Charteris - Treasury Portfolio Managers Limited
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Legal Information – Including Disclaimer & Pillar 3 disclosure document

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Charteris Treasury Portfolio Managers Limited ('Charteris') maintains this website as a service. By accessing, browsing and/or using this website, you acknowledge that you have read, understood, and agree to be bound by the following terms of use and to comply with all applicable laws and regulations.

Terms of Use
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The information contained in this website is believed to be accurate at the time of posting, however Charteris does not warrant the completeness nor accuracy of the information at all times. In addition, Charteris is neither responsible nor liable for any errors or omissions in the information contained in this website.

Charteris does not make any representations regarding any other websites which may be accessed through this website, and accordingly shall not be responsible for other content or use of such websites.

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Forward-looking statements
This website may from time to time contain forward-looking statements relating to Charteris management's expectations, estimates and projections. Words such as 'expects,' 'intends,' 'plans,' 'projects,' 'believes,' 'estimates' and similar expressions are used to identify such forward-looking statements. Any such statements are not guarantees of future performance and can involve certain risks, uncertainties and assumptions that are difficult to predict. Further, certain forward-looking statements are based upon assumptions as to future events that may not prove to be accurate. Therefore, actual outcomes and results may differ materially from what is expressed or forecast in such forward-looking statements.

Pillar 3 Disclosures Document

Introduction:
CTPM is a Discretionary Portfolio Management Company (with a small Number, of legacy advisory clients). It is also the adviser, to a number of funds. CTPM is a BIPRU Limited Licence £125k company.

The following relates to CTPM but not to its client nominee Company, Charteris Treasury Nominees Ltd, nor to its parent Company, Charteris Holdings Ltd.

Risk Management:
The Company’s risk management strategic approach is set by the Board – with day to day management being the responsibility of the Compliance Officer. Objectives and policies are dealt with, collectively, as below.

CTPM is audited annually and this is supplemented by our internal systems and controls. This conforms to the requirements of the Authorisers and Regulators of the Company (the Financial Conduct Authority – the "FCA" and the Financial Services Commission - the "FSC").

Annual Reports are prepared for the Board and updates are issued throughout the year where necessary. The Company has prepared an ICAAP (Internal Capital Adequacy Assessment Process) as is required by the FCA.

Credit Risk:
CTPM mainly deals with the following counterparties: Retails Clients, Market Counterparties, Banks & Custodians.

The assets of our Private clients (Discretionary & Advisory) are held in specially segregated accounts by our custodians AJ Bell. No credit is permitted. As a result, Private Client accounts are not allowed to borrow. No leverage is permitted by the funds of which CTPM are the adviser.

CTPM use the DVP (Delivery Versus Payment) system within the AJ Bell investment IMAS system, when dealing with Market Counterparties for Private Clients. Transactions in the funds, of which CTPM are the adviser, occur between third parties.

When dealing with our Bank and Custodian, we do not allow credit against our holdings. Both daily, and monthly, reconciliations of assets are made by AJ Bell as required by the FCA and FSC.

For BIPRU 3 reporting purposes, the standardised approach is adopted, but using the simplified option where applicable.

Market Risk:
Apart from standard risks in the market, applicable to private clients and the funds (of which CTPM is the adviser). CTPM as an entity is not exposed, directly to market risk. This is because CTPM does not hold principal positions. The impact to the company of changes in market conditions is covered below under the heading "Business Risk and Testing".

Liquidity Risk:
CTPM currently has an agreed overdraft in place with our bankers. The Company currently has cash above its Capital Resource Requirement.

Operational Risk:
The Firm has standard risks, as applicable to most operational contexts. It operates segregation of duties with dealing and settlement handled by the back office and our external custodians whereas Investment Management and Marketing are handled by the front office on a sole instruction basis.

Insurance Risk:
The Company maintains PII (Professional Indemnity Insurance) – as required by the FCA and FSC. In addition has Office Insurance including Employer Liability and public liability. This is complimented by cash reserves, to cover applicable short term contingencies.

Concentration Risk:
The Company has diversified to act as the Adviser on a number of Funds (which are themselves diversified across a number of Asset classes and sectors), to compliment the Private Client element of the business.

Residual Risk:
The Company does not lend money. Most debtors, as applicable, are trade debtors

Securitisation Risk:
This is not applicable to CTPM.

Business Risk and Stress Testing:
Risks to the Company, from its business activities, relate to the impact of significant falls in the equity and/or gilt and/or gold markets, lack of appropriate conditions for trading activity, changes of advisers to Fund investment managers, changes to the wealth management sector and the UK/global economy in general. It also relates to issues which would cause damage to the Company’s reputation. The Company has prepared an ICAAP, as required by the FCA and FSC.

Interest Rate Risk:
As the Company holds some client assets in cash, these assets (and the resultant Annual Management Charge to the company) should benefit/ decrease with rises/ falls in the base rate, as they are impacted. Naturally, stock & securities would be directly or indirectly affected by changes to the interest rate. As no credit is provided to clients (see above), this element would not be impacted by interest rate risks. Any borrowings/overdraft held by the Company would be impacted by changes to the interest rate.

Pension Obligation Risk:
Due to recent legislation, the Company will be obliged to provide a pension for those between 22 and retirement age between August 2015 and April 2017.

Equity/ collective investment schemes (CIS) Risk:
Equities and CIS are used within Funds (of which we are the adviser to the investment managers) and portfolios that CTPM advises on/manages. These are standard risks in the market.

Option Risk:
Options (Covered Calls) are used within the Funds (of which we are the adviser). There are standard risks in the market.

Commodity and foreign currency Risk:
Investments in Commodity based investments and via foreign currencies are made within Funds (of which we are the adviser) & portfolios that CTPM advises and/or manages. There are standard risks in the market.

Trading Book Risk:
This is not applicable to the Firm. CTPM does not run its own trading book.

People Risk:
As identified in the ICAAP, People Risk (Key Person Risk) is particularly weighted in a relatively smaller size Company. As a result, we have invested in key man insurance and have in place a system of cross training and cover to address these issues. These risks have been identified in the annual reports.

Processes & Systems Risks:
These risks have also been identified in the annual reports.

External events Risks:
The risks here have been identified in the annual reports. Exogenous (i.e. external) events – including theft, fire, flooding, terrorist attacks, etc – can be mostly addressed through our BCP [Business Continuity Plan]. This is tested annually.

01/08/2013