We collect information about you when you engage us for any of our services, these may include personal or business financial planning/financial advice/mortgage, protection advice/investment management services/auto enrolment services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us. Website analytics are collected using cookies via We also use Google Analytics to collect information regarding site usage. This data is collected via cookies, which are text files placed on your computer to collect standard internet log information and visitor behaviour information. We use the information collected to better understand and improve our user experience.
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for you to pass to the connected individual if appropriate.
Whilst it is our policy to seek consent to process your data wherever possible, this is not a legal obligation in certain circumstances. The primary legal basis for the processing of your data is for the performance of our contract with you, or as a result of other legal obligations such as regulatory compliance with the Financial Conduct Authority (FCA). The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data * is required, we are legally obliged to obtain your explicit consent in order to collect and process this information.
* Special category' data is sensitive personal data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual orientation and health details
We collect information about you in order to provide you with the services for which you engage us.
If you agree, we may email you about other products or services that we think may be of interest to you. We never share your information for marketing purposes with companies outside our group of companies.
In order to deliver our services to you effectively, we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data; we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions. Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures such as password protection and/or encryption of data to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
During the course of our relationship with you, we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship. We’re also subject to regulatory requirements to retain your data for specified minimum periods.
These are, generally:
• Five years for investment business
• Three years for mortgage business
• Indefinitely for pension transfers and opt-out business
• Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. In any case, we’ll not keep your personal data with the exception of pension transfer business, for longer than 5 years after our relationship with you has ended.
You have the right to request deletion of your personal data at any time. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
If you use our online application portal (The IronMarket App) some personal information will be gathered through the information that you input into the system. Your data is collected in order for us to carry out the service for which you engage us. If you’re unsure about the outcome of the automated process you can contact us to discuss or to challenge the outcome.
We take measures to ensure the security of your data, with our application being encrypted and only accessed with individual secure log-in details. We don’t use any special category data (such as data about your health) in the automated process unless it’s strictly necessary to deliver our service and we have obtained your explicit consent to do so.
We regularly check our systems for accuracy and bias and feed any changes back into the design process.
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click on 'Set Preferences' in the footer at the bottom of this page or, alternatively, you can contact us by email or post.
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office
Wycliffe House, Water Lane
P: 0303 123 1113 (local rate)
We use Google Analytics to track non-personal visitor information regarding the use of this website and to compile statistical reports on website activity via Google Analytics.
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You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Our registered office and mailing address:
Lotus House, 31 Marsh Parade
The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services businesses aren’t able to resolve themselves. To contact the Financial Ombudsman Service please visit www.financial-ombudsman.org.uk.
IronMarket Limited is a private client wealth management firm, authorised and regulated in the United Kingdom by the Financial Conduct Authority (‘FCA’).
Under the FCA’s Prudential Sourcebook for Banks and Investment Firms (‘BIPRU’), IronMarket Limited is classified as a BIPRU €50K Limited Licence investment firm. As such, it is required to comply with the three “Pillars” of the EU’s Capital Requirements Directive (‘CRD’) framework. These are:
Pillar 1, which sets out the minimum amount of capital the Firm needs to meet its regulatory requirements;
Pillar 2, which requires us and our regulatory supervisors to consider the requirement to hold additional capital against risks not covered in Pillar 1. In the UK, this is implemented through the Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by IronMarket Limited, and by the FCA through the Supervisory Review and Evaluation Process (“SREP”);
Pillar 3, which requires us to disclose to market participants key information about our underlying risks, risk management controls and capital position.
The purpose of this document is to meet our obligation in respect of Pillar 3.
IronMarket Limited is a directly authorised discretionary fund management and financial advisory company.
IronMarket Limited makes Pillar 3 disclosures on at least an annual basis, as soon as practicable following the end of our Financial Year. These are provided on our corporate website, www.ironmarket.co.uk . Under the rules of BIPRU 11, the firm may omit certain information from the Pillar 3 disclosure, in specifically defined circumstances, where it believes that the disclosure contains information that is immaterial, proprietary or confidential. We confirm that we have not omitted any disclosures on these grounds.
All figures in this document are correct at 30th May 2020 unless stated otherwise
Our interpretation of risk appetite is how comfortable would we be if a risk were to emerge. This is quite a subjective analysis, however, it does gauge how the Board is feeling about the risks within our firm.
The current view is that the Board are relatively comfortable with the key risks potentially affecting the Firm, but we will keep this in view on an ongoing basis.
The Board will review the overall effectiveness and relevance of the Firm’s system and controls for each financial year. The Board will also carry out an evaluation of the major risks affecting the business and the processes in place within the business to control and monitor such risks on an ongoing basis. On this basis the Board will report and disclose its findings and whether it believes that all necessary actions have been, or are being, taken to remedy any significant failings identified as part of the ongoing risk management process and that no significant weaknesses were identified during the year.
The Firm’s activities are non-complex and the Firm does not hold client money or assets or trade on its own account.
Risk Management Framework
In order to ensure that IronMarket Limited regularly reviews and monitors all the potential areas of risk to the business, the Firm has put in place a risk management framework which enables all senior management and any relevant committee and the Board to be kept fully informed of any potential risks to the business and also how those risks might impact the group’s capital adequacy position.
A Risk Matrix has been designed which captures the core fundamental risks inherent in the firm and assesses how those risks are managed and mitigated, the key indicators that would suggest if the risk is likely to materialise together with an assessment that each risk may have on the Firms regulatory capital. This is the core assessment of the Pillar 2 requirements.
A thorough Compliance Monitoring Programme (“CMP”) is managed via an annual programme of reviews. Details of the CMP and the current status are provided to the Board on a regular basis, with any material issues being escalated to the Board immediately they are identified.
