Trium Regulatory disclosures

Sustainability Related Disclosures in the Financial Services Sector "SFDR"

Updated December 2022

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 November 2022

The Firm has considered the recent updates 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.

Pillar 3 Disclosure

Updated May 2021


Trium Capital LLP (“Trium” or the “Firm”) is a London-based discretionary investment manager to professional clients and unregulated collective investment schemes. The Firm is required to make its Pillar 3 disclosure at least annually, and is made as at the Firm’s Accounting Reference Date. The disclosure may be published on our website or as an appendix to our statutory audited annual accounts. The purpose of this disclosure is to encourage market discipline.

The Capital Requirements Directive (CRD) created a revised regulatory capital framework across Europe covering how much capital financial services firms must retain. In the United Kingdom, rules and guidance are provided in the General Prudential Sourcebook (GENPRU) and the Prudential Sourcebook for Banks, Building Societies and Investments Firms (BIPRU).

The FCA framework consists of three “Pillars”:

Pillar 1 sets out the minimum capital requirements that companies need to retain to meet their credit, market and operational risk;

Pillar 2 requires companies to assess whether their Pillar 1 capital is adequate to meet their risks and is subject to annual review by the FCA;

Pillar 3 requires companies to develop a set of disclosures which will allow market participants to assess key information about its underlying risks, risk management controls and capital position. These disclosures are seen as complimentary to Pillar 1 and Pillar 2.

BIPRU 11 sets out the provisions for Pillar 3 disclosure. The rules provide that companies may omit one or more of the required disclosures if such omission is regarded as immaterial. Information is considered material if its omission or misstatement could change or influence the decision of a user relying on the information. In addition, companies may also omit one or more of the required disclosures where such information is regarded as proprietary or confidential.

The information contained in this document has not been audited, and as such does not constitute any form of financial statement and must not be relied upon.

Firm Overview

Trium is incorporated in the UK and is authorised and regulated by the Financial Conduct Authority (“FCA”) as a Full-Scope Alternative Investment Fund Manager with the Collective Portfolio Management Firm (“CPMI”) designation, which also makes the Firm a BIPRU firm. The Firm is a Solo regulated entity, and as such does not form part of a UK Consolidation Group for FCA prudential requirements.

The Governing Body of Trium has management and oversight responsibility.  It generally meets monthly and is composed of:

Mr Robert Dow – Chairman of Trium – SMF 9

Mr Shenan Dhanani – Co-head of Trium – SMF27 & Certified Person

Mr Donald Pepper – Co-head of Trium – SMF27 & Certified Person

Mr Fredrik Ostlund – Head of Compliance – SMF 16 & 17

Dr Patrick Mang – Chief Operating Officer – SMF27

Mr James Jarvis – Head of Research – SMF27 & Certified Person

Mr Onno de Koster – Head of Risk – Certified Person

Mr Andrew Collins – Head of UCITS – SMF 27 

Mr Richard Hutchinson – Investor Director

The Governing Body is responsible for the entire process of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Governing Body decides Trium’s risk appetite or tolerance for risk and ensures that Trium 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 Governing Body for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of Trium.

Capital Resources and Requirements

Pillar 1

As a limited liability partnership its capital arrangements are as follows: The Firm is a BIPRU Investment Firm without an Investment Firm Consolidation Waiver deducting Material Holdings under (GENPRU 2 Annex 4). Tier 1 Capital comprises of Members’ Capital.

As a CPMI, the Firm is subject to the capital requirements set out in IPRU (INV) Chapter 11 and also BIPRU/GENPRU.  The Firm has the following capital resources:

Members Capital: Tier 1 capital of £4,207,996 (as at 31st December 2020)

Pillar 2

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 which takes the higher of Pillar 1 and 2 as the ICAAP capital requirement.  It has assessed Business Risks by modelling the effect on its capital planning forecasts and assessed Operational Risk by considering if Pillar 2 capital is required taking into account the adequacy of its mitigation.

Risk Management

The Firm has established a risk management process in order to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the Firm’s members.

As risks are identified within the business, appropriate controls are put in place to mitigate these and compliance with them is monitored on a regular basis. The frequency of monitoring in respect of each risk area is determined by the significance of the risk. The Firm does not intend to take any risks with its own capital and ensures that risk taken within the portfolios that it provides investment services to is closely monitored. Details of the Firm’s risk management systems and controls is reported to the Governing Body.

The Firm has a risk management objective to develop systems and controls to mitigate risk to within our risk appetite, as set-out in our ICAAP. Ordinarily, a firm must disclose its risk management objectives and policies for each separate category of risk. On the basis of materiality, we have omitted those items not relevant to the Firm, however, have provided summary information upon the below listed risk items.

Operational Risk

Disruption by COVID-19 virus spread.

