Information

Regulation

This website is issued by Credere Capital LLP (“Credere”). Credere is authorised and regulated in the United Kingdom by the Financial Conduct Authority (“FCA”).

The information in this website was prepared by Credere and is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence, domicile or otherwise) we would become subject to licence or registration regulations of the jurisdiction, or the publication or availability of this Website is prohibited. Persons in respect of whom such prohibitions apply must not access this Website. The information in this website is not intended for the use of and should not be relied on by any person who would qualify as a Retail Client. In addition, access to the information included on, and the services and/or products described on, this website may be restricted to certain other categories of persons or in some countries. It is your responsibility to be aware of and to observe all applicable laws and regulations of any relevant jurisdiction. You hereby acknowledge this website is intended only for persons meeting the requirements noted above and represent that you are authorised to access the information contained on this website under applicable law.

Credere Capital LLP is a limited liability partnership incorporated in England and Wales (number OC400672), with its registered address at 60 Gresham Street, London EC2V 7BB.

Use of Site

Use of this website is subject to the following terms and legal notices (“Terms of Use”). You may not use this website for any purpose that is unlawful or prohibited by these Terms of Use.

Upon access to this website, you consent to the Terms of Use and in particular, you acknowledge and confirm that: You qualify as a Professional Client or Eligible Counterparty under the FCA rules; and/or you are authorised to access this website under applicable law.

Access

The information in this website was prepared by Credere only for, and is directed only at, persons that qualify as Professional Clients or Eligible Counterparties under the FCA rules, including appropriate institutional investors and intermediaries, or ‘Sophisticated Investors’ under the AIFMD. The services provided by Credere are available only to such persons. The information in this website is not intended for the use of and should not be relied on by any person who would qualify as a Retail Client.

Credere is established in the United Kingdom, which is a member state of the European Economic Area (the “EEA”). Accordingly, this website is issued by Credere to firms and other persons that are both resident in and accessing this website from any member state of the EEA in reliance on its rights under the Directive on Electronic Commerce (number 2000/31/EC). The member states of the EEA are: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovak Republic, Slovenia, Spain, Sweden and the United Kingdom.

If you are not resident in an EEA member state or you are viewing this website in a country that is not an EEA member state, information displayed on this website contains material that may be interpreted by the relevant authorities in the country from which you are viewing the website as a financial promotion or an offer to purchase securities. Accordingly, the information on this website is not intended for you. By reviewing the information in this website, you hereby acknowledge this website is intended only for persons meeting the requirements noted above and represent that you are authorised to access the information contained on this website under applicable law (e.g., you fall outside the scope of any law that seeks to regulate financial promotions in your country of residence or in the country in which the website is being viewed). If you are uncertain about your position under the laws of your country of residence or the country in which the website is being viewed then you should consult your legal adviser.

Investment Management

The description of the investment management services and processes in this website is necessarily general in nature. The terms and conditions applicable to individual investors will be set out in the applicable contract or offering document.

Investments

Applications to invest in any product referred to on this website must only be made on the basis of the documentation relating to the specific investment.

Risk Warnings

You should always bear in mind that:

The value of investments and any income from them may go down as well as up. You may not get back all of your original investment. Past performance is not a reliable indicator of future results. You should be aware that indications of past performance displayed on this website will not necessarily be repeated. Rates of exchange may cause the value of underlying investments to go up or down

No Reliance

Although Credere has taken all reasonable care to ensure that the information contained within the website is accurate at the time of the publication, no representation or warranty (including liability towards third parties), express or implied, is made as to its accuracy, reliability or completeness of such information by Credere. Opinions and any other contents on this website are provided by Credere for personal use and informational purposes only and are subject to change without notice.

No Advice

Nothing contained on the website constitutes investment, legal, tax or other advice nor is to be relied on in making an investment or other decision. You should obtain appropriate professional advice before making any investment decision.

No Offer

The information on this website (including, but not limited to, any documentation, data, literature or other material) is issued by Credere for information only. It does not constitute an offer by Credere to enter into any contract or agreement, nor is it a solicitation to buy or sell any investment.

Cookies

Like many websites, this website may use “cookies”. A cookie is a piece of data stored on a user’s device containing information about the user’s visit. Cookies are of various types and have different purposes.

You can change the user settings in your browser to prevent this website storing cookies on your device. You can find out how to do this, and find more information on cookies, at: www.allaboutcookies.org.

No Warranty; Liability

Credere does not warrant as to the adequacy, accuracy, reliability or completeness of any information on the website and expressly disclaims any liability for errors or omissions therein. You are responsible for evaluating the adequacy, accuracy, reliability and completeness of any information or the content available on the website.