The CMP also includes undertaking stress and scenario testing of its key risks to determine the impact to our current and future profitability and balance sheet.
The key risk exposures the Firm faces and the mitigating controls in place are listed below:
The value of the assets that we manage or advise upon could reduce for a variety of reasons, including the loss of clients and a reduction in the value of a clients’ portfolio either due to market movements or poor portfolio performance. The highest potential risks are:
Loss of Clients – The firm has a diverse client base for our discretionary managed clients. IronMarket Limited currently manages £62.2 million of discretionary assets for 535 client relationships across 683 active accounts. The current average client size across all portfolios is approximately £116,000. Client relationship management and retention is at the very centre of operations. Should a client be deemed to be ‘at risk’ a formal action plan would be managed to prevent the loss of the client.
Relative investment performance is monitored and reported on an ongoing basis. Should the performance be such that either we or the clients were unhappy with portfolio performance, we would instigate a formal action plan, as discussed above.
This relates to the risks resulting from inadequate or failed business processes and systems. IronMarket Limited seeks to monitor potential sources of errors arising from its operations and continually strengthen our internal systems and processes, supervisory and oversight functions to reduce our residual risk exposure. The Firm maintains resilient infrastructure, and regularly tests its Business Continuity and Disaster Recovery arrangements to limit the impact of potential external events. Additionally the Firm maintains comprehensive Professional Indemnity Insurance cover to cap our exposure to potential large claims or operational losses.
There are two registered investment managers, who act as a contingency for each other.
Liquidity Risk & Market Risk
Reduction in Portfolio Values – The two principal reasons for a reduction in the value of a clients’ portfolio, would either be adverse market movements or poor relative investment performance. We have modelled the impact of a downturn in the markets, with the result that income derived from discretionary assets under management could fall by 69% before ongoing profitability would fall into a loss-making situation. Our current view is that such a market correction is unlikely.
The key liquidity requirements within the firm are the cashflows within the business and how a non-receipt of funds may significantly impact the firm.
At present the firm is not materially reliant on any one client for income (materiality is defined as any exposure to one client which may impact by the balance sheet by more than 10%).
The firm has undertaken an analysis of how a significant increase, or decrease, in business volumes may impact the firm. It is envisaged that the client base of approximately 535 clients, could increase by a further 30% before the three principal advisors of the firm would require additional assistance in managing those relationships.
The mission of IronMarket is to provide the highest standards of advice, discretionary investment management and service to its clients. We wish to establish a successful partnership with our clients, our staff and product providers that respect the interests and the goals of each party.
We strive to maintain and increase our current customer base by providing our services in a manner whereby the fair treatment of customers is consistently at the heart of the business.
Success is measured by our clients choosing us above the competition because of their belief in our ability to meet or exceed their expectations on cost, service and expertise.
As at 30th November 2020 the firm’s Capital Resources were £229k which cover a capital adequacy requirement of approximately £102k. This provides a surplus of £127k.
The following table itemises the components of the Capital Resource Requirement, the Firm’s Pillar 2 current Capital figures and the Total Capital and Surplus.:
|Minimum capital||Firm’s Pillar 2 capital|
|Base capital resource requirement||€50,000 – equivalent to £44,895 as at date of Review (£/Euro – 0.8979 as at 30/11/20)||€50,000 – equivalent to £44,895 at date of Review (£/Euro – 0.8979 as at 30/11/20)|
|Market risk||Not applicable||£102,018|
|Fixed overhead requirement (FOR)||£102,018||£102,018|
|Pillar 1 total||£102,018|
|Insert heading for Pillar 2 risk identified *||0|
|Insert heading for Pillar 2 risk identified||0|
|Pillar 2 total||£102,018|
|Adjustments (diversification if claimed etc)||0|
|Additional capital to cover stress testing||0|
|Current total capital||£229,089||£229,089|
SYSC 19F, which came into force on 1 January 2018, requires that where remuneration arrangements have the potential to create material conflicts of interest between individuals and Clients:
(a) Incentives must not be solely or predominantly based on quantitative commercial criteria, and must take fully into account appropriate qualitative criteria reflecting compliance with the applicable regulations, the fair treatment of clients and the quality of services provided to clients.
(b) A balance between fixed and variable components of remuneration must be maintained at all times, so that the remuneration structure does not favour the interests of the firm or its relevant persons against the interests of any client.
SYCS 19 requires IronMarket Limited to implement remuneration policies and procedures consistent with sound risk management and which do not incentivise staff to take risks outside the Company’s risk profile.
In line with FCA Rules and Guidance, IronMarket Limited has deemed that it does not need to comply with the prescriptive quantitative requirements in SYSC 19C on variable remuneration as these are not appropriate to the nature scope and complexity of its activities. Nevertheless, IronMarket Limited has adopted a remuneration policy (“the Remuneration Policy”) that covers all aspects of staff reward, including all fixed and variable components of remuneration, such as salaries, pensions and other benefits. The Policy is intended to incentivise and reward performance and encourage staff retention, but to do so in a manner that:
a) Is consistent with, and promotes sound and effective risk management;
b) Does not encourage risk-taking which is inconsistent with the risk profiles of the Company or its clients; and
c) Does not impair our compliance with our duty to act in the best interests of clients.
The Policy comprises a number of interlinked components, which are applied depending on the level of an individual’s seniority within the business:
Annual Pay Review – Awards are based upon the job evaluations and with reference to market rates.
Annual Bonus (Short Term Incentive Compensation) – Awards are based on a combination of Company and Personal Performance factored against market rates. Company results adjust the level of personal performance awards available based upon agreed business measures such as New Money, Assets, profit and loss, customer scope, expenses etc.
All staff performance measurement is subject to qualitative as well as quantitative commercial criteria and at least one performance measurement for all staff must be linked to risk control.