Pillar 3 Disclosure

for the year ended 30 November 2019

Registration No: 0C302606

Introduction

North Asset Management LLP is authorised and regulated by the Financial Conduct Authority. As part of the Capital Requirement Directive ('CRD') North Asset Management LLP, is required to carry out an Internal Capital Adequacy Assessment Process ('ICAAP').

The capital requirements for firms such as North Asset Management LLP has been enacted in the United Kingdom through the Financial Conduct Authority ('FCA') Handbook and particularly within the FCA Prudential Sourcebook for Banks, Building Societies and Investment Firms ('BIPRU') which are known as Pillar 3. To comply with the new regulatory capital framework the rules built on 3 pillars have to be followed:

Pillar 1 is a variable capital requirement based on the sum of operational, market and credit risk requirements. A firm must maintain at all times capital resources equal to or in excess of the amount specified.

Pillar 2 requires each firms and supervisors to review whether additional capital should be held against risks not covered in Pillar 1, to instigate additional controls to mitigate such risks or a combination of these two approaches.

Pillar 3 requires firms to publish certain details of capital and risk management and to review and update this information at least annually.

Under the rules a firm may omit one or more disclosures where the information provided by such disclosure is not regarded as material.

The disclosures below are the required Pillar 3 disclosures and apply solely to the Firm North Asset Management LLP. The disclosures do not apply to the funds managed by the Firm, which are exposed to different risks.

The Company

North Asset Management LLP was incorporated in 2002 and is authorised and regulated by the Financial Conduct Authority to conduct investment business, without permission to hold and control client money. The firm is categorised as a Limited Licence Firm by the FCA for capital purposes and acts as an Alternative Investment Fund Manager (AIFM) for the Alternative Investment Funds (AIFs) that it manages. North Asset Management principle activity is the provision of investment management and advisory service focusing on the global fixed income and currency markets. North Asset Management LLP also advises on investments, arranging deals on investment, dealing in investment as an agent, making arrangements with a view to transactions in investment and managing investment and therefore Pillar 3 disclosure relate to this entity.

Our business model seeks to maximise absolute total returns by investing in strategies which have strong fundamental basis and are long term in nature.

Risk Management objectives and policies

North Asset Management LLP maintains an uncomplicated company structure, it also does not hold client money or assets on these grounds management have categorised the company as simple and therefore the ICAAP has been prepared in relation to the complexity of this category.

The members of North Asset Management LLP place a high priority on a strong risk management culture. The members recognise that risk is inherent to their business and the market in which they specialise.

North Asset Management faces a number of business risks which are actively managed. The principle risk areas which we seek to manage are investment risk, credit risk, market risk, liquidity risk and operational risk.

Investment risk

Poor investment performance in the funds that we manage could result in a reduction in the management and performance fees that we earn. This is a fundamental risk to our business which we actively manage by:

Recruitment and retention of highly talented portfolio managers who embrace our investment approach of generating attractive risk adjusted returns with an absolute return mentality.
Establishment of a robust investment process.
Independent risk analysis provided to the portfolio managers.

Credit risk

Our funds only enter into over the counter transactions with high rated institutions. We do not hold client money and as a result have no obligation to pay our clients. Therefore the likelihood of a default in receiving our management and performance fee is very low. Even though we do not consider credit risk affecting us, we still mitigate this by:

Holding large amount of cash in bank accounts with highly rated banks
The funds managed by the company on behalf of the fund company get approval from the fund company directors before any decisions are made, also all trades are executed with highly rated counterparties.
Assess credit risk with counterparties by taking into account current exposures and potential future exposures based on potential market movements.

Market risk

Our management fee and performance fee is received in US dollars and in Euros. As we report in GB sterling there is a danger of suffering from exchange rate losses. This risk is managed by:

Holding money received from performance fees and management fees in USD or Euro bank accounts. Money is transferred into GBP when the rates are favourable.

Liquidity risk

Not being able to meet our financial obligations as they fall due. Even though we think this is highly unlikely we manage the risk by:

Holding money in our money market bank accounts that earn us interest.
Hold money in our deposit accounts that we have access to as required.
Monitor our bank balance on a regular basis

Operational risk

Management and performance fees drop significantly that affects our ability to operate. We believe the key ingredients to this are:

We have adequate working capital to cover expenses, the savings are held in highly rated bank deposits
The recruitment, retention and motivation of high quality professionals.
Continual reviewing and upgrading of internal controls and procedures.

