Privacy, Terms and Conditions
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• In addition to the information herein contained, one investor considering the products and services analysed should carry out his own due diligence, should carefully study the account forms, disclosure documents and/or risk disclosure statements which are provided directly by the asset management companies, banking or brokerage counterparties.
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• The Terms and Conditions of this website are without prejudice to any contractual terms you may enter into with us, which will take precedence over the Terms and Conditions of this website
• Any use of this website shall be subject to UK law.
- The material in the website is directed solely at Eligible Counterparties and Professional clients (as defined by the rules of the Financial Conduct Authority). The material is not directed at, may not be suitable for and should not be relied on by retail clients. By accessing the relevant pages you acknowledge that you are not a retail client.
- Investments and foreign exchange can go up as well as down and involve the risk of loss. Past performance will not necessarily be repeated in the future.
- The content of the pages of this website is for your general information and use only. It is subject to change without notice. The information contained in this website is believed to be reliable but no warranty or representation, expressed or implied, is given as to their accuracy or completeness
- Your use of any information or materials on this website is entirely at your own risk, for which JCI Capital Limited shall not be liable. None of the services or investments referred to in this website is available to persons resident in any country where the provision of such services or investments would be contrary to local law or regulation. If you choose to use this website it is your sole responsibility to ensure you comply with any local laws and regulations and to seek legal advice if you are uncertain as to what these are.
- Unless indicated otherwise, all information and images are the property of JCI Capital Limited. By using the pages of this website, and/or by reading the material within it, you agree that you will use the information only for your internal business purposes and that you will not otherwise download copy, transmit or distribute in any way any of this material in whole or in part. All intellectual and other property information shall remain the property of JCI Capital Limited and no rights in it shall be transferred to you.
- Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence. Any dispute arising from the use of this website is governed by English law.
- From time to time this website may also include links to other websites, however these links are provided for your convenience to provide further information. JCI Capital Limited has no responsibility for the content of the linked website(s).
- Trading futures, options or contracts for differences involves the risk of loss. You may lose more than the amount originally invested and, in respect of these products as well as other products traded on margin, you may have to pay more later. You should not invest in such products unless you are satisfied that they are suitable for you. It could be some time before you see a return on your investment. Changes in the rates of exchange between currencies may cause your investment/the income to go down or up. If you have any doubts as to the suitability of these investments you should seek financial advice.
JCI Capital Limited is authorised and regulated by the Financial Conduct Authority (FRN: 536817).
Registered Office: 44 Davies Street, 1st floor Brookfield House, London W1K 5JA. Registered in England & Wales (Company Number 7372983); T: +44 (0)207 297 6700; VAT No. GB 114182449
Scope of the Best Execution Obligation
JCI Capital Limited (the Firm) must take all sufficient steps to obtain the best possible result when executing, placing or transmitting client orders on behalf of a client [or when dealing on a request for quote basis (“RFQ”)], taking into account the execution factors (as defined below) (“best execution”).
The regulatory duty to provide best execution extends to Professional Clients only when their order or RFQ relates to a MiFID II financial instrument and the Firm is executing on behalf of such clients.
The Firm will not owe best execution where it has correctly categorised a client as an Eligible Counterparty (generally or for a particular type of product or transaction). The Firm is not permitted to deal with Retail Clients and therefore its best execution arrangements are not applicable to such persons.
The Firm will apply best execution in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of MiFID II financial instruments.
The Firm will provide best execution where it determines that the client is relying on the Firm to protect its best interests in relation to the pricing or other aspects of an order placed with the Firm (“legitimate reliance”). The Firm will assess legitimate reliance having regard to factors such as which party initiates the transaction, questions of market practice and the existence of a convention to “shop around”, the relative levels of price transparency within a market and the information provided by the Firm and any agreement reached. If the Firm determines that the client is not legitimately relying on the Firm then best execution will not apply.
In so far as the Firm receives specific instructions from a client as to how to execute a transaction, best execution will not apply as the Firm will instead follow those instructions to the extent possible. In such circumstances, the Firm will be deemed to have satisfied its best execution obligation, but only in respect of that part or aspect of the order to which the client instructions relate. To the extent that there are other parts or aspects of the order for which the Firm has not received specific instructions from the client, the Firm will apply its best execution arrangements as detailed in this Summary.
The Firm’s commitment to obtain the best possible result for its clients does not mean that it owes any fiduciary or other responsibilities over and above the specific regulatory obligations placed upon the Firm or as may be otherwise contracted between the Firm and its clients through terms of business or otherwise.
