advertisements by visiting the NAI website opt-out page here: http://www.networkadvertising.org/choices/ or the DAA opt-out page here: http://www.aboutads.info/ or, for EU users, the EDAA opt-out page here: http://youronlinechoices.eu/.
By using our websites you are agreeing to the placement of cookies on your computer.
Date of last update: 8 May 2017
Pursuant to the General Data Protection Regulation (“GDPR”) that comes into effect on 25th May 2018 please find below a copy of Algebris (UK) Limited’s (“Algebris” or “we” or “us” or “our”) Privacy Notice (the “Notice”) to inform you how we hold your data and what we use it for in connection with the provision of discretionary investment management services.
Algebris is committed to protecting and respecting your private data.
“Our Group” means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies.).
This Notice sets out the basis upon which any personal data that Algebris collects from you, or that you provide to Algebris, will be processed by us.
Who we are and what we do
We are an investment management firm authorised and regulated by the Financial Conduct Authority. We act as the discretionary investment manager to a number of collective investment schemes and a number of managed accounts.We collect personal data of the following types of people to enable us to undertake our discretionary investment management activities:
- Investors and potential investors in collective investment schemes and/or managed accounts for which we act as investment manager;
- Fund distributors and other business partners (e.g. local paying agents, fund trading platforms, consultants);
- Supplier and vendor contacts to support the services that we provide; and
- Employees, consultants and temporary workers.
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give to us in connection with the provision of our investment management services and/or by corresponding with us by phone, email, in writing or otherwise.
It includes information that you provide to us when you enquire about or invest in a collective investment scheme for which we act as investment manager, subscribe to our mailing lists and/or attend events or meetings organised by us. It includes information that you provide to us when you appoint us as the investment manager of your managed account.
The information that you provide to us, or that we collect from you, may include your name, address, date of birth, private and/or corporate email address, private and/or corporate telephone number, specific and general financial information, sensitive documentation and other data which relates to your background, circumstances, investment experience, and information pertaining to your employment including obtaining information from public registers with governmental and/or quasi-governmental organisations (e.g. the Financial Conduct Authority), copies of identification documents such as a passport or driving licence, photographs, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, and/or a corporate website.
Purposes of the processing and legal basis for the processing
We use information held about you in the following ways:
- To enable us to carry out our discretionary investment management activities;
- To enable us to comply with our regulatory and legal record-keeping obligations;
- To provide you with periodic updates as to the performance of the collective investment schemes or managed accounts in respect of which Algebris acts as investment manager;
- To carry out our obligations arising from any contractual obligations amongst us, you and the collective investment schemes or managed accounts for which Algebris acts as investment manager;
- To provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to you, your organisation and/or the shares/units that you hold in a collective investment scheme or managed account for which Algebris acts as investment manager;
- To provide you with information about other products and services that Algebris offers that are similar to those that you have already been provided with or have enquired about.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below within section 4, although we will also in certain circumstances rely on contract, legal obligation and consent for specific uses of data.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal and/or regulatory obligations.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described within this section 4.
As an investment management firm we provide discretionary investment management services to a number of collective investment schemes and a number of managed accounts. In this capacity, the exchange of personal data between: us; you; the collective investment schemes or managed accounts (for which we act as investment manager); certain third parties (appointed to provide ancillary services directly related to the provision of our discretionary investment management activities); and global governmental and quasi-governmental agencies is a fundamental and essential part of our business.
In order to support those collective investment schemes and managed accounts for which we act as investment manager, we maintain databases of personal data of investors or prospective investors in such collective investor schemes and managed accounts which contain both current and historical information of the kind described within section 2 above.
In order to maintain, expand and develop our business we must record the personal data of investors in the collective investment schemes that we manage.