Credere makes no guarantee as to the adequacy, accuracy, reliability or completeness of any information on any website to which you gain access via a hypertext or other link from this website.

If you are in any doubt about the information contained on this website, please contact us or consult your usual professional adviser.

Credere will not be liable for any damages (including without limitation loss of profit or loss of use) arising out of your use or delay or inability to use this website, its content or any link to another website arising in contract, tort (including negligence) or otherwise. Credere does not however exclude liability for death or personal injury caused by negligence.

Termination

Credere may terminate your access and use of any part of this website at any time without notice (whether or not you are in breach of any of these Terms of Use).

Confidentiality

Certain parts of this website are accessible only with a password. If Credere issues you with a password (a “Password”) you shall keep it confidential and not share it with any other person. You shall keep content accessed with a Password confidential and not disclose it to any other person. This does not apply to any content which comes into the public domain other than through your breach of these Terms of Use. You shall be responsible for any access to the website (whether or not authorised by you) made using such Password.

Intellectual Property

Content included in this website is owned by Credere or its licensors and may be accessed for your own personal, non-commercial use only (whether or not it is confidential). Where the functionality is provided, you may also for this purpose download reasonable excerpts of this content to your own device. Other than this, you may not copy, perform, publish, modify, transfer, commercially exploit or otherwise use any content obtained from this website.

Credere expressly prohibits linking by other sites to any part of this website other than the home page (so-called “deep-linking”) or other than where Credere has otherwise expressly given permission. In addition, Credere expressly prohibits the linking to the home page of this website in such a manner that suggests or could be understood to imply that any part of this website is part of another website and, in particular, third parties must not frame or use other techniques to enclose any part of this website.

Links

Credere does not control, endorse and is not responsible for the availability or content of any third party websites available via this website through a link.

Law and Jurisdiction

These Terms of Use shall be governed by and interpreted in accordance with English law and the courts of England shall have non-exclusive jurisdiction to hear all disputes arising in connection with these Terms of Use.

Specific Jurisdictional Notifications

UK

In the UK, this Website is directed only at persons who (i) have professional experience in matters relating to investments who fall within Article 19(1) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (“FPO”), (ii) are high net worth companies, unincorporated associations, etc. within Article 49 FPO or (iii) are persons to whom it otherwise lawfully may be communicated (including, for the avoidance of doubt, such persons that fall within a specified exemption under the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 or COBS 4.12 of the Financial Conduct Authority Conduct of Business Sourcebook).

All persons who fall within the above categories are deemed “Relevant Persons”. Any investment or investment activity to which this Website relates is available only to, and will be engaged in only with, Relevant Persons. Any person who is not a Relevant Person should not act or rely on this Website or any of its content.

European Economic Areas

In the European Economic Area, the information on this Website is not to be issued or distributed to, nor directed at, persons other than “Qualified Investors” within the meaning of Article 3(2)(a) of Directive 2003/71/EC (the “Prospectus Directive”). The information contained on this Website must not be accessed by, acted on, or relied on by persons in the European Economic Area who are not Qualified Investors. Within the European Economic Area, any investment or investment activity to which the information on this Website relates is only available to Qualified Investors and will be engaged in only with Qualified Investors.

Switzerland

The Funds mentioned on this Website have not been registered with the Swiss Financial Market Supervisory Authority FINMA as foreign collective investment schemes pursuant to Article 120 of the Swiss Collective Investment Schemes Act (the “CISA”). Accordingly, the interests in the Funds may not be publicly offered in or from Switzerland, and no offering or marketing materials relating to the interests in the Funds may be made available through a public offering in or from Switzerland. The interests in the Funds may only be offered and any offering or marketing materials may only be distributed, or otherwise made available, in or from Switzerland by way of private placements exclusively to qualified investors as such term is defined in the CISA and its implementing rules and regulations.

Neither the contents of this Website, nor any offering or marketing materials relating to the interests in the Funds have been or will be filed with, or approved by, any Swiss regulatory authority. The investor protection afforded to investors of interests in collective investment schemes under the CISA does not extend to acquirers of interests in the Funds.

This Website does not represent a prospectus as defined in Article 652a or 1156 of the Swiss Code of Obligations.

Hong Kong

No Credere entity is currently licensed or regulated by the Hong Kong Securities and Futures Commission (“SFC”). No collective investment schemes presently managed by Credere are currently authorized by the SFC and they are, therefore, not available for investment by Hong Kong retail investors. The information on this website has not been reviewed or approved by the SFC or any regulatory authority in Hong Kong.