During 2020 and 2021 we have had to deal with the COVID-19 pandemic, and the associated measures that governments, service providers, counterparties and investors have put in place to deal with it. While we will undoubtedly suffer some adverse impact from this in the short term, we are confident that we can work through the temporary disruption and that our strategic plan is robust even in the current situation.

The extraordinary circumstances caused by the spread of the COVID-19 virus globally has required the Firm to evoke its business continuity plan and the entire workforce to work remotely from home. The Firm does not consider this to have a material impact to the Firm’s operations and this will not require any additional Pillar 2 amount.

The Firm places strong reliance on the operational procedures and controls that it has in place in order to mitigate risk and seeks to ensure that all personnel are aware of their responsibilities in this respect.

The Firm has identified a number of key operational risks. These relate to disruption of the office facilities, system failures, trade failures and failure of third party service providers. Appropriate policies are in place to mitigate against risks, including appropriate insurance and business continuity plans.

All Operational Risks assessed are within the Firm’s risk appetite.  It is therefore considered that, in normal circumstances, should any of these Operational Risks materialise, the impact and resultant expense would be managed within the business. On this basis, the Firm has not allocated any additional Pillar 2 capital to be allocated to any specific risks.

Credit Risk

The Firm neither holds client money nor assets, nor lends money and does not deal on its own account and is, therefore, not exposed to Credit Risk in its traditional sense.  The Firm’s exposure to Credit Risk is the risk that investment management and advisory fees cannot be collected and the exposure to banks where surplus funds may be deposited.  The Firm’s Credit Risk appetite is low, so the Firm holds surplus funds in cash with banks assigned high credit ratings.  Credit Risk, for the purpose of Pillar 2, is assumed to be that calculated at Pillar 1.

Market Risk

The Firm does not have a Trading Book. The only potential exposures 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 Market Risk appetite is low and, for the purposes of Pillar 2, is assumed to be that calculated at Pillar 1.

Money Laundering Risk

The Firm’s money laundering risk appetite is low.  To manage the risk to this level, the Firm has in place a number of policies and procedures.  Training is also provided annually to all staff.  Where the Fund administrator performs the ongoing money laundering programme, the Firm carries out an annual on-site due diligence visit and, on a sample basis, reviews client files.  With regard to managed accounts, money laundering checks are performed at on-boarding and at least annually thereafter.

Liquidity risk

With respect to its designated investment business (excluding managing AIFs and UCITS), the Firm is subject to the FCA’s Liquidity Rules, set out in BIPRU 12, on a solo basis.  The Firm is classified as a Non-ILAS Firm and, hence, is subject to the Overall Liquidity Adequacy Rule (BIPRU 12.2.1) and considered liquidity systems and controls which include the management of Liquidity Risk via scenario and stress testing of the Firm’s cash flow forecast and the establishment of management actions and contingency funding plans.  

Remuneration Code

Trium Capital LLP (herein “TCL”) has adopted a remuneration policy and procedures that comply with the requirements of chapter 19B (AIFMD activities), chapter 19C (MiFID activities) and chapter 19E (UCITS activities) of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”), to the extent to which they apply. 

TCL has also considered ESMA’s Guidelines on sound remuneration policies. The Firm has also considered all the proportionality elements in line with the FCA Guidance. 

The Firm has assessed the proportionality elements and does not apply the Pay Out Rules. Furthermore, the Firm 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.

Code Staff Remuneration

Senior management and members of staff whose actions have a material impact on the risk profile of TCL are classified as Code Staff. The below table shows the number of Code Staff in each business area. 

Type of Remuneration Code Staff Number of Code Staff

Senior Management: 8

Other Remuneration Code staff*: 12

Total Fixed Remuneration of Code Staff: £2,427,540

Total Variable Remuneration of Code Staff: £125,000

The above remuneration disclosure includes remuneration paid to Code Staff in respect to both their AIFMD and non-AIFMD activities.

*Other remuneration code staff includes staff members whose professional activities can exert material influence on the firm’s risk profile or on an AIF managed by the firm.

As of September 2020

TCL has made no omissions on grounds of data protection. For further information please contact: Email:


What are MiFID and MiFID II?

Prompted by changes in the way financial markets operate, in 2007 the European Commission introduced the Markets in Financial Instruments Directive (MiFID) with the aim of creating a level playing field in the European Economic Area (EEA).

The further MiFID II reforms, effective from January 2018, mean that organised trading of financial instruments had to move to multilateral and regulated trading platforms or be subject to transparency requirements where traded over-the-counter (OTC). Strict transparency rules also ensure that dark trading of shares and other equity instruments which might undermine efficient and fair price formation are no longer allowed.

Best Execution

Under MiFID and MiFID II, with effect from 3 January 2018, 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. Trium must also make disclosures to allow clients to make informed choices between competing dealers by publishing reports (under RTS 28) on execution venue selection.

Trium Capital LLP RTS 28 Disclosure 2021

Trium Best Execution Policy – May 2022