Sustainability Related Disclosures in the Financial Services Sector "SFDR"
Updated June 2023
Trium Capital LLP SFDR Disclosure
Trium Capital LLP ESG Due Diligence Policy
Fund specific SFDR disclosures can be found on our strategies page here.
No Consideration of Sustainability Adverse Impacts
As a smaller investment firm (with fewer than 500 employees), Trium measures the Principal Adverse Impact of certain funds, but does not quantify the entire firm’s impact. Trium takes into account the adverse impacts of sustainability risks to the extent that such risks form an intrinsic part of other risks, such as market risk and operational risk. However, Trium does not consider this to amount to considering the adverse impacts on sustainability factors of investment decisions as set out under the SFDR.
Where any of our Funds promotes environmental or social characteristics or has ‘sustainable investment’ as an objective, we will ensure that sustainability risks in relation to the Fund are considered. For the Funds which do consider, address and mitigate PAIs we use MSCI to measure these.
Where a Fund does not promote environmental or social characteristics or have ‘sustainable investment’ as an objective, we consider that the best interests of the Fund’s investors are served by following the investment objectives and policies of the Fund.
Trium plan to review its approach to the consideration and management of principal adverse impacts on an ongoing basis, building on its existing engagement and responsible investing practices shared with its underlying managers.
Stewardship Code
Updated June 2023
The Firm has considered updates made to the Stewardship Code in January 2020 and the Shareholder Rights Directive II that took effect in June 2019.
The Financial Conduct Authority and the Financial Reporting Council have acknowledged that certain aspects of the Stewardship Code are not directly relevant to all managers.
The Firm is a fund manager to a number of alternative and regulated funds and strategies and it pursues an investment strategy to which the aims of the Stewardship Code are not fully relevant.
While the Firm supports the general objectives that underlie the Code and the Directive, the provisions of the Code are not relevant to the type of activity currently undertaken by the Firm because it does not adapt an overall active approach to shareholder participation.
In ESG related matters the Firm is committed to creating real ESG impact in accordance with the principles of UNPRI.
The Firm’s Executive Board will continue to review the Code’s applicability.
Shareholders Rights Directive II
Updated June 2023
The Directive took effect in June 2019 and falls under COBS 2.2B in the UK. It applies, broadly, to Portfolio Managers, UCITS Management Companies and Full Scope AIFMs. The Directive requires firms that invest in shares that trade on an UK/EU regulated market, in addition to ‘comparable’ markets outside the UK/EU, to develop and publicly disclose an engagement policy or publicly disclose a clear and reasoned explanation of why it has chosen not to comply with this requirement.
Given the similarity with the UK Stewardship Code, which is at present not deemed relevant to the type of activity undertaken by the Firm, it has been decided not to comply with the Directive at the current time. However, this position is subject to annual review, in conjunction with the Stewardship Code, and any change to the current strategy of the Firm will be taken into account.
MIFIDPRU Disclosure
Updated June 2023
Trium Capital LLP (herein “TCL”) has adopted a remuneration policy and procedures that comply with the requirements of chapter 19B (AIFMD activities) and chapter 19G (MiFID activities) of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”), to the extent to which they apply.
Under MIFIDPRU 8, as a Small and Non-Interconnected (“SNI”) MiFID Investment Firm with no Additional Tier 1 Capital, TCL is required to provide an annual disclosure about its remuneration arrangements. The regulatory aim of the disclosures is to improve market discipline. This disclosure is in respect of the period ending 31 December 2022.
Summary of the firm's approach to remuneration for all staff
TCL’s overarching approach to remuneration is designed to encourage the alignment of the risks taken by the Firm’s staff, its clients, mandates, and the Firm itself.
When TCL assesses individual performance to determine the amount of variable remuneration, it will consider both financial and non-financial criteria. As conduct is crucial to the compliance culture of the Firm, if an employee shows poor conduct, this may override their performance in financial areas. Conduct is therefore the biggest metric within non-financial considerations.
TCL has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business, that it does not need to appoint a separate remuneration committee. Instead, the Firm’s Governing Body sets, and oversees compliance with, the Firm’s remuneration policy including reviewing the terms of the policy at least annually.
Key characteristics of its remuneration policies
TCL distinguishes between criteria for setting fixed and variable remuneration and ensures that remuneration is clearly categorised as one or the other.
In line with the FCA’s guidance, the Firm considers the difference between the two as follows:
- Fixed remuneration primarily reflects a staff member’s professional experience and organisational responsibility as set out in the staff member’s job description and terms of employment. It should be pre-determined, non-discretionary and not dependent on performance.
- Variable remuneration should be based on performance and should reflect long-term performance, as well as performance above and beyond their job description. It includes discretionary pension benefits and carried interest.
The firm assesses performance across the firm, business units and individuals considering the following criteria:
- Financial metrics including contribution to revenue/ sales growth as well as cost reduction; and
- Non-financial metrics including: the building and maintenance of positive customer relationships and outcomes; alignment with our strategy or values, for example by displaying leadership, teamwork or creativity; adhering to our compliance policies & procedures; and meeting other non-financial targets relating to environmental, social and governance factors and diversity and inclusion.
In assessing performance, the above factors are considered at firm, business unit and individual level as applicable. Overall, greater weight is placed on non-financial metrics when assessing performance. All variable remuneration is adjusted in line with capital and liquidity requirements.
Quantitative information for the financial year ended 31st December 2022:
Total Fixed Remuneration for all staff: £4,148,000
Total Variable Remuneration for all staff: £516,000
TCL has made no omissions on grounds of data protection.
MiFID II
MiFID II after Brexit
MiFID II continues to apply in the UK, post the UK’s exit from the EU, under the UK MiFID framework.
Best Execution
Under MiFID and MiFID II, Trium Capital LLP is required to take sufficient steps to obtain the best possible result for its clients when executing orders on their behalf. In order to detail our approach, we include below the Trium Best Execution Policy that complies with this MiFID II obligation.
MiFID II stipulates that we act in the best interests of clients when providing execution services and maintain monitoring arrangements that demonstrate compliance.