Disclosure of your information inside and outside of the EEA
We may disclose information about you to our affiliates or third parties, including the administrator and the prime brokers and the custodians of the collective investment schemes and/or managed accounts that are managed by Algebris, for our everyday business purposes, such as to facilitate transactions, maintain your account(s) or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information about the investors in order to accept subscriptions from them or to facilitate the establishment of trading relationships with executing brokers or other trading counterparties. 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 as described above. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. If you are a new investor, we can begin sharing your information 30 days from the date we sent this privacy notice. When you are no longer our investor, we may continue to share your information as described in this privacy notice.
We do not share your information with non-affiliates for them to market to you
In addition to the above, we may also disclose your personal information to third parties in the following circumstances:
- Where Algebris sells or buys a business and/or assets, we may disclose your personal data to a prospective seller or buyer of such a business or assets;
- If Algebris or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers and/or investors will be one of the transferred assets.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to facilitate the provision of the ancillary services to us and/or the collective investment schemes and/or managed accounts for which we act as investment manager;
- satisfaction of their contractual obligations to us as our data processor;
- for the purpose of a contract in place or in contemplation;
- to fulfil their legal and/or regulatory obligations.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA to enable us to provide our discretionary investment management services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, amongst other things, the provision of discretionary investment management services. By submitting your personal data, you agree to this transfer, storing and/or processing. Algebris will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Retention of your data/strong>
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
The GDPR provides you with the following rights:
- To request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- To request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- To object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- To request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- To request the transfer of your personal information to another party in certain formats, if practicable.
- To make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act/GDPR.
A subject access request should be submitted to firstname.lastname@example.org .
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on our website and, where appropriate, notified to you by email. We would encourage you to periodically review our privacy notice to ensure that you continue to be aware of your rights.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to email@example.com.
For the purposes of data protection legislation in force from time to time the data controller is Algebris (UK) Limited, 4th Floor, 1 St. James’s Market, London, SW1Y 4AH.
Our nominated representative is David Liddle.
Public Regulatory Disclosures
Algebris (UK) Limited
In 2006, the Basel II capital accord revised the existing regulatory capital framework to make it more sensitive to the risk management practices of modern banks and investment firms. The European Union implemented these provisions via the Capital Requirements Directive (‘CRD’), which consists of a three pillar framework:
- Pillar 1 – sets out the minimum capital requirements firms will be required to hold in order to meet credit, market and operational risk.
- Pillar 2 – firms and supervisors have to take a view on whether a firm should hold additional capital against risks not covered in Pillar 1 and must take action accordingly.
- Pillar 3 – aims to improve market discipline by requiring firms to publish certain details of their risks, capital and risk management.
The United Kingdom financial regulatory body, the Financial Conduct Authority (‘FCA’) has incorporated the new framework into its existing rules and guidance through the General Prudential Sourcebook (‘GENPRU’) and the Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’).
- BIPRU 11 relates specifically the Pillar 3 disclosure requirements affecting firms subject to the CRD. This document discloses those requirements, as laid out in BIPRU 11.5, detailed below:
- BIPRU 11.5.1R – the risk management objectives and policies for each separate risk referred to under BIPRU 11.5.1R to 11.5.17.
- BIPRU 11.5.2R – the scope of application of directive requirements.
- BIPRU 11.5.3R – information regarding capital resources.
- BIPRU 11.5.4R – information regarding compliance with the BIPRU rules and the overall Pillar 2 rule.
- BIPRU 11.5.12R – regarding disclosures relating to market risk.
Information which is regarded as proprietary or confidential, or immaterial, is not included. Information should be considered as material if its omission or misstatement could change or influence the assessment or decision of a user relying on it to make economic decisions. Proprietary or confidential information could include information which, if shared with competitors, would render a firm’s investments less valuable or if the information comprises obligations to customers or other counterparty relationships binding a firm to confidentiality.
Scope of application of directive requirements
The Pillar 3 disclosures set out in this document pertain to Algebris (UK) Limited (‘Algebris’ or ‘the firm’), an FCA registered limited licence BIPRU investment firm.
The firm is a subsidiary of Algebris Investments Luxembourg SARL, which is not regulated.
