Important Information

Important Information

This important information should be read carefully as it contains the terms and conditions of this website and also important regulatory information and risk warnings.

Site Information

We take all reasonable care to ensure information contained on the pages of this site is accurate however we give no guarantee to the accuracy and completeness of the information or to any errors and omissions that may occur due to circumstances beyond our control. We reserve the right to change the content of the pages of this site without prior notice.

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Firm Information

Tcam Asset Management Limited is authorised and regulated by the Financial Conduct Authority, reference number 550227. Registered office Level 1, Princes Exchange, 1 Earl Grey Street, Edinburgh, EH3 9BN.

VT Tcam Growth Fund, VT Tcam Income Fund, VT Tcam Absolute Return Fund and VT Strategic Value are the available funds of VT Tcam Investment Funds an Investment Company with Variable Capital (ICVC) authorised by the FCA, reference number 190667. Tcam Asset Management Limited is the Investment Manager for the VT Tcam Investment Funds. Valu-Trac Investment Management Limited is the Authorised Corporate Director for the funds.

Risk Warnings

Information provided on this site and any opinions expressed are for general use and not personal to your circumstances, nor are they intended to provide specific legal or financial advice. No information on this site should be viewed as an offer or recommendation to dispose of or acquire any investment or undertake any specific transaction. If you are unsure as to the suitability of any investment you should contact a financial planner who will provide tailored advice.

All information provided is based on our understanding of current legislation which is subject to change.

You should remember that the value of investments and the income derived from them may fall as well as rise and you may not get back the full amount you invest. Past performance is not a guide to future performance. Taxation is based on individual circumstances and is subject to change.

Non-mainstream investments

Certain investments are deemed to be non-mainstream collective investments (these include unregulated collective investment schemes, some special purpose vehicles and other complex investments) and are not subject to the same regulatory protections as other investments. These investments are not available to retail clients.

Conflicts of Interest Policy Summary

Tcam Asset Management Limited's policy is to avoid any conflicts of interest between itself and its associates on one hand and its clients on the other. In the event of such a conflict arising, it will always put the interests of the client first.

If there is a conflict between two or more clients, the company will act in the most fair and equitable way it can. For example, client orders for the same security will be dealt with in the order they are received, except in exceptional circumstances, such as when an aggregated order may be in the best interest of clients.

If you would like to see a copy of the full Conflicts of Interest Policy please click here.

Intellectual Property

All rights to use the content of this site belong to the Tcam Asset Management Limited and any unauthorised use, including transmission, extraction, modification and distribution is strictly prohibited. You may not reproduce part or all of the content of this site in any form unless it is for personal use.

Pillar 3 Disclosure

Tcam Asset Management as at 31st March 2016


The Pillar 3 disclosure of Tcam Asset Management Limited (“the Company”) is set out below as required by the European Union’s Capital Requirements Regulations (“CRR”). This follows the introduction of the Capital Requirements Directive (“CRD”) which represents the European Union’s application of the Basel Capital Accord. The regulatory aim of the disclosures is to improve market discipline.


The Company will be making Pillar 3 disclosures annually.

Media and Location

The disclosure will be published on our website.


These disclosures explain how the Board have calculated certain capital requirements and provide information about risk management generally. The information contained in this document has not been audited by the Company’s external auditors and does not constitute any form of financial statement and must not be relied upon in making any judgement on the Company.


The Company 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 Company deems a certain disclosure to be immaterial, it may be omitted from this Statement. Some of the disclosures required under the CRR are deemed immaterial or are omitted since they are not relevant to the Company’s business.


The Company 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 Company’s investments therein less valuable. Further, the Company must regard information as confidential if there are obligations to clients or other counterparty relationships binding the Company 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.
We have made no omissions on the grounds that it is proprietary or confidential.

Company Background

The Company is incorporated in the UK and is authorised and regulated by the FCA as an Investment Management company. The Company’s activities give it the IFPRU categorisation of a “limited licence 125K investment firm”.

1. Risk management objectives and policies

Risk Management Objective

The Company’s general risk management objective is to develop governance structures and systems and controls to mitigate risk to a level that does not require the allocation of material Pillar 2 Capital.

Governance Framework

The Board of Tcam Asset Management Group Limited is the governing body ultimately responsible for the risk management regime within the Company. The Board has authorised the Risk and Compliance Committee (comprised of Non-Executive Directors and the Joint Chief Executive Officers) to identify the risks which are deemed appropriate to accept and those which are unacceptable and should be eliminated or mitigated. The committee exercises its remit through quarterly review of reports which cover, among other matters, regulatory compliance, systems and controls, client assets, anti-money laundering and all significant risks including operational, investment and financial markets risk. It also reviews the Internal Capital Adequacy Assessment Process (ICAAP) and recommends it for approval to the Board. The committee reports to the Board on the quality of internal policies, disciplines, controls, processes and monitoring procedures in place to deal with risk, making recommendations for improvements where significant internal control failures have occurred. The Risk and Compliance Committee met four times during the year to 31st March 2016. We also have in place an Asset Allocation and Implementation Committee (AAIC) containing external members which supports the risk management of the company by providing independent input and comment on financial markets and investment strategy.