In complying with its regulatory obligation to obtain the best possible result when executing, placing or transmitting client orders on behalf of a client, the Firm will take into account the following factors when determining its execution arrangements (the “execution factors”):
- Price (price at which the financial instrument is executed);
- Speed (time it takes to execute a client order);
- Likelihood of execution and settlement;
- Size of the Order (in particular, how the size of the order affects the price of execution);
- Costs (for example, execution and settlement fees);
- Nature of the transaction (how the particular characteristics of the order may affect how best execution is achieved); and
- Any other consideration relevant to the efficient execution of the order, including whether it is executed on a regulated market, multilateral trading facility or organised trading facility (each a “trading venue”) or over-the-counter (“OTC”).
The variety of execution factors that are taken into account and their order of relative priority will be determined by the Firm on a transaction by transaction basis.
It is the general policy of the Firm that the most important execution factor for its Professional Clients is the price at which the relevant financial instrument is executed. However, there may be circumstances where the primary execution factors vary and another factor, such as the likelihood of execution and settlement or the time it takes to execute a client order, becomes the most important execution factor and is given precedence over price.
When executing a client order, the Firm will take into account the following criteria for determining the relative importance of the execution factors (the “execution criteria”):
- The characteristics of the client, including the categorisation of the client which will always be professional;
- The characteristics of the client order;
- The characteristics of the financial instruments that are the subject of that order; and
- The characteristics of the execution venues to which that order can be directed.
The Firm will apply the execution factors and criteria in a number of different ways, depending on the type of instrument involved, its liquidity and the role played by the Firm.
For fixed income instruments that are considered liquid, the Firm will seek best price on the market and will execute the trade with the client at the best price. In relation to fixed income instruments that are considered to be less liquid the firm may consider an OTC transaction to be the most appropriate form of execution or may also look to source niche counterparties. [In all cases, if the firm considers that after due enquiry it is able to offer a better price than is available at the relevant time on the market, it may execute the trade with the client.]
Having regard to the execution factors and criteria, the Firm may use one or more of the following venue types when executing client orders:
- regulated markets
- organised trading facilities or multilateral trading facilities
- other exchanges that are not regulated markets
- systematic internalisers
- the Firm’s trading desks’ principal positions
The Firm will not discriminate between execution venues when choosing an execution venue on behalf of a client. However, it is the general policy of the Firm that it will seek to execute orders directly with regulated markets through direct market arrangements. A list of Direct Market Access providers that may be used by the Firm is set out towards the end of this Summary.
Notwithstanding the above, and taking into account the execution factors and criteria, the Firm may use other execution venues when executing client orders.
Execution outside of a trading venue
The Firm may execute all or part of a client order outside of a trading venue. The Firm is required to obtain its clients’ consent in order to do so, which consent has been outlined in the terms of business.
The FCA’s rules require that where you have given the Firm a limit order for shares admitted to trading on a regulated market or MTF that is not immediately executed under prevailing market conditions, the Firm must make that unfulfilled limit order public immediately unless you expressly instruct us otherwise. We have framed our terms of business such that our clients are presumed to have instructed us not to make their unfulfilled limit orders public unless they tell us otherwise, as we believe the Firm’s ability to exercise discretion as to when and how unfulfilled limit orders are made public helps it to achieve the best possible result for its clients.
Order Handling and Aggregation
When carrying out client orders, the Firm is required to:
- ensure that orders executed on behalf of clients are promptly and accurately recorded and allocated; and
- carry out otherwise comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise (COBS 11.3.2AEU).
Aggregation and allocation of client orders
The Firm may carry out a client order (i.e. execute an order on behalf of a client or transmit client orders to other entities for execution) or a transaction for own account in aggregation with another client order (i.e. combine a client order or transaction for own account with another client order) provided it is satisfied that:
- it is unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any client whose order is to be aggregated;
- it is disclosed to each client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order; and
Where the Firm aggregates a client order with a transaction for own account and the aggregated order is partially executed, it will allocate the related trades to the client in priority to the firm, (COBS 11.3.10AEU).
Most corporate finance activity, such as underwriting and advisory services, does not involve the Firm executing, placing or transmitting client orders on behalf of a client, in which best execution does not apply.
However, depending upon the nature of the engagement, the Firm may execute, place or transmit client orders on behalf of a client in a corporate finance context, for example where the Firm is engaged to:
- build a strategic stake or acquire a target company;
- facilitate a share buy-back; or
- sell a significant shareholding.
in which case best execution will apply.