Historically, Algebris Investments (UK) LLP was the investment manager of the various Algebris funds and managed accounts. As part of an internal re-organisation between December 2016 and June 2017 Algebris (UK) Limited became the investment manager of the various funds and managed accounts.
Algebris (UK) Limited is a Collective Portfolio Management Investment (“CPMI”) Firm, as a result in addition to having to meet regulatory capital requirements based upon the retention of sufficient regulatory capital to meet an expenditure based requirement, Algebris is also subject to a capital requirement based upon its Assets Under Management. Although, as an AIFM, Algebris is subject to the capital requirements of the AIFMD, it continues to be categorised as a BIPRU Firm and is still subject to the Pillar 3 Disclosure Requirements. For the purposes of the CRD, the firm is not consolidated as per BIPRU 8.5.
There are no current or foreseen material practical or legal impediments to prompt the transfer of capital resources or repayment of liabilities between the parent undertaking and any subsidiary undertakings. The firm’s capital resources are in excess of the required minimum and it is not affected by a solo consolidation waiver.
Risk management objectives and policies
The firm is governed by its Directors who determine its business strategy and risk appetite. They are also responsible for establishing and maintaining the firm’s governance arrangements, along with designing and implementing a risk management framework that takes into account the risks that the firm is likely to meet. The firm also addresses how these risks should be mitigated and managed.
BIPRU 11.5.4-17 lists several risk categories for which the risk strategy must be disclosed. From those listed, the firm has identified credit, market and operational risks as currently applicable to its business. All risks identified are reviewed regularly as part of the firm’s internal capital adequacy assessment process (ICAAP). Any perceived changes to these risks are acted upon promptly.
The firm is exposed to credit risk through its cash deposits, trade debtors, intercompany balances prepayments, amounts due from member’s, and the Firm’s monthly management fees.
The firm will hold all cash with banks with whom the firm has strong, well-established relationships and who typically have a minimum Moody’s or S&P rating of investment grade. It does not have any external investments.
The firm uses the standardised approach to calculating credit risk exposures, i.e. 8% of the risk weighted credit exposure. Under this approach the firm calculated its total credit risk to be €1,086,881.
Market risk is primarily limited to foreign exchange risk arising from a currency mismatch between the firm’s management fees and functional currency. The majority of the management and performance fees are received in the firm’s base currency, Euro. As the currencies involved are highly liquid (Sterling, Dollar and Euro), and the potential fluctuations relatively small, the firm does not believe it is necessary to hedge this exposure.
The firm uses the standardised approach to calculating market risk exposures, i.e. 8% of the risk weighted market exposure. Under this approach the firm calculates its total market risk to be €189,044.
The firm has in place a companywide risk management framework which outlines responsibilities and escalation procedures for the identification and management of risks, as outlined in the risk policy. As part of this risk management framework, the firm explicitly considers whether each identified key operational risk should be ‘taken’ (i.e. accepted with no changes to business processes and controls)’, ‘treated’ (i.e. its impact or likelihood of occurrence reduced by improvements in the control environment) or ‘transferred’ (i.e. insured). The responsibility for ensuring that operational risk management is performed in line with this ‘take, treat or transfer’ approach rests with the Risk Committee and Directors of the firm.
The driver of the Pillar II capital is operational risk. The Operational Risk has been calculated using the Standardised Approach, as per, BIPRU 6.4. The firm has calculated that its Pillar II Operational Risk is €717,675.
Fixed Overhead Requirement
The Firm has determined the Fixed Overhead Requirement (FOR) to be €2,822,036. The Firm has determined that the actual costs associated with a wind down to be €1,328,810, which is less than those determined in the FOR calculation.
The total value of tier 1 capital resources, reflecting the Firm’s total capital resources as at 31 December 2016 was €10,289,358. There were no deductions relating to material holdings in financial institutions.