Individuals are selected to become directors of Tcam Asset Management or members of the AAIC on merit and to ensure that all of the skills and experience required within the regulated business are covered. There is no policy on diversity with regard to selection of directors or AAIC members. A profile showing the knowledge, skills and experience of the executive directors is provided under the People section of this website.

Risk Framework

Risk within the Company is managed by use of the following:
• regular reviews by the Joint CEO and Compliance Director;
• adopting a relatively conservative risk appetite;
• identifying risks and evaluating them in the ICAAP;
• reviewing the ICAAP at least annually at meetings of the Board;
• undertaking scenario analysis and stress tests on the most significant risks. This informs the Company on the likely impact of risks materialising and what, if any, impact there is likely to be on capital adequacy;
• applying an internal control framework with risk scoring to govern processes and procedures and to mitigate risks, and
• maintaining a risk event reporting mechanism which seeks to identify the root cause of any failures or omissions.
In addition, National Regulatory Services also provide ad-hoc regulatory advice and support and attend the quarterly Risk and Compliance Meetings.

Risk Statement

The Board is ultimately responsible for reviewing the effectiveness of the Company’s risk management arrangements and systems of financial and internal control. These arrangements are designed to mitigate rather than eliminate the risks within the business and offer reasonable assurance against fraud, material misstatement and loss. The Board considers that it has in place adequate systems and controls with regard to the Company’s profile and strategy

2. Approach to assessing adequacy of Own Funds

Capital adequacy is monitored daily by Finance and with monthly reporting to the Board. Capital planning forms a key part of the Company’s budgeting process. The capital plan ensures the Company has sufficient Own Funds to support its business objectives.

The Company performs an ICAAP annually that considers all of the risks faced by the Company, the likely impact on the business if they were to occur, how these risks can be mitigated and the amount of capital it is prudent to hold against them occurring under stress conditions. The aggregate of these “Pillar 2” risk allocations is then compared against the Pillar 1 capital requirement and the higher figure constitutes the Company’s Own Funds requirement.

The ICAAP is updated annually with approval provided by the Board.

3. Own Funds

The company is an IFPRU 125k Limited Licence Firm because it does not deal for its own account or underwrite issues on a firm commitment basis. It manages individual portfolios and it holds client money. An IFPRU firm must maintain at all times capital resources equal to or in excess of the base requirement (€125,000).
The Pillar 1 capital requirement for an IFPRU 125K Limited Licence Firm is set out in Article 95 (2) of the CRR and is the higher of the sum of its market and credit risk capital requirements and its Fixed Overhead Requirement (FOR) (i.e. one quarter of the firm’s relevant fixed expenditure). The Company’s FOR exceeds the total of the credit and market risk capital requirement and also exceeds the base capital requirement of €125,000. The Company’s Pillar 1 capital requirement is therefore determined by its Fixed Overhead Requirement of £1,534,970.

The Pillar 2 capital requirement assesses all other risks that the Company is exposed to such as operational risk, business risk and reputational risk. Stress scenarios are modelled which determine the amount of capital that should be allocated to each risk type so the Company can survive severe but plausible risk events. During the year ended 31st March 2016 the Company calculated that capital of £1,624,000 should be held under Pillar 2. As this exceeded the Pillar 1 requirement, the Pillar 2 requirement of £1,624,000 therefore represented its own funds requirement.

During the 12 month accounting period to 31st March 2016 the Company complied fully with all capital requirements and maintained a surplus in excess of its Pillar 2 capital resources requirement. At the accounting reference date, the Company held the following capital position:

31 Mar 2016
Common Equity Tier 1 Capital
Ordinary Share Capital                                           £1,825,668
Share premium                                                        Nil
Retained earnings *                                                 £867,022

Deductions                                                              Nil
Common Equity Tier 1 Capital after deductions      £2,692,690

Tier 2 Capital                                                           Nil

Own Funds                                                               £2,692,690

Risk weighted exposure amount **                         £19,187,125

Core Tier 1 and Total Capital Ratio                         14.03%

Surplus capital over Pillar 2 own funds                    £1,068,690

* The retained earnings includes the profit for the year ended 31st March 2016 after audit.

** The risk weighted exposure amount is 12.5 times the Fixed Overhead Requirement based on the audited accounts to 31st March 2016.

