Stewardship Code

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Albert Bridge Capital LLP (the "Firm") is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy.

The seven principles of the Code are that institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
  • Monitor their investee companies;

The Firm pursues a long only strategy based on fundamental research that involves it investing in highly liquid, large cap stocks in developed European markets, including UK equities and derivatives. The Code is therefore relevant to some aspects of the Firm's trading.

While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code.

The Firm invests in a variety of jurisdictions across Europe and takes a consistent approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

For further information on the Firm’s approach contact: Doriana Pavlicu at info@albertbridgecapital.com

Pillar 3 Disclosure

Pillar 3 Disclosure as of December 31, 2019

The Capital Requirements Directive (“CRD”) and the Alternative Investment Fund Managers Directive (“AIFMD”) (“together, the Directives”) created a revised regulatory capital framework across Europe covering the amount and nature of capital financial services firms must maintain, including provisions for compensation.

In the United Kingdom, rules and guidance are provided by the Financial Conduct Authority (“FCA”) in the General Prudential Sourcebook (“GENPRU”) for Banks, Building Societies and Investments Firms (“BIPRU”) and the Investment Funds Sourcebook (“FUND”).

The FCA framework consists of three "Pillars":

Pillar 1 sets out the minimum capital requirements for firms to meet their credit, market and operational risk;

Pillar 2 requires firms to assess whether their Pillar 1 capital is adequate to meet their risks and is subject to annual review by the FCA; and

Pillar 3 requires public disclosure of qualitative and quantitative information about the Firm’s underlying risk management controls, capital position and remuneration arrangements.The AIFMD adds further capital requirements which relate to the assets under management and professional liability risks of the Alternative Investment Funds (“AIFs”) operated by a manager.Rule 11 of BIPRU sets out the provisions for Pillar 3 disclosure. This document is designed to meet our Firm’s Pillar 3 obligations.The rules provide that firms may omit one or more of the required disclosures if such omission is regarded as immaterial. Information is considered material if its omission or misstatement could change or influence the decision of a user relying on the information. In addition, firms may also omit one or more of the required disclosures where such information is regarded as proprietary or confidential.Future disclosures will be issued on an annual basis, at a minimum, and will be made available on Albert Bridge’s website.

Firm Overview

Albert Bridge Capital LLP (“the Firm”) is incorporated in the UK and it is authorised and regulated by the FCA. The Firm has permission to provide discretionary investment management and investment advisory services on behalf of professional clients and eligible counterparties. The Firm is a full scope alternative investment fund manager (“AIFM”) and it is classed as a Collective Portfolio Management Investment firm (“CPMI”) that is an external AIFM by the FCA for capital purposes.The Firm is governed by its senior management, tasked with designing a risk management framework that allows them to identify the risks faced by the business, measure their potential impact and establish policies and procedure to ensure such risks are actively managed. Business, operational, market and credit risks have been identified as the main areas of risk to which the Firm is exposed. Where, in the course of business, any material risk is identified, the financial impact of such risk is measured as part of business planning and capital management and determination is made whether the amount of regulatory capital is adequate.

Capital Resources and Requirements

Capital Resources

Pillar 1
The Firm is a Limited Liability Partnership and its capital arrangements are established in its Partnership Deed. Its capital comprises of £303,000 Tier 1 capital and £1,300,000 supplementary capital with the latter absorbing the expenses. As at 31 December 2019, the Firm's Pillar 1 capital requirement was £281,235. The Firm’s capital requirements and main features of its resources are summarised below.As a BIPRU limited license firm, the Firm’s capital requirements are the greater of:Its base capital requirement of €50,000;The sum of its market and credit risk requirements; orIts fixed overhead requirement (FOR).In addition, as a CPMI, the Firm is also required to maintain at all times ‘own funds’ which equal or exceed the higher of:Funds under