The Pillar I Requirement
The Firm’s base capital requirement is €50,000. The Firm bases its Pillar I capital requirements as the fixed overhead requirement, as this amount is higher than both the sum of the credit risk and market risk, and the base capital requirement. The firm’s total Pillar I liquid capital requirement is therefore €2,822,036.
The Pillar II Requirement
The firm has calculated that €717,675 of capital should be held against Pillar II Operational Risks.
Total Capital Requirement
The Firm bases its Total Capital Requirement calculation on the Pillar I Plus approach. The sum of the individual Pillar I and Pillar II Capital Requirements is €3,539,710. This is greater than the cost of a wind down, and thus reflects the Firm’s Total Capital Requirements.
The Firm holds €6,749,648 of surplus Capital.
UK Stewardship Code Disclosure Statement
Under COBS 2.2 of the FCA Handbook, all FCA authorised firms are required to make a public disclosure in relation to the nature of their commitment to the above Code (“the Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010.
The Code aims to enhance the quality of engagement between institutional investors and the companies they invest in with the intention of improving long term returns for shareholders and the efficient exercise of governance responsibilities. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. Firms may either comply with the Code or choose not to comply with certain aspects of the Code, in which case an explanation of non compliance is required. If a firm does not commit to the Code, it must state, in general terms, its alternative investment strategy.
On behalf of the funds that it manages, the Firm invests in securities issued in, but not limited to the entirety of the European Union. The Code is therefore applicable only to some aspects of the firm’s trading (UK equities), but this represents just a small proportion of the firm’s business. At times, the funds may hold no UK equities. Although the firm supports the Code’s objectives, the firm has taken the decision not to commit to the specific principles of the Code.
The Firm invests in various asset classes and jurisdictions globally. The current policy of the Firm in engaging with issuers and their management is determined by the Chief Investment Officer and the investment team. The Firm takes a consistent approach to engaging with the issuers and their management in all the jurisdictions the Firm invests in. It is therefore not deemed appropriate to comply with any voluntary codes of practice in individual jurisdictions.
FCA Remuneration Code (the “Code”)
The Firm is a proportionality level three firm, as described in the FCA’s General Guidance on Proportionality dated September 2012, for the purpose of the Code. The other entities within the UK consolidation group of which the firm is a member are not considered relevant for the purpose of the disclosure requirements of BIPRU 11.5.18R in view of the limited nature of their activities (they are however subject to the Code’s provisions). This disclosure relates to the 12 month period ended 31 December 2016.
The remuneration policy is the responsibility of the Firm’s Board. The Board oversees the remuneration governance framework and ensure that remuneration arrangements are consistent with, and promote, effective risk management (the agency nature of the business of the firm does not place its balance sheet directly at risk).
The Board considers remuneration in the context of a wider agenda including retention, recruitment, motivation and talent development and the external market environment. The Board also receives updates on regulatory developments and general remuneration issues, as well as market and benchmarking data.
The Board sets and monitors the remuneration policy standards and monitors compliance with them. The amount and composition of the total remuneration paid is determined under this policy.
Information on the link between pay and performance
The various components of total remuneration (which comprise base salary, variable bonus and benefits) are considered and are balanced appropriately having regard to the role fulfilled by each particular individual.
Firm and individual performance are the significant contributors to the determination of variable bonus awards. The principal objective in determining variable bonus awards is to reward individual performance whilst ensuring that such payments are warranted given business results. In this context performance can include financial and non-financial measures, risk measures and other relevant factors. There is a focus on differentiation so that any rewards are determined according to the contribution of individuals. Bonus pools and individual awards are subject to the governance of the Board and it is possible that in any year no variable bonus will be awarded.
Staff are strongly encouraged to personally invest in the Algebris funds which supports a performance culture where employees recognise the importance of sustainable (and sustained) firm and individual performance. This also encourages sound risk management whilst aligning the longer-term interests of participants with those of investors.