The information you are about to access is available in Hong Kong only (1) to “professional investors” or (2) in circumstances which do not constitute an offer to the public for the purposes of the Companies Ordinance (Cap 32, Laws of Hong Kong) or the Securities and Futures Ordinance (Cap 571, Laws of Hong Kong) (“SFO”), and only such offerees are eligible to act on the information herein. As defined in the SFO and its subsidiary legislation, “professional investors” include the following: 1) exchange companies and other automated trading facilities; 2) licensed financial intermediaries, their wholly-owned subsidiaries and holding companies; 3) licensed banks, their wholly-owned subsidiaries and holding companies; 4) licensed insurers; 5) authorised retail funds; 6) Hong Kong mandatory provident fund schemes or a trustee or an investment manager of any such scheme; 7) any government of central banking authority; 8) a trust corporation with total assets of at least HK$40m; 9) an individual (either alone or with any of his or her associates on a joint account) with a portfolio of investments valued at at least HK$8m; 10) a corporation or partnership having a portfolio valued at at least HK$8m or total assets of at least HK$40m; and 11) an investment holding company wholly-owned by a person referred to in preceding category.

Pillar 3 Disclosure

Updated 23 May 2018.

Introduction

Credere Capital LLP (“Credere” or the “Firm”) is a London-based discretionary investment manager to a unregulated collective investment scheme. The Firm is required to make its Pillar 3 disclosure at least annually, and is made as at the Firm’s Accounting Reference Date. The disclosure may be published on our website or as an appendix to our statutory audited annual accounts. The purpose of this disclosure is to encourage market discipline.

The Capital Requirements Directive (CRD) created a revised regulatory capital framework across Europe covering how much capital financial services firms must retain. In the United Kingdom, rules and guidance are provided in the General Prudential Sourcebook (GENPRU) for Banks, Building Societies and Investments Firms (BIPRU).

The FCA framework consists of three “Pillars”:

  • Pillar 1 sets out the minimum capital requirements that companies need to retain to meet their credit, market and operational risk;
  • Pillar 2 requires companies to assess whether their Pillar 1 capital is adequate to meet their risks and is subject to annual review by the FCA;
  • Pillar 3 requires companies to develop a set of disclosures which will allow market participants to assess key information about its underlying risks, risk management controls and capital position. These disclosures are seen as complimentary to Pillar 1 and Pillar 2.

BIPRU 11 sets out the provisions for Pillar 3 disclosure. The rules provide that companies may omit one or more of the required disclosures if such omission is regarded as immaterial. Information is considered material if its omission or misstatement could change or influence the decision of a user relying on the information. In addition, companies may also omit one or more of the required disclosures where such information is regarded as proprietary or confidential.

The information contained in this document has not been audited, and as such does not constitute any form of financial statement and must not be relied upon.

Firm Overview

Credere is incorporated in the UK and is authorised and regulated by the Financial Conduct Authority (“FCA”) as a Full-Scope Alternative Investment Fund Manager with the Collective Portfolio Management Firm (“CPMI”) designation, which also makes the Firm a BIPRU firm. The Firm is a Solo regulated entity, and as such does not form part of UK Consolidation Group for FCA prudential requirements.

The Governing Body of Credere has management and oversight responsibility. It generally meets quarterly and is composed of:

  • Oliver Dobbs Managing Partner
  • David Staton Partner
  • Nicolas Marquez Partner
  • Catherine Vassallo Partner

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

Capital Resources and Requirements

Pillar 1

As a limited liability partnership its capital arrangements are as follows: The Firm is a BIPRU Investment Firm without an Investment Firm Consolidation Waiver deducting Material Holdings under (GENPRU 2 Annex 4). Tier 1 Capital comprises of Members’ Capital.

As a CPMI, the Firm is subject to the capital requirements set out in IPRU(INV) Chapter 11 and also BIPRU/GENPRU. The Firm has the following capital resources:

Members Capital: Tier 1 capital of £160,831.

As at 31 March 2018, the Firm’s Pillar 1 capital resource requirement was £43,980.

Pillar 2

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 which takes the higher of Pillar 1 and 2 as the ICAAP capital requirement. It has assessed Business Risks by modeling the effect on its capital planning forecasts and assessed Operational Risk by considering if Pillar 2 capital is required taking into account the adequacy of its mitigation.

