IFPR Disclosure Statement 2022
Public disclosure is an essential element of facilitating market discipline and encouraging the stability of financial markets by allowing market participants to assess key information on firms’ capital adequacy and risk and control processes, including remuneration policies and practices.
On 1 January 2022, the UK’s Investment Firms Prudential Regime (“IFPR”) came into force and applies to all FCA-authorised investment firms providing MiFID services.
The public disclosure requirements of IFPR are set out in the Financial Conduct Authority’s (“FCA”) MIFIDPRU 8 standards. Requirements under MIFIDPRU 8 replace the previous disclosure requirements under Pillar 3. In accordance with MIFIDPRU 8.1, Platina Partners LLP (“Platina” or the “Firm”) is required to disclose information abouts its Remuneration Policies and Practices (MIFIDPRU 8.6). It is not required to disclose information relating to its Risk Management Objectives and Policies (MIFIDPRU 8.2), its Own Funds (MIFIDPRU 8.4), its Own Funds Requirements (MIFIDPRU 8.5) and its Investment Policy (MIFIDPRU 8.7).
Remuneration Policy and Practices
Authorised as an Alternative Investment Fund Manager (“AIFM”), Platina is also subject to the AIFMD Remuneration Code of SYSC 19B. The Firm must therefore comply with the higher standard or the most stringent of requirements across both SYSC 19B and 19G (the new MIFIDPRU Remuneration Code).
The disclosure requirements regarding remuneration are set out in MIFIDPRU 8.6. However, in accordance with the transitional provisions in MIFIDPRU TP 12, the Firm is not required to disclose the information about its remuneration policies and practices that would ordinarily be required by MIFIDPRU 8.6 as the Firm’s remuneration period, relating to the financial year ended 31 March 2022, commenced prior to 01 January 2022.
UK Stewardship Code
Under the Financial Conduct Authority Rule COBS 2.2.3R, Platina is required to make a public disclosure in relation to the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”).
The Code aims to enhance the quality of engagement between institutional investors and companies to assist in improving long-term returns to investors and the efficient exercise of governance responsibilities. It provides a set of principles and guidance for how institutional investors should perform their duties. It is to be applied by firms on a “comply or explain” basis.
The Code is directed in the first instance to institutional investors by which is meant asset owners and asset managers with equity holdings in UK listed companies.
The Financial Reporting Council (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. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases, firms are required to explain why it is not appropriate to comply with a particular principle.
Although Platina seeks to align its approach with the broad aims of the Code, the provisions of the Code are primarily not relevant to the type of investment activity currently undertaken by Platina. Should any of these factors change, we will review our commitment to the Code at that time and make the appropriate disclosure.