Capital Resources

At November 2019, North Asset Management LLP held £689k of Tier 1 capital in the form of members' capital contributions.

North Asset Management is not required to and does not hold Tier 2 or 3 capital. There are no other items or deductions.

The company's Pillar 1 capital resource requirements is the higher of the base capital requirements and the variable capital resource requirements, as detailed in the table below.

Requirement Details

Base Capital requirement €125,000 (conversion sterling amount £106,583)

The higher of:

Variable capital resource (1) The sum of the credit Risk Capital Requirement and the market

Requirement risk capital requirement; or

(2) The fixed over head requirement

	Pillar 1	ICAAP
	Minimum capital 000's	Pillar 2 Capital 000's


Base Capital	107	-
Credit risk	457	-
Market risk	22	-
	479	-
Fixed overhead requirement	543	-
Pillar 1 total (higher of CR+MR and FOR)	543	543
Pillar 2 total		-
ICAAP capital		543
Current total capital		689
Surplus		146

The Fixed Overhead Requirement of £543k equates to 13 weeks of the Firm's annual expenses excluding variable costs. The total Credit and Market risk is £479k. The LLP has a surplus reserve of 116k and therefore North Asset Management LLP has the required regulatory capital compared with the variable capital resource requirement (and hence, its Pillar 1 capital resource requirement).

In conclusion, North Asset Management is sufficiently capitalised for the risks to which it is exposed.

IMPORTANT INFORMATION: PLEASE READ CAREFULLY BEFORE ACCEPTING THESE TERMS

About North Asset Management LLP

North Asset Management LLP is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”). None of the fund(s) described herein (each, a “Fund”) is a recognised collective investment scheme for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the “Act”). The promotion of the Fund(s) and the distribution of this website in the United Kingdom is accordingly restricted by law. This website is being issued inside and outside the United Kingdom by North Asset Management LLP only to and/or is directed only at persons who are professional clients or eligible counterparties for the purposes of the FCA Handbook rules and guidance. This website is exempt from the scheme promotion restriction (in Section 238 of the Act) on the communication of invitations or inducements to participate in unrecognised collective investment schemes on the grounds that it is being issued only to and/or directed only at such persons.

North Asset Management LLP is also registered with the U.S. Commodity Futures Trading Commission as a commodity pool operator and is a member of the National Futures Association in such capacity. North Asset Management LLP acts as the commodity pool operator of the Fund and has filed a notice of claim of exemption pursuant to CFTC Reg. § 4.7. in connection with pools whose participants are limited to qualified eligible persons, an offering memorandum for these pools is not required to be, and has not been, filed with the Commission. The Commodity Futures Trading Commission does not pass upon the merits of participating in a pool or upon the adequacy or accuracy of an offering memorandum. Consequently, the Commodity Futures Trading Commission has not reviewed or approved this/these offering(s) or any offering memorandum for this/these pool(s).

Information on this Site

The information on this site is issued by North Asset Management International (Guernsey) Limited (The Company), regulated under the Protection of Investor legislation by the Guernsey Financial Services Commission (GFSC). It has expressed its own views and opinions on this website, and these may change without notice. This web site does not constitute an offer or solicitation to sell units in any fund or investment service referred to herein or otherwise any product or service provided by North Asset Management entities and must not be relied upon in connection with any investment decision. It is designed to keep existing investors informed and for professional advisers to use. Applications to invest in any fund referred to on this web site must only be made on the basis of the relevant offer document relating to the specific investment. Products or services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Accordingly, persons are required to inform themselves of and observe any such restrictions. Nothing in this website should be construed as investment, tax, legal or other advice.

Where access to any part of this site is restricted and requires possession of a unique username and password, no other person should attempt to gain access to such part of the site. Neither your username nor password may be transferred to any other person.

Past performance is not necessarily a guide to future performance. The value of investments and the income of any financial instruments mentioned in the website may fall as well as rise, and investors may get back less than the amount originally invested.

Accuracy of Information

The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by The Company to be reliable, but is not guaranteed as to its accuracy or completeness. Such information is provided without obligation on the part of The Company and its associated companies and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at his own risk. Information posted on this site is current only as at the date it is first published and may no longer be true or complete when viewed by you. All information contained on this site may be changed or amended without prior notice although The Company does not undertake to update this site regularly.

