Pillar 3 Disclosure

Camomille LLP (the “Firm”) is authorised and regulated by the Financial Conduct Authority (the “FCA”).  The Firm is categorised as a BIPRU limited license firm by the FCA for capital purposes. The Firm is a member of a group and is required to prepare consolidated reporting for prudential purposes.

The Directors of the Corporate member, the members and the Chief Financial Officer, who is also the compliance officer, (known as the “Board”) of the Firm who determine its business strategy and the risk appetite, have designed and implemented a risk management framework that recognizes the risks that the Firm faces. The Board also determines how those risks may be mitigated and assesses on an ongoing basis the controls and procedures necessary to manage those risks. The Board meets on a regular basis to discuss current projections for profitability, liquidity, regulatory capital management, business planning and risk management.

The Board manages the Firm’s risks through a framework of policies and procedures having regard to relevant laws, standards, principals and rules (including FCA principals and rules) with the aim of operating a defined and transparent risk management framework.  These policies and procedures are updated as required.

The Board has identified that business, operational, market and credit risks are the main areas of risk to which the Firm is exposed.  There is a regular review of these risks, the controls and other risk mitigation arrangements and assessment of their effectiveness.  Where the Board identifies material risks they model the financial impact of these risks as part of the business planning and capital management and conclude whether the amount of regulatory capital is sufficient.

The Firm has a small, yet effective, operational structure.  It carries no market risk, other than foreign exchange risk on its cash, accounts receivable and foreign exchange forward contracts (hedges) denominated in foreign currency, and credit risk from its cash counterparties as well as from its management and performance fees receivable from its clients.  The firm uses the standardized approach to market risk and the simplified standard approach to credit risk.  The Firm is subject to the Fixed Overhead Requirements and is not required to calculate an operational risk charge.

As discussed above the firm is a BIPRU limited license firm and assigned a C4 conduct classification and a P3 prudential classification.  As such its capital requirements are the greater of:

  • a base capital requirement of EUR 50,000;
  • the sum of market and credit risk requirements; and
  • the Fixed Overhead Requirement (“FOR”).

It is the Firm’s experience that its capital requirement normally consists of the FOR.

Having performed the ICAAP it is the Firm’s opinion that no additional capital is required in excess of its Pillar 1 capital requirement.

Remuneration Disclosures

As an LLP, the Firm is owned by the Partners.  Each partner is obliged, on joining, to contribute capital to purchase their ownership interest.  Such interest gives them the right to share in the profits of the Firm, in accordance with the terms of the Partnership Agreement.

The LLP is majority owned by Camomille Associates Ltd, its corporate partner who is responsible for the operations of the Firm.

The FCA defined Remuneration Code Staff (“Code Staff”) as senior management, risk takers, staff engaged in control functions and any employee receiving total remuneration that takes them into the same remuneration bracket as those whose professional activities have a material impact on the Firm’s risk profile.

The Firm has decided to treat all Partners as Code Staff.  One of the Code Staff is registered with the FCA as CF30.

Camomille LLP has determined that the Firm is a “Remuneration Code: Proportionality Level 3” firm and has applied proportionality and, where relevant, has neutralized various provisions of the FCA Remuneration Code.

The Partner’s profit share is paid from profits after ensuring FCA capital, liquidity and working capital requirements have been considered.

As well as Partners, the Firm, via its corporate member, has a number of employees who are salaried personnel and who are entitled to a discretionary bonus determined by the Firm’s Board.  These remuneration arrangements are considered in accordance with the FCA’s Remuneration Principles.

It has been determined that, due to the limited number of remuneration code staff, disclosure of aggregated remuneration amounts for the financial year, along with details such as the split between fixed and variable remuneration would result in the disclosure of remuneration amounts that could be attributed to specific employees when such information is combined with publicly available information about the Firm.