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

ST. JAMES'S PLACE INVESTMENT

ADMINISTRATION LIMITED

Pillar 3 Disclosures Report 2020

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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	9
C.4	Liquidity Risk	10
D.	Capital Management and Own Funds	11
D.1	Own funds	11
D.2	Capital Requirements	11

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Introduction

Following the UK's exit from the EU and the end of the subsequent Transitional Period at 11pm on 31 December 2020, the UK has adopted the previous CRD IV requirements with only limited changes. Throughout this document, any references to CRD IV should be interpreted as referring to the UK enactment of this legislation (unless otherwise indicated).

This Pillar 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 managed, and its capital position.

SJPIA is part of the wider St. James's Place group of companies, headed up by St. James's Place plc.

Relevant information about the Company's business is also provided in:

• The Company's Annual Report and Accounts for the year ended 31 December 2020 (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 2020 (the "Group Report & Accounts"), a copy of which can be found athttps://www.sjp.co.uk/shareholders/reports-presentation-and-webcasts/2021.

Where appropriate we will refer readers to these documents.

There are, however, certain specific CRD IV and CRR requirements which are not already reported publicly elsewhere, and those are specifically included in this report. In particular, this report includes full reporting of the Company's capital position at 31 December 2020.

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, or for any other purpose other than that for which they are intended.

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1. 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. James'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 range of unit trusts, both UCITS funds and NURS funds, and acts as 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. James's Place plc ("SJP"), the ultimate parent company of the Group.

An overview of the Group structure, and SJPIA's role within this, is included in the Strategic Report within the Company Report & Accounts.

SJPIA is domiciled in England and Wales (No. 08764231) and its registered address is St. James's Place House, 1 Tetbury Road, Cirencester, Gloucestershire GL7 1FP.

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

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1. System of Governance

B.1 General information on the system of governance

SJPIA Governance

SJPIA is managed as a Group subsidiary company with a number of key governance, strategy, planning and risk management processes, and, to a large extent, senior operational management, operating at a Group level.

The FCA has approved a modification of its rule IFPRU 1.2.3R, which removes the requirement for SJPIA to have its own entity-level Nomination, Risk and Remuneration Committees (Waiver reference number 00001390 was granted on 28 August 2020 and expires on 1 January 2022). In line with this direction, these committees operate 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 accounting and auditing legislation (such as approving annual accounts));
• Those required by regulators (e.g. approval of the CRD IV disclosures and 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	Other	Total
	Group
A M Croft	13	1	14
I S Gascoigne	10	1	11
C G Gentle	17	1	18
I D MacKenzie	7	3	10

Group Governance

The business performance of each of the regulated entities within the Group, including SJPIA, is ultimately linked with that of the Group as a whole and the majority of risks impact more than one of the regulated entities. 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, and risk appetite of, the Group. The Group Board has delegated certain 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 Group's operational matters. Each member of ExBo has individual responsibility for a number of divisions within the Group, providing smooth and effective reporting structures and delegations of authority.

In line with the centralised governance structure, the key functions are organised as Group functions, ensuring consistent implementation of systems and procedures across the Group.

SJPIA has been subject to the UK's Senior Managers and Certification Regime since December 2019. SJPIA has allocated Senior Management Functions and Prescribed Responsibilities to its senior managers and responsibilities are reflected in the Management Responsibilities Map for relevant staff (as well as in Statements of Responsibility and 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 82 to 143).

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