Execution factors in a corporate finance context
Most corporate finance transactions are unique. The means that the Firm’s general policy of identifying price as the most important execution factor is less likely to apply and other execution factors, such as likelihood of execution and settlement and speed of execution are likely to be the most important execution factors, depending on the particular characteristics and context of each transaction.
Execution venues in a corporate finance context
Corporate finance transactions tend to involve the acquisition or sale of larger blocks of shares and often involve additional complexities which limit the choice of execution venues available to the Firm, such as the need for secrecy, the requirements of the market abuse regime (or other appropriate standards of market conduct) in the particular circumstances and, where/if relevant, compliance with the Takeover Code or similar rules. Moreover, there is no formalised market or settlement infrastructure for OTC transactions. The Firm’s choice of execution venue may therefore be further limited where there is only one venue where it can execute a transaction.
When selling shares or debt, the general policy of the Firm is to choose to build a book or negotiate a private placement with identified investors (or the client may expressly instruct the Firm to do so). In these circumstances, the third party investment firms involved (trading proprietary or agency positions) will constitute the execution venue. Alternatively, the Firm may choose to use the block trade facility of an investment exchange.
The Firm’s clients will be deemed to have provided implied consent to the content outlined in this Summary when they instruct the Firm to act on their behalf in relation to an order.
Monitoring and Review
At least annually, the Firm will review its best execution arrangements and policy to ensure their ongoing effectiveness. The review will include consideration of whether the Firm could obtain better results for its clients if it was to:
- include additional or different execution venues or brokers;
- assign a different relative importance to the execution factors;
- modify the process by which execution venues or brokers are selected;
- modify any other aspects of its best execution arrangements and policy.
The Firm will also review its execution arrangements and policy whenever a material change occurs that could affect its ability to obtain the best possible result, on a consistent basis, for its clients (for example, a significant market event or material change to the Firm’s business model that could impact the parameters of the Firm’s best execution arrangements such as the execution factors specified above). Clients will be notified of any material changes to the Firm’s order execution arrangements or policy through publication of an updated version of this Summary [on the Firm’s website].
Annual Publication of Top 5 Execution Venues and Brokers
Each year the Firm will publish [on its website] data on its top execution venues and brokers used to obtain the best result for its clients, in respect of each class of financial instruments. Such data will include:
the top five execution venues in terms of trading volumes (the number of financial instruments traded times price for each transaction, cumulated for the year), where the Firm executed client orders in the preceding year, together with information on the quality of execution obtained; and
the top five brokers in terms of trading volumes to which the Firm transmitted or placed client orders for execution in the preceding year, and information on the quality of execution obtained.
List of DMA providers
Market Hub (Banca IMI SpA)
The Pillar 3 disclosure of JCI Capital Limited (“the Firm”) is set out below as required by the Capital Requirement Regulation Art. 431et seq. This is a requirement, which stems from Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on Prudential requirements for Credit Institutions and Investment Firms and amending Regulation (EU) No 648/2012 (“Capital Requirement Regulation”, “CRR”) which represented the European Union’s application of the Basel Capital Accord. The regulatory aim of the disclosures is to improve market discipline.
The Firm is a €730k full scope IFPRU investment firm and it is authorised and regulated by the FCA (registration number 536817 and registered since 19 April 2011.
The Firm will be making Pillar 3 disclosures at least annually. The disclosures will be as at the Accounting Reference Date (“ARD”).
Media and Location
The document will be uploaded on the Firm website.
The information contained in this document has not been audited by the Firm’s external auditors, as this is not a requirement, and does not constitute any form of financial statement and must not be relied upon in making any judgement on the Firm.
The Firm regards information as material in disclosures if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions. If the Firm deems a certain disclosure to be immaterial, it may be omitted from this Statement.
The Firm regards information as proprietary if sharing that information with the public would undermine its competitive position. Proprietary information may include information on products or systems, which, if shared with competitors, would render the Firm’s investments therein less valuable. Further, the Firm must regard information as confidential if there are obligations to customers or other counterparty relationships binding the Firm to confidentiality. In the event that any such information is omitted, we shall disclose such and explain the grounds why it has not been disclosed.
The CRR, to which the Firm is subject to, has three pillars; Pillar 1 deals with minimum capital requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by a firm and the Supervisory Review and Evaluation Process through which the Firm and Regulator satisfy themselves on the adequacy of capital held by the Firm in relation to the risks it faces and; Pillar 3 which deals with public disclosure of risk management policies, capital resources and capital requirements.
The regulatory aim of the disclosure is to improve market discipline.
