Public Disclosures
Introduction
Amberside Capital Ltd (the Company) is incorporated in the UK and is authorised and regulated by the Financial Conduct Authority (FCA). As such, the Company has to comply with the Prudential Sourcebook for Investment Firms (IFPRU) and the Investment Firms Prudential Regime (IFPR). The Company is a non-SNI firm that has a permanent minimum capital requirement of £75,000.
The rules set out the need for firms to publish certain details of their risks, capital and risk management in order to improve transparency and market discipline. The Company makes the capital requirement disclosures available on its website and the information is also available from the Company Secretary on request. The disclosures will be updated each year after completion of the annual audit and approval of the audited financial statements. The Company year end is 31st October.
The Company may omit information it deems immaterial. Materiality is based on the criterion that omission or misstatement would be likely to change or influence the decision of a person relying on that information. Accordingly, where the Company has considered an item to be immaterial it has not been disclosed. In addition, if the required information is deemed to be proprietary or confidential then the Company may take the decision to exclude it from the disclosure. It defines proprietary information as that which, if shared, would undermine its competitive position. It defines information as confidential where there are obligations binding it to confidentiality with customers, suppliers or counterparties. If information is omitted for either of these reasons this will be clearly stated. The information in this document has not been audited by the Company’s external auditors.
Capital resources
The FCA’s prudential regime requires firms to consider two or three elements. The first two apply to all firms, the third only to what are called non-Small and non-Interconnected firms (“SNI Firms”). Amberside Capital is an SNI firm.
– Permanent Minimum Requirement – this prescribes the minimum capital requirements that the Company needs to hold and is £75,000 for Amberside Capital.
– Fixed Overheads – this requires firms to consider the costs of running the business for a period of three months and establish which costs could not be reduced in the short term.
In identifying these two numbers, firms under the regime carry out an Internal Capital and Risk Assessment (ICARA). This enables the firm to consider whether additional capital should be allocated to the higher of those numbers through an analysis of the risks to the business and then consider whether the impact of risks is mitigated to an appropriate standard. If the Company considers that the risks are not adequately mitigated, then it will allocate additional capital to cover those risks.
Public disclosure – this requires firms to develop a set of disclosures which allow market participants to assess key information about the Company’s risks, controls and capital position.
Annually, the Board formally review the firm’s risks, controls and other risk mitigation arrangements and assess their effectiveness. Where material risks are identified the company will model the financial impact of these risks as part of its business planning and capital management and conclude whether the amount of regulatory capital is adequate.
Risks considered
Strategic risk – includes the risk of financial loss due to the failure to anticipate the changing business and economic climate in the provision of services to our clients. It also includes risks arising from the way we conduct our business, i.e. regulatory risk. The senior management monitor and review the business to minimise the impact of such risks.
Financial risk – includes the effects of market risk, credit risk and liquidity risk. These arise from having income dependent on the availability of capital in the market and factors leading to creditors not paying and from the management of short-term cash flows. The impact appetite in the sector is carefully monitored by management to assess the impact on the business and determine appropriate actions.
Operational risk – covers our assessment of the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. The Company has procedures in place to check and monitor the processes to minimise these risks.
The directors have discounted areas of risk which are not considered to be material, such as market and credit risk, and have calculated that the fixed overhead is at a higher amount than the base requirement. The conclusions from the ICARA are that no additional capital is required.
As at 31st October 2023, the company had total capital resources of £116,000 and a fixed overheads requirement of £32,000 and a permanent minimum capital requirement of £75,000. As a result, the company has a capital resource surplus, as at that date, of £41,000.
Remuneration policy
Amberside Capital currently has two directors and no staff. The directors take a relatively modest fixed salary paid monthly from the business and additional compensation is in the form of dividends and bonuses. An individual’s share of the bonus pool is dependent on a number of factors including responsibilities and contribution to the Company. The Board reviews the level of salaries and considers any discretionary awards annually. The total remuneration cost for the year of staff within the scope of the Remuneration Code was £216,531.
30th November 2023