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

2021

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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	7
B.3 Risk management system including the ICAAP	8
C.	Risk Profile	9
C.1 Market risk	9
C.2 Credit risk	9
C.3 Operational risk	10
C.4 Liquidity risk	10
D. Capital Management and Own Funds	11
D.1 Own Funds	11
D.2 Capital Requirements	12

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Introduction

Following the UK's exit from the EU at the end of 2020, the UK 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") which applied at 31 December 2021, 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. From 1 January 2022, these requirements will be superseded by those of the UK's new Investment Firms Prudential Regime ("IFPR").

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 2021 (the
  "Company Report & Accounts"), a copy of which can be found at https://find-and-update.company-information.service.gov.uk/company/08764231/filing-history.
• The Group's Annual Report and Accounts for the year ended 31 December 2021 (the "Group Report & Accounts"), a copy of which can be found athttps://www.sjp.co.uk/shareholders/reports-presentation-and-webcasts/2022.

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 2021.

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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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. 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 (Company Registration 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").

The Company has fully assessed the requirements of the new IFPR, and implemented the necessary changes to ensure that it complies with the new regulations. Although the IFPR introduces a more granular assessment of required capital, the overall level of required capital will be broadly similar to that required under the existing CRD IV regime.

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B. 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.

Following the introduction of the new IFPR regime on 1 January 2022, SJPIA is no longer required to maintain separate entity level Nomination, Risk and Remuneration Committees. These committees will therefore continue to 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 relevant internal capital assessments and regulatory disclosures, including 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 Group	Other	Total
I S Gascoigne	11	0	11
C G Gentle	17	1	18
I D MacKenzie	7	2	9

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