The Firm is an IFPRU broker, investment management firm and principal trader. It acts as agent and principal. The Firm’s greatest risks have been identified as business and operational risk. The Firm is required to disclose its risk management objectives and policies for each separate category of risk which include the strategies and processes to manage those risks; the structure and organisation of the relevant risk management function or other appropriate arrangement; the scope and nature of risk reporting and measurement systems; and the policies for hedging and mitigating risk, and the strategies and processes for monitoring the continuing effectiveness of hedges and mitigants.
The Company does not extend credit to third parties. The market risk system monitors suitability risk in relation to advisory and managed client mandates. All managed customers have their own settlement and custody arrangements and he Company only executes transactions on their behalf.
The Firm has assessed business and operational risks in its ICAAP and set out appropriate actions to manage them.
The Firm does not outsource any major business related operational function. Its IT infrastructure and IT support services are outsourced. In addition, the Firm relies on specialist external advisers for a number of matters, with a view to minimising operational risk. The Firm has an operational risk framework (described below) in place to mitigate operational risk.
Market Risk exposure has been assessed by the Firm Market risk arises principally through proprietary trading activity. The Firm has in place risk management procedures including a designated limit per trader which, when amalgamated, equals the total Firm limit. The Firm’s risk allocation and appetite is discussed at board meetings (or earlier as required). Periodic/daily reporting of all positions against the trading limits are communicated to the Chief Financial Officer.
The Firm’s Reporting Currency is GBP and all foreign currency assets are regularly converted into GBP on the basis of its needs.
Background to the Firm
The Firm is incorporated in the UK and is authorised and regulated by the FCA as an IFPRU Firm. This is due to the firm being authorised to deal as principal, and place instruments on a non-firm commitment basis and on a commitment basis and gives the Firm the category of an IFPRU 730K firm.
The ICAAP covers the Firm only. The Firm is a Solo regulated entity.
Disclosure: Risk Management Objectives and Policies
Risk Management Objective
The Firm has a risk management objective to develop systems and controls to mitigate risk to within its risk appetite.
The Board of Directors is the Governing Body of the Firm and has the oversight responsibility. It meets monthly and as at 31 December 2017 it was composed of:
- Roberto Colapinto
- Flavio De Paulis
- Daniele Pinci
The Board of Directors has oversight of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Governing Body decides the Firm’s risk appetite or tolerance for risk and ensures that the Firm has implemented an effective, ongoing process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed. Senior Management is accountable to the Board of Directors for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of the Firm.
Risks are managed as set out below.
The Firm undertakes robust risk identification and scoring exercises across the Firm, this Risk Appetite Statement translates into the acceptance of risks rated L or below. Any risk rated M or H is deemed to be unacceptable to the Company, deemed to be outside of the Firm’s Risk Appetite and must be addressed as a priority to ensure that it is able to receive a L rating. Any risk rated M must be addressed as a priority to ensure that it is able to receive an L rating or have Pillar 2 capital allocated.
As a €730k full scope IFPRU investment firm, the Firm has a Trading Book in respect of its intra-day bond positions. In addition there are Non-Trading Book Exposures, i.e. to Foreign Currency held on deposit and assets or liabilities held in Foreign Currency, such as Debtors, on the Firm’s Balance Sheet. The Firm’s appetite for Market Risk is low (no overnight positions are held) and, for the purposes of Pillar 2, is assumed to be that calculated at Pillar 1.
As a €730k full scope IFPRU investment firm, the Firm acts as principal, manages investments and neither holds client money nor assets nor lends money, and is, therefore, not exposed to Credit Risk in its traditional sense. The Firm’s exposure to Credit Risk is the risk of failed trades, that commissions cannot be collected and the exposure to banks where revenue is deposited. The Firm’s Credit Risk Appetite is low so the Firm only deals with regulated market makers and holds all cash with banks assigned high credit ratings. Credit Risk, for the purpose of Pillar 2, is assumed to be that calculated at Pillar 1.
Disclosures concerning Board of Directors
- Number of directorships (excluding those held in respect of FIRM) held by members of Board of Directors as at 31 December 2017
The number of outside directorships held by members of the Board of Directors is as follows:
- Roberto Colapinto – three
- Responsibility and Information Flow on risk to Board of Directors
As at 31 December 2017, The Board of Directors has oversight of the Firm’s risk management, with monthly reporting to the Board of Directors.
Disclosure: Own Funds
The Firm is an IFRU Full Scope Firm. Tier 1 Capital comprises of share capital and audited reserves.
|Tier 1 Capital and Total Capital||
Disclosure: Capital Requirements
The Firm has adopted the “Structured” approach to the calculation of its Pillar 2 Minimum Capital Requirement as outlined in the Committee of European Banking Supervisors Paper, 27 March 2006.