Quantitative information on remuneration
The Firm considers that it has a single business area (investment management). The aggregate remuneration of the individuals engaged in this business area for the period was €15,556,756, which is comprised of 47 individuals. This includes the aggregate remuneration of €12,941,967 of its Remuneration Code Staff, which is comprised of 19 individuals each of whom performs a significant influence function. The latter figure includes the aggregate remuneration of individuals who ceased to become Remuneration Code Staff during the year to 31 December 2016.
Modern Slavery Statement
Algebris (UK) Limited, Algebris Investments (UK) LLP, Algebris Investments (US) Inc, Algebris Investments (Asia) Pte Ltd, Algebris Investments (Luxembourg) Sarl and Algebris (UK) Limited – Milan Branch (collectively “Algebris Investments”) fully supports the Modern Slavery Act, which aims to drive out all forms of modern day slavery and human trafficking from business practices. Algebris Investments takes a zero tolerance approach towards human rights violations and is committed to having ethical and sustainable business practices and supply chains.
Our Organisation, Risks and Policy
Algebris Investments has considered its direct exposure towards forms of slavery, human trafficking or child labour and, in particular, its employment practices which it believes eliminate any risk of these occurring at Algebris Investments. Algebris Investments operates in the financial services industry which, by its nature, limits direct exposure towards forms of slavery, human trafficking or child labour. As is generally the case with financial services firms, Algebris Investments is required to be authorized, is subject to regulatory supervision and operates in a heavily regulated environment. Algebris Investments undertakes comprehensive pre-employment checks in relation to all potential employees that are required to be satisfied prior to employment. In addition, the work carried out typically requires staff with a higher education or other professional qualifications who, in order to perform their roles, are often subject to individual regulatory authorisation and continuing professional training requirements. Algebris Investments does not believe any incidents as outlined by the Modern Slavery Act have ever occurred within Algebris Investments.
It is noted that, being in a professional services industry, procurement activities are also limited, as products and services are not manufactured using raw materials or other material goods, and material goods are not produced and sold by Algebris Investments. Accordingly, Algebris Investments’ exposure to supply chain risks is also considered limited. However, Algebris Investments has undertaken a risk based assessment of its suppliers and has determined due diligence based on the level of risk associated with each service provision.
As part of our commitment to the aims of the Modern Slavery Act, Algebris Investments seeks to ensure that it knows who is providing it with goods and services at all times. Algebris Investments will communicate its policy of zero tolerance in writing to its existing and new suppliers that pose a material or higher risk. Algebris Investments also has controls in place to ensure that legal and regulatory requirements, including the Modern Slavery Act, are considered prior to any supplier agreement being finalized. Algebris Investments has standard contractual provisions on modern slavery that are included wherever appropriate.
Algebris Investments’ material outsourcing relationships are with other financial services firms which, for similar reasons, are low risk from a modern slavery perspective. Notwithstanding, Algebris Investments has obtained Modern Slavery Act statements of compliance from all such suppliers rated as posing a material or higher risk. Algebris Investments also conducts routine periodic due diligence over its material outsourcing relationships and other vendors and includes modern slavery checks as part of these processes. Algebris Investments has reviewed service providers involved in the provision of office facilities, cleaning, and other products and services for its offices.
Algebris Investments’ Code of Ethics includes sections on ethical procurement, which all staff are provided with and attest to on at least an annual basis.
Algebris Investments will continue to look at how it can further mitigate the risk of modern slavery in its supply chain, and is ready to take appropriate action promptly to address any concerns that may arise. To this end, it will monitor the effectiveness of this policy and take any steps as may be appropriate to maintain an effective zero tolerance anti-modern slavery policy. This includes ensuring that all of its suppliers, existing and new, that pose a material or higher risk have provided statements of compliance; that contractual terms with any such new suppliers satisfy modern slavery requirements; that all relevant staff receive training appropriate to their needs and that any material issues arising from implementation of this policy are effectively escalated should the need arise.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. As required by the Act, it has been approved by the Board of Directors of Algebris (UK) Limited, and it has been published on our website.
RTS 28 Disclosure