St James Place : Investment Administration Limited - Pillar 3 disclosures report

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ST. JAMES'S PLACE INVESTMENT

ADMINISTRATION LIMITED

Pillar 3 Disclosures Report 2019

Table of Contents

Introduction

3

A.	Background	4
B.	System of Governance	5
B.1	General information on the system of governance	5
B.2	Group Policies	6
B.3	Risk management system including the ICAAP	7
C.	Risk Profile	8
C.1	Market risk	8
C.2	Credit risk	8
C.3	Operational risk	8
C.4	Liquidity Risk	9
D.	Capital Management and Own Funds	10
D.1	Own funds	10
D.2	Capital Requirements	10

Introduction

This Pilla r 3 Report has been prepared in line with the requirements of the Capital Requirements Directive ("CRD IV") and Capital Requirements Regulation ("CRR"), to assist clients of St. James's Place Investment Administration Limited (the "Company" or "SJPIA") and other stakeholders in understanding the nature of our business, how it is m a naged, a nd its ca pital position.

SJPIA is pa rt of the wider St. Ja mes's Pla ce group of companies, headed up by St. Ja mes's Pla ce plc.

Relevant information about the Company's businessisalsoprovidedin:

• • The Company's Annual Report and Accounts for the year ended 31 December 2019 (the "Company Report & Accounts"), a copy of which can be found athttps://beta.companieshouse.gov.uk/company/08764231/filing-history

• • The Group's Annual Report and Accounts for the year ended 31 December 201 9 (the "Group Report & Accounts"), a copy of which can be found athttps://www.sjp.co.uk/shareholders/reports-presentation-and-webca sts/2020

Where a ppropriate we will refer rea ders to these documents.

There are, however, certain specific CRD IV and CRR requirements which are not already reported publicly elsewhere, a nd those are specifically included in this report. In particular, this report includes full reporting of the Company's capital position at 31 December 2019.

These disclosures have been reviewed internally and approved by the Board of SJPIA. They have not been externally audited, except to the extent that they reproduce information also included within the Company Report & Accounts or the Group Report & Accounts.

These disclosures do not constitute financial statements and should not be relied upon in making judgements about SJPIA,orforanyotherpurposeotherthanthatforwhichtheyareintended.

A.

Background

The St. James's Place group ("the Group") is a vertically integrated wealth management group, which benefits from the synergies of combining funds management with the provision of advice.

St. Ja mes's Place Investment Administration Limited ("SJPIA" or the "Company") is a limited license investment firm, with no subsidiaries, which administers investments in the Group's ra nge of unit trusts, both UCITS funds a nd NURS funds, a nd acts a s an ISA manager.

SJPIA is a wholly-owned subsidiary of St. James's Place Wealth Management Group Limited ("SJPWMG"), which in turn is a wholly owned subsidiary of St. Ja mes's Pla ce plc ("SJP"), the ultimate parent company of the Group.

An overviewof the Group structure,andSJPIA's role within this, is included in the Stra tegic Report within the Company Report & Accounts.

SJPIA is domiciled in Englandand Wales (No. 08764231) and its registered a ddress is St. Ja mes's Pla ce House, 1 Tetbury Road, Cirencester, Gloucestershire GL7 1FP.

SJPIA is a uthorised in the UK by the Financial Conduct Authority ("FCA").

B. System of Governance

B.1 General information on the system of governance

SJPIA Governance

SJPIAis managedasaGroupsubsidiarycompanywithanumberofkeygovernance,strategy,planningandrisk m a nagement processes, a nd, to a la rge extent, senior operational m anagement, operating a t a Group level.

The FCA has approved a modification of its rule IFPRU 1.2.3R, which removes the requirement for SJPIA to ha ve its own entity-level Nomination, Risk a nd Remuneration Committees (Wa iver reference number 4708524, which was granted in 2017 and expires on 11 September 2020). In line with this direction, these committees opera te at a Group level.

However, certain decisions and key matters must be considered directly by the board of SJPIA. Such matters include:

• • Those required by law (e.g. matters under the Companies Act 2006 (such as dividend payments) and a ccounting a nd a uditing legisla tion (such as a pproving a nnual a ccounts));

• • Those required by regulators (e.g. a pproval of the CRD IV disclosures a nd ICAAP); and

• • Other commercial matters the directors of SJPIA deem, in view of their fiduciary duties, they should consider directly (e.g. entering into key agreements).

The members of the SJPIA Board are shown in the following table, which also contains details relating to the number of other directorships they hold:

Number of directorships held
Within SJP Group	Other	Total
A M Croft	14	2	16
I S Gascoigne	10	1	11
C G Gentle	19	1	20
I D MacKenzie	7	3	10

Group Governance

The business performance of each of the regulated entities within the Group, including SJPIA, is ultim ately linked with that of the Group as a whole and the majorityof risks impact more than one of the regulatedentities. The governance structure is designed to reflect this high level of integration and interconnectedness, with the business of the Group being governed by a unified Group board committee structure for SJP plc.

The Board of directors of SJP plc (the "Group Board"), in conjunction with its Executive Board Committee ("ExBo"), sets the strategic direction for, a nd risk appetite of, the Group. TheGroupBoard hasdelegatedcertain responsibilities to board committees, whose members are non-executive. The Group Board reserves certain matters to itself but delegates other matters to ExBo, which is responsible for the Grou p's operational matters. Ea ch member of ExBo has individual responsibility for a number of divisions within the Group, providing smooth a nd effective reporting structures and delegations of a uthority.

In line with the centralised governance structure, the key functions are organised as Group functions, ensuring consistent im plementation of systems and procedures a cross the Group.

On 9 December 2019 the Senior Managers and Certification Regime replaced the Controlled Functions regime for FCA solo-regulated entities (including SJPIA). SJPIA has allocated Senior Management Functions and Prescribed Responsibilities to its senior managers and updated responsibilities have been reflected in a new Ma nagement Responsibilities Ma p for relevant staff (a s well a s in Sta tements of Responsibility a nd updated job descriptions).

Further information on the Board and the Group's System of Governance is provided in the Governance section of the Group Report & Accounts (on pages 72 to 118).