The ICAAP assessment is reviewed by the Board of Directors and amended where necessary, on a yearly basis or when a material change to the business occurs. The Credit and Risk Committee reviews the ICAAP document to the Governing Body of the Firm which reviews and endorses the risk management objective each quarter or when a material change to the business occurs at the same time as reviewing and signing off the ICAAP document.
Internal Ratings Based Approach
The Firm does not adopt the Internal Ratings Based Approach.
Disclosure: Exposure to Counterparty Credit Risk
Counterparty credit risk is the risk that the counterparty to a transaction could default before the final settlement of the transaction’s cash flows.
For derivatives, counterparty credit risk arises primarily from unsettled security, commodity and foreign exchange transactions with a contractual settlement or delivery lag that is longer than the lesser of the market standard for the particular instrument or five business days (long settlement transactions).
The process for approving a counterparty’s risk exposure limit is guided by core credit policies, procedure and standards; experience and judgement of credit risk professional and the amount of credit risk. Credit risk is monitored on a daily basis versus limits and any issues are escalated to risk and business management as appropriate.
The firms does not engage in any credit derivative trading, hence no collateral or credit reserve are required. Furthermore, as the firm trades only intraday with no overnight exposures there is no wrong-way risk exposures.
All credit exposures are measured the mark-to-market method.
The firm does not have any credit derivative hedge.
Disclosure: Capital buffers
This disclosure is not in force as at 31 December 2017.
Disclosure: Indicators of Global Systemic Importance
This disclosure is not applicable as we are not a Global Systemic Important Institution
Disclosure: Credit Risk Adjustments
Credit risk adjustments to exposure to trading counterparties are reviewed on a monthly basis by reference to the age of the exposure and the rating of the counterparty together with the company’s internal assessment of the counterparty (which is calculated by public domain information).
Any asset which is over 6 months past due is considered fully impaired unless there are mitigating circumstances. However, no such balances existed at the balance sheet dated and the company considers that there is no assets where such a provision is needed for amounts past due for a shorter period or for any other probable loss except for small non-trading balances.
Counterparties are generally the within the EU and US and large established institutions with significant market presence.
Disclosure: Unencumbered Assets
All assets are unencumbered
Disclosure: Use of ECAIs
Disclosure: Exposure to Market Risk
The Firm has adopted the Trading Book and Non Trading Book (Articles 325-377) approach to its Pillar 1 capital calculation. Market risk exposure is calculated as follows.
Article 92(3) b requirements for trading book business
|Item||Own fund Requirement|
|Large exposures which exceed limits in Arts 395-401||nil|
Article 92(3) c requirements
|Item||Own fund Requirement|
|Foreign Exchange Risk||20,00|
The Firm does not hold securitisation positions and therefore there is no Specific Interest Rate Risk to disclose,
Disclosure: Operational Risk
The Firm uses the Basic Indicator Approach as set out in Articles 315-316 to calculate its Operational Risk Own Funds Requirement.
|Item||Own fund Requirement|
Disclosure: Exposures in Equities not Included in the Trading Book
This disclosure is not required as the Firm does not have a Non-Trading Book Exposure to Equities.
Disclosure: Exposure to Interest Rate Risk on Positions not Included in the Trading Book
Although the Firm has substantial cash balances on its Balance Sheet, there is currently no significant exposure to Interest Rate fluctuations.
Disclosure: Exposure to Securitization Positions
This disclosure is not required as the Firm does not Securitise its assets.
Disclosure: Remuneration Policy
The Firm is a Remuneration Code Proportionality Level 3 Firm and has applied the rules appropriate to its Proportionality Level. The Governing Body is responsible for the Firm’s remuneration policy and generally meets on monthly basis. All variable remuneration is adjusted in line with capital and liquidity requirements.
The Firms classifies senior managers and those staff whose professional activities have a material impact on the Firm’s activities as Remuneration Code Staff. The Firm has not paid a severance payment to a Remuneration Code Staff. The total number of Remuneration Code Staff is 16. The aggregate remuneration paid the Remuneration Code Staff during the previous 12 months was £1,5k. No remuneration was awarded in the form of shares or share linked instruments or similar type of instruments to Remuneration Code Staff.
Total remuneration during the financial year to 31 December 2017 was £1,5K. No member of staff has been awarded a total remuneration of €1m or more.
| Aggregate Quantitative Remuneration by Senior Management and other Remuneration Code Staff