Since the Firm’s Internal Capital Adequacy Assessment Process (ICAAP or Pillar 2) process has not identified capital to be held over and above the Pillar 1 requirement, the capital resources detailed above are considered adequate to continue to finance the Firm over the next year. No additional capital injections are considered necessary and the Firm expects to continue to be profitable.

Risk Management

The Firm has established a risk management process in order to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the Firm’s members.

As risks are identified within the business, appropriate controls are put in place to mitigate these and compliance with them is monitored on a regular basis. The frequency of monitoring in respect of each risk area is determined by the significance of the risk. The Firm does not intend to take any risks with its own capital and ensures that risk taken within the portfolios that it provides investment services to is closely monitored. Details of the Firm’s risk management systems and controls is reported to the Governing Body.

The Firm has a risk management objective to develop systems and controls to mitigate risk to within our risk appetite, as set-out in our ICAAP. Ordinarily, a firm must disclose its risk management objectives and policies for each separate category of risk. On the basis of materiality, we have omitted those items not relevant to the Firm, however, have provided summary information upon the below listed risk items.

Operational Risk

The Firm places strong reliance on the operational procedures and controls that it has in place in order to mitigate risk and seeks to ensure that all personnel are aware of their responsibilities in this respect.

The Firm has identified a number of key operational risks. These relate to disruption of the office facilities, system failures, trade failures and failure of third party service providers. Appropriate policies are in place to mitigate against risks, including appropriate insurance and business continuity plans.

Credit Risk

The main credit risk to which the Firm is exposed is in respect to the failure of its debtors to meet their contractual obligations. The majority of the Firm’s receivables is related to its investment management activities. The Firm believes its credit risk exposure is limited since the Firm’s revenue is ultimately related to management fees received from funds, which are drawn throughout the year from the funds managed. Other credit exposures include bank deposits. The Firm undertakes periodic impairment reviews of its receivables. All amounts due to the Firm are current and none have been overdue during the year.

The Firm has adopted the standardised approach to credit risk, and therefore follows the provision within BIPRU 3 standardised credit risk of the FCA handbook. The Firm applies a credit risk capital component of 8% to its non-trading book risk weighted exposure. As the Firm does not make use of an external credit rating agency, it is obligated to use a risk weight of 100% to all non-trading book credit exposures, except cash and cash equivalents which are held by investment grade firms and currently attract a risk weighting of 20%. The Firm has excluded disclosure of its Credit risk calculation on the basis that it is not material.

Market Risk

The Firm is not exposed to Market risk, since the Firm holds no trading book positions on its own account, and all bank accounts are in GBP. Accordingly, the Firm has excluded disclosure of its Market risk calculation on the basis that it is not material.

Remuneration Code

The Firm has adopted a remuneration policy and procedures that comply with the different chapters of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (SYSC), and in accordance with ESMA’s Guidelines on sound remuneration policies. The Firm have considered all the proportionality elements in line with the FCA Guidance. All variable remuneration is adjusted in line with capital and liquidity requirements.

As a UK AIFM the Firm has assessed the proportionality elements and disapplies the Pay Out Rules. Furthermore, the Firm has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the Governing Body sets, and oversees compliance with, the Firm’s remuneration policy including reviewing the terms of the policy at least annually. The Firm make the following remuneration disclosure:

Remuneration Code Staff Remuneration by Business Area*

Business AreaTotal Remuneration
Investment Management£161,000

Aggregate Quantitative Remuneration by Senior Management and other Remuneration Code Staff * **

Type of Remuneration Code StaffTotal Remuneration
Senior Management (SIF)£161,000
Other Remuneration Code Staff£0
Total Fixed Remuneration of Code Staff£0
Total Variable Remuneration of Code Staff£161,000

* The above remuneration disclosure includes remuneration paid to Code Staff in respect to both their AIFMD and non-AIFMD activities.

** As of 31 March 2018

Stewardship Code

Updated 23 May 2018

The Firm supports the principles enshrined in the Financial Reporting Council’s Stewardship Code which sets out good practice for investor engagement. The FCA requires all authorised asset managers to publicly disclose either a statement of compliance with the Stewardship Code or where they do not commit, their alternative investment strategy.

The Financial Conduct Authority and the Financial Reporting Council have acknowledged that certain aspects of the Stewardship Code are not directly relevant to all managers. The Firm is a fund manager to a single alternative fund. Compliance with the Stewardship Code is not relevant to the Firm because it does not adapt an active approach to shareholder participation.

The Firm’s Governing Body will continue to review the Code’s applicability.

For further information on the Firm’s approach please contact the Firm at: catherine@crederecap.com