No Liability

No representation, warranty or undertaking is given as to the accuracy or completeness of the information contained on this site by The Company or any of its associated companies and no liability is accepted by such persons for the accuracy or completeness of such information. In no event will The Company or any of its associated companies be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the information contained on this site, or on any other hyper-linked site, including, without limitation, any lost profits, business interruption, loss of programmes or data on your equipment, or otherwise, even if The Company is expressly advised of the possibility or likelihood of such damages.
This does not exclude or restrict any duty or liability that North has to its customers under the regulatory system in the United Kingdom. You should be aware that the Internet is not a completely reliable transmission medium. Neither The Company nor any of its associated companies accept any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. This does not exclude or restrict any duty or liability that North has to its customers under the regulatory system in the United Kingdom.

Material Interests

The Company, its associated companies and their directors, officers and/or employees may have holdings in the investment funds referred to on this site and may otherwise be interested in transactions in those funds.

Linked Websites & Third Party Content

This site may link to third party websites or contain information provided by third parties. Neither The Company nor any of its associated companies makes any representation as to the accuracy or completeness of such websites or information, have not and will not review or update such websites or information and caution browsers that any use made of such websites or information is at their own risk. Neither The Company nor any of its associated companies accepts any liability arising out of the information contained on any linked website or information on this site provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that The Company has to its customers under the regulatory system in the United Kingdom.

Copyright, Trademarks and Other Rights

Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by The Company, its licensors or relevant third party content providers. A single copy of webpages published on this website may be made for personal and/or non-commercial reference, any copy of such webpages shall retain all copyright and other proprietary notices contained therein. Such information may not otherwise be reproduced, distributed or transmitted to any other person or incorporated in any way into another database, document or other materials. Nothing on this site should be considered as granting any licence or right under any trademark of The Company or any third party. If you wish to link to content on this site, you are required to request permission from the site administrator by contacting info@north-int.com.

Privacy Policy

The Company and its affiliates will collect your personal data. This privacy policy intends to show you how your personal data is processed, for what purposes this will be done and what rights you have in relation to the personal data that will be collected and used. Personal data is at all times processed in order for North Asset Management to fulfil its obligations.

Personal data

North Asset Management complies with its General Data Protection Regulations (“GDPR”) obligations and ensures that personal data shall be processed lawfully and in a transparent manner in relation to you; that the personal data shall be collected and processed for the purposes stated; that the personal data shall be accurate and at all times kept up to date; that the personal data shall be kept for no longer than is necessary for the purposes for which it is collected; and that the personal data shall be adequately securitised and be protected against loss, unauthorised access or processing, and destruction or damage.

Your personal data will be treated as strictly confidential, and will be shared only with North Asset Management. Your personal data will only be shared with third parties if consent to do so has been given.

Where personal data has not been obtained directly from you, North Asset Management shall provide you with the source from which certain personal data originates, and if applicable whether it came from publicly accessible sources.

Who else may have access to your Personal data?

North Asset Management may need to share personal data with third parties as may be required by law, or in order to fulfil contractual obligations. Where your personal data is shared with third parties, we will ensure that equivalent safeguards are offered in order to protect your personal data.

International transfers of Personal data

Transfers of personal data to countries outside of the EEA will be deemed unlawful unless the recipients of personal data in non-EEA countries offer an equivalent level of data protection to that of EEA countries.

The European Commission has the power to determine on the basis of Article 45 GDPR which countries, by default, offer an adequate level of data protection. This will result in data being able to be transferred to such countries without the need for additional safeguards.

In instances where personal data will be transferred to countries other than those recognised by the European Commission, North Asset Management will ensure that the recipients offer safeguards that are of an equivalent level to those of the EU. This will be achieved through methods listed in Article 46 GDPR.

Data retention

For audit trail purposes, North Asset Management shall hold personal data for a period of at least five years in order for them to comply with their record keeping obligations under the Money Laundering Regulations 2017.

At the end of that period, North Asset Management will be required to delete all personal data relating to you unless a legal requirement requires them to keep the data for a prolonged period of time, or you have expressly consented to their data being held for an extended period of time.

Your personal data rights

You will have the following rights with respect to their personal data:

The right to access personal data
The right to request that personal data regarding them is corrected if it is found to be inaccurate
The right to request that their personal data is erased where it is no longer necessary
The right to withdraw consent to processing at any time, where relevant
The right to restrict processing where there is a dispute in relation to the accuracy or processing of the personal data
The right to request that North Asset Management provides you with their personal data and where possible, transmit that data to another data controller. [applies only where the processing is based on consent or is necessary for the performance of a contract with you and in either case the data controller processes the data by automated means].
The right to object to the processing of personal data [applies only where processing is based on legitimate interest]
The right not to be subject to a decision which is based solely on automated processing, including profiling which produces legal effects concerning them or similarly significant affects them

The type of data collected and purpose for collection

The type of data we collect along with the purpose for collection is listed below:

Personal data type:	Purpose:
Personal information such as gender, name, date of birth and address	To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes.
Contact information (email address and phone number)	In order to send you correspondence in relation to the services provided and to fulfil our regulatory and compliance obligations
Employment information, financial information, relevant education and trading experience	In order to comply with KYC obligations and in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services
Ethnicity, citizenship and social security numbers or national identity and passport numbers	In order to comply with KYC and regulatory trade reporting and other AML obligations
Proof of photo ID, address verification	In order to comply with KYC and regulatory trade reporting and other AML obligations
Unique device number (IP address) and device information including version of web browser you use	When you visit our website, navigate through the pages or fill in any forms, we may collect your unique device number or IP address in order to set up your profile.
Financial sanctions and credit header information	In order to perform our electronic AML screening checks and to comply with other fraud detection policies. This may generate further information on your credit history, criminal convictions or political interests leading to us making decisions based on the results of these checks

Lawful basis for processing

The following state the lawful bases for processing. At least one of the following would need to apply in order for processing to be deemed lawful.

Consent of the data subject;
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Processing is necessary for compliance with a legal obligation;
Processing is necessary to protect the vital interests of a data subject or another person;
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

Contact Details

In order to exercise all right, queries and complaints please contact Charlotte Hervouet (privacy@northasset.com)

Data protection

As of 25th May 2018 the law regarding data protection is changing as the EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/45/EC. The GDPR was designed to harmonise data privacy laws across Europe, to protect and empower all EU citizens’ data privacy and to reshape the way organisations across the region approach data privacy. We have updated our privacy policy to provide you with more information on how we use and protect your personal data, the legal bases we rely on to process your personal data, and how you can exercise your rights to your personal data.

When you visit this website and in the course of our providing services to you, we may collect personal data about you when you are asked to provide data (e.g. name, e-mail address and mailing address) or when you e-mail, phone, or otherwise contact us.

Personal data collected via this website or otherwise may be processed for the purpose of website administration, responding to queries, updating our records and databases, improving the personalisation of our services to you, maintaining contact data about you or a third party (e.g. your company), informing you of our services and products and related information from The Company or affiliates which may be of interest to you. We will not share your personal data with others for marketing purposes.

Additionally, we may appoint third parties to host, maintain, manage, or to provide other services in relation to the website as a result of which your personal data may be accessed and used by these as necessary to fulfil their hosting, maintenance, and other related functions.

You may be able to update some of the data we hold about you or your company yourself. If you are acting on behalf of a third party or supply us with information regarding a third party (such as your employer or a client company), you undertake that you are an authorised representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data.

The data may be disclosed to staff within The Company specifically to process your enquiries or otherwise to administer the website, as well as to those staff involved in the provision of services and products which may be of interest to you.

Cookies

This website uses cookies. A cookie is a piece of data stored on your computer containing information about your use of this website. Cookies are used in order to make the website work, as well as to provide information to us. The following types of cookie may be used:

"Session based" cookie: This is essential for parts of the website to operate and has already been set. It is used to maintain the state of a user’s actions so as not to constantly request the same information from them within a ‘session’.

"Permanent" cookie. This is a permanent cookie which can remember that you have accepted our terms and conditions and/or the use of so you are not asked to log in again for future visits. The website requires that you explicitly give your consent before this cookie is set.

"Analytics" cookie. This, in combination with the session cookie, is used to collect information about how you use our site, such as where you have come to the site from and which website pages you have visited. We use the information to help us improve the website.

You can enable or disable cookies by modifying the settings in your browser; however, you may not be able to use all of the features of the website if cookies are disabled. You can find out how to disable/enable cookies at: www.allaboutcookies.org.

The Company uses reasonable physical, electronic, and procedural measures to safeguard information against loss, theft, unauthorised use, disclosure, or modification. This website when delivered over the internet may however flow over networks without appropriate security measures and as result it is possible it may be accessed and used by unauthorised persons.

Please note that this privacy policy only covers this website and does not regulate the privacy practices of other websites which may be accessible through or linked to this website, or the networks through which this website is delivered to you.

If you have any questions in relation to the information concerning privacy and personal data above, if your personal data changes or if you no longer wish to receive our service, please let us know and we will correct, update or remove your details. This can be done by contacting info@north-int.com.