The Own Funds of the Company are its Shareholder Funds as shown in its Balance Sheet at the reporting date. There are no regulatory adjustments or deductions from regulatory Own Funds. A full analysis of Own Funds is included in Annex 1.

The main features of the ordinary shares in issue are shown in Annex 2 (link to PDF on Dropbox) as required by Article 437 (1b) of the CRR. The Company does not have any form of Additional Tier 1 or Tier 2 capital.

The Core Tier 1 and Total capital ratios of 14.03% exceed the minimum ratios by 9.53% and 6.03% respectively.

4. Principal risks

The principal risks to the financial position of the business and the severity and probability of impact are discussed below together with steps that could be taken to mitigate their impact. These risks are analysed between the following categories:
• Credit Risk
• Market Risk
• Interest Rate Risk
• Operational Risk

The Company is not exposed to any risk arising from the holding of equities in other companies nor is there any Securitisation Risk in the business of the Company as there is no packaging of assets for on-sale or similar activities. The Company does not make use of derivatives to manage its own risk profile and accordingly is not exposed to counterparty credit risk.

Credit Risk

For its Pillar 1 regulatory capital calculation of credit risk, under the credit risk capital component the Company has adopted the Standardised approach which weights exposures according to their risk profile and, where appropriate, credit ratings in accordance with the CRR.

The Company issues invoices to Financial Planning clients which carries the risk that they may not pay the fees charged. The incidence of unpaid fees within the Financial Planning area of the business is historically very low. The Company is also exposed to credit risk from institutions with which it places its corporate cash but regularly conducts due diligence on these institutions to mitigate this risk.

Market Risk

The Company does not itself take positions in shares or other instruments and is not exposed to foreign-exchange, settlement or commodities risk. The firm is indirectly subject to market risk as income is dependent on the value of client assets under management. This risk is mitigated by the asset allocation strategy which ensures that clients have diversified portfolios with limited exposure to any one asset class. The firm’s Pillar 2 business risk assessment considers various scenarios where a fall in assets under management following a severe market downturn leads to lower management fee income, although other risk scenarios are considered. The Company regularly analyses various different economic scenarios to model the impact of economic downturns on its financial position.

Interest Rate Risk

The only Interest Rate Risk is in relation to the Company’s own cash on deposit. Any impact on the Company is limited and is regarded as negligible.

Operational Risk

Operational risk is defined as the risk of loss arising from inadequate or failed internal processes, people and systems or from external events, including legal risk. It includes potential low frequency, high severity events such as IT security and internal and external fraud. The company is aware that operational risk can never be eliminated, but seeks to minimise the probability and impact of operational events.

The company’s business areas manage this risk through appropriate controls and loss mitigation techniques, including use of insurance. A framework of policies, procedures and internal controls is in place which ensures compliance with laws and regulations and allows the Board to control risk within its risk appetite. Further control assurance is provided by the company’s compliance department and through regular testing of the business continuity plan.

The operational risk policy incorporates a review of the company’s risk register by the Risk & Compliance Committee. The company has implemented a risk and control assessment by the Compliance department through discussion with directors and relevant managers. This scores risk events as to probability and impact as well as evaluating the design and performance of controls that have been put in place to mitigate that risk. The results of the assessment inform the annual ICAAAP.

As a limited licence 125K investment firm the Company assesses the need to hold additional Pillar 2 capital against operational (and other) risks during its ICAAP.

5. Remuneration

The FCA's Remuneration Code ("the Code") applies to certain individuals' total remuneration, both fixed and variable.


The Company is subject to the Remuneration Code and is categorised as a Level 3 firm.

The Company's policy is designed to ensure that it complies with the Code and therefore that its compensation arrangements:
• are consistent with and promote sound and effective risk management;
• do not encourage excessive risk taking;
• include measures to avoid conflicts of interest; and
• are in line with the Company's business strategy, objectives, values and long-term interests.

Application of the requirements
The Company is required to disclose certain information on at least an annual basis regarding its remuneration policy and practices for those staff whose professional activities have a material impact on the risk profile of the Company (“code staff”). This disclosure is made in accordance with the Company's size, internal organisation and the nature, scope and complexity of its activities.

Summary of information on the decision-making process:
• The Company's policy has been agreed by senior management in accordance with the Code's principles.
• The group has in place an independent remuneration committee which met once during the year to 31st March 2016. The members are all Non-Executive Directors and considered independent.
• The Company's policy will be reviewed as part of an annual process or following a significant change to the business requiring an update to its internal capital adequacy assessment.
• The Company's ability to pay bonuses is based on the performance of the Company overall and is based on the Company's actual results for the year in question adjusted for any need to retain resources to meet regulatory capital requirements or for business development

Tcam Investment Portfolio’s
VT Tcam Growth Fund, VT Tcam Income Fund and VT Tcam Absolute Return Fund are the available funds of VT Tcam Investment Funds an Investment Company with Variable Capital (ICVC) authorised by the FCA, reference number 190667. Tcam Asset Management Limited is the Investment Manager for the VT Tcam Investment Funds. Valu-Trac Investment Management Limited is the Authorised Corporate Director for the funds.

Summary of how the Company links between pay and performance
The Company's remuneration policy is linked to the performance of the Company as a whole, each department and of individual employees. Remuneration comprises of both fixed and variable remuneration with variable remuneration paid in the form of cash bonuses. The payment of cash bonuses is deferred and made in equal instalments in June and December following the financial year in which they are earned to those who are still employed at that time. No element of variable pay is guaranteed for any code staff. Management take both financial and non-financial criteria into account when assessing individual performance. Individuals are rewarded on an assessment based on their contribution to the overall strategy and achievement of the business taking into account factors including, where appropriate:
• Investment management.
• Operations.
• Client interaction including business development.
• Overall performance, reliability and effectiveness.

Aggregate remuneration of Code Staff
For the year ending 31st March 2016 there were 12 code staff (as defined below).

Remuneration earned in the year was divided between fixed and variable remuneration as follows:

Fixed remuneration £0.77m

Variable remuneration £0.27m

The ratio of fixed to variable remuneration earned in the year to 31st March 2016 was 2.9:1

Fixed remuneration consists of base salaries only while variable remuneration consists of cash bonus payments. The six non-executive directors who receive fixed fees are not entitled to any element of variable remuneration. All of the variable remuneration noted above was awarded in respect of performance during 2015/16 and is deferred and due for payment in June and December 2016. Variable remuneration awarded in respect of 2014/15 of £181,000 was paid during 2015/16. No performance adjustments were made in respect of these payments.

Remuneration Code staff comprises categories of staff including senior management, risk takers, staff engaged in control functions excluding CF30’s (i.e. CF1 – 29) and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the company's risk profile.

Interest Rates and Foreign Exchange

Interest Rates

From the 1st October 2016 the rates of interest on un-invested cash held on deposit are:

Cash Balance                                          AER* Rate
On the first £99,999.99                             0.00%
On the next £900,000 to £999,999.99       0.00%
£1,000,000 and above                             0.00%
*AER stands for Annual Equivalent Rate and is an illustration of the effective interest rate that would be earned if interest paid remains in the account itself earning interest.

The above rates apply to instant access sterling accounts only. No interest is paid on accounts denominated in any other currency.

Our interest rates are subject to variation.

We hold all client money in accordance with the Financial Conduct Authority Client Money rules. These require us to hold client money separately from the firm's money and hold it in a regulated credit institution. For added security, client money is held with a number of banks in line with the firm's diversification policy details of which are available on request.

Previous Interest Rates

Schedule of Interest Rates With Effect From 1st May 2015
The rates of interest on uninvested cash held on deposit were:

Cash Balance                                                 AER* Rate
On the first £99,999.99                                    0.075%
On the next £900,000 to £999,999.99              0.100%
£1,000,000 and above                                    0.150%
*AER stands for Annual Equivalent Rate and is an illustration of the effective interest rate that would be earned if interest paid remains in the account itself earning interest.

The above rates apply to instant access sterling accounts only. No interest is paid on accounts denominated in any other currency.
Interest is accrued daily and will be credited to your account quarterly in arrears at end February, May, August and November. Interest is paid gross without deduction of tax. Our interest rates are subject to variation.

We hold all client money in accordance with the Financial Conduct Authority Client Money rules. These require us to hold client money separately from the firm's money and hold it in a regulated credit institution. For added security, client money is held with a number of banks in line with the firm's diversification policy details of which are available on request.

Foreign Exchange

Where we carry out foreign exchange transactions, a margin of 0.5% will be applied to the foreign exchange rate obtained for all transactions. We effect transactions in the wholesale money markets to obtain prices that are considerably more favourable than the rates typically available from retail banks and currency exchange businesses.

Please click here if you wish to download the above information as a PDF file.

Legal Entity Identifier (LEI) Information

Please click here for a Q&A providing further information about LEIs and letting you know how to apply for one.


If you have any complaints about the service or advice you have received from us then you should contact the Compliance Director, Tcam Asset Management Limited, Level 1 Princes Exchange, 1 Earl Grey Street, Edinburgh, EH3 9BN, or telephone 0131 297 3767.

We will investigate your complaint in accordance with our written complaints procedures and will aim to resolve your complaint as quickly as possible. If you are dissatisfied with the progress or outcome of the investigation into your complaint you have the right to refer matters to the Financial Ombudsman Service.  You can obtain a copy of the Financial Ombudsman Service explanatory leaflet from us or directly from the Financial Ombudsman Service at:

The Financial Ombudsman Service
Exchange Tower
E14 9SR