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FCA Disclosure Requirements

FCA disclosure requirements

Previously referred to as Pillar 3 Disclosure Requirements

As at 31 March 2023

1. Introduction

1.1 Purpose and Scope

This document presents the FCA Disclosure Requirements (previously referred to as the Pillar 3 disclosures) for Titan Asset Management Ltd (‘TAM’ or ‘the Firm’) which is authorised and regulated by the Financial Conduct Authority (‘FCA’).

From 1st January 2022, TAM has been classified as an SNI MIFIDPRU investment firm subject to the FCA’s Investment Firm Prudential Regime (IFPR). (Previously it was classified as limited activity €125K investment firm.

These FCA requirements are intended to ensure that TAM’s disclosures are sufficient to allow participants to form an assessment of the Firm’s risk profile and capital resources on a basis comparable with other regulated financial services firms.

1.2 FCA Disclosure Policy

All disclosures, unless otherwise stated, apply as at 31 March 2023 or for the 12 months ending 31 March 2023 in line with the Firm’s financial year end. All disclosures are for TAM on a standalone or company basis.

The disclosures are prepared on an annual basis solely for the purposes of complying with FCA requirements.  The disclosures have not been audited and do not form part of the annual audited financial statements of the Firm. However, they are subject to internal review and verification and are approved by TAM’s Board of Directors. The Firm may consider it appropriate to publish updated disclosures more frequently should a significant change in business or operating environment require this.

TAM’s disclosures are considered to be appropriate to its size and internal organisation, and to the nature, scope and complexity of its activities.

2. Internal Capital Management

The Firm’s capital management strategy is to maintain sufficient capital resources for its size and complexity of business both in the present and in order to facilitate future growth.

TAM monitors its financial adequacy regularly and undertakes a formal internal capital and risk assessment at least annually to identify and manage its principal risks and capital requirements in both business-as-usual and stressed scenarios.

This assessment has been conducted in accordance with the FCA’s Internal Capital Adequacy And Review Assessment (ICARA) requirements and expectations.

In accordance with the overall financial adequacy rule, TAM manages and monitors its principal risks and considers the impact of stressed scenarios on its requirements to determine the amount of own funds and liquid assets, in terms of both amount and quality, it requires to remain financially viable throughout the economic cycle and to address any material potential harm that may result from its ongoing activities. It also considers the amount of own funds and liquid assets it would require if, for whatever reason,

3. Remuneration

The Remuneration Policy is approved by the Board. TAM’s Staff Committee is responsible for all aspects of staffing, including the remuneration of senior staff. The committee ensures that the remuneration arrangements comply with the Remuneration Policy and that staff rewards support the strategic aims of the business, its corporate culture and approach to risk management.

3.1 Policy and Governance

TAM has established a remuneration policy in accordance with the FCA’s Remuneration Code, which is the responsibility of the Board.  The aim of the remuneration policy and governance framework is to establish, implement and maintain remuneration policies, procedures, governance and practices that:

  • are in line with the business strategy, and the sustained, long-term performance of the Firm;
  • neither encourage, nor reward risk taking outside the Board’s appetite; and
  • promote sound and effective risk management.

3.2 Link between Pay and Performance

As an SNI-MIFIDPRU investment firm TAM is obliged to disclose remuneration split between fixed pay and variable, performance-related pay.

  • Fixed pay refers to the employee’s base salary. This forms the core element of pay and reflects the individual’s role and position within the Firm.
  • Variable, performance related pay refers to discretionary bonus payments. The Firm considers both individual and firm level performance as factors to determine bonus payments.

In the financial year to 31-March 2023, remuneration comprised base salary, fixed pay £607k and variable, performance-related pay £116k.

The below table outlines the disclosure requirements:

Staff Category

Total number of Individuals

Total amount of fixed remuneration (£ 000’s)

Total amount of variable remuneration 
(£ 000’s)

Aggregated Remuneration 
(£ 000’s)

All Staff





Titan Sustainable MPS

Below, each factsheet number corresponds to risk level, from 3-8

Titan Sustainable 3

Titan Sustainable 4

Titan Sustainable 5

Titan Sustainable 6

Titan Sustainable 7

Titan Sustainable 8

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Our funds have moved

The previous Titan Asset Management funds have now moved to a new site and trading entity, Titan Investment Solutions. Titan Asset Management now holds the MPS only.

Titan Active MPS

Below, each factsheet number corresponds to risk level, from 3-8

Titan Active MPS 3

Titan Active MPS 4

Titan Active MPS 5

Titan Active MPS 6

Titan Active MPS 7

Titan Active MPS 8



Titan Passive MPS

Below, each factsheet number corresponds to risk level, from 3-8.

Titan Passive MPS 3

Titan Passive MPS 4

Titan Passive MPS 5

Titan Passive MPS 6

Titan Passive MPS 7

Titan Passive MPS 8

Paul Hunt


Paul Hunt is a proven business leader and entrepreneur with over 30 years’ experience and track record of scaling businesses across multiple sectors. Hunt is highly experienced in business turnarounds, strategic planning and creating a positive people culture geared for success.

David Chandler

Senior Portfolio Analyst

David is responsible for providing operational support to the fund managers. David has passed the CFA UK IMC and graduated in 2018 with a degree in Economics and Business Management from the University of Sheffield.

James Peel, CFA

Portfolio Manager – ESG

James is a Portfolio Manager at Titan Asset Management and is responsible for Titan’s approach to sustainable investing. He previously worked as a researcher at the British Chamber of Commerce in Taipei. James graduated in 2018 from the University of St Andrews, where he studied economics. He is a CFA charter holder and has passed the CFA UK Investment Management Certificate (IMC), the CFA UK Certificate in ESG Investing and the CFA UK Certificate in Climate and Investing (CCI). He was also included in Citywire Wealth Manager’s 30 Under 30 in 2023.

Jonah Levy, CFA

Portfolio Manager – Physicals

When not collecting various minerals and mining memorabilia, Jonah can be found managing the physical allocations at Titan Asset Management. Prior to Titan he worked at Tavistock Wealth for 3 years, having previously gained experience in Holland at an oil brokerage, and in London at an energy trading house. Jonah is a CFA charter holder, having graduated from St. Andrews University with an MA in Management and Economics.

Alex Livingstone, CFA

Head of Trading – FX & ETFs

Alex is responsible for the ETF trading and FX strategy at Titan Asset Management and has executed over £5 billion of trades during his prior 4 years at Tavistock Wealth. Alex also assists in the wider portfolio management of the CIP specialising in technical analysis and risk management. He is a CFA charter holder and holds an BSc in Retailing, Marketing and Management from Loughborough University.

Sekar Indran, CFA

Senior Portfolio Manager – Equities

Sekar is responsible for managing the team’s equity investments. He helped expand the investment proposition over five years at Tavistock Wealth and continues this role at Titan Asset Management. Sekar has prior financial services experience at Barclays and Allianz. He is a CFA charter holder and holds a BSc degree in Industrial Economics from the University of Nottingham.

John Leiper, MSc, CFA, FDP, CFTe

Chief Investment Officer

John Leiper is the Chief Investment Officer of Titan Asset Management and carries direct responsibility for all investments in the Centralised Investment Proposition (CIP) at the firm. John has 15 years’ experience in financial markets having previously worked in a variety of roles at RBS, Morgan Stanley, Credit Suisse and Tavistock Wealth. John Leiper is a CFA and FDP charter holder and a member of the Society of Technical Analysts. He holds a BSc degree in Economics from Warwick University and an MSc degree in Economic History from the London School of Economics.

Damian Sharp

Chief Operating Officer

Damian’s financial services career spans over 30 years, the greater part spent at Pantheon Financial Management Ltd. As Managing Director Damian steered the group through its RDR rationalisation to its ultimate sale to Ascot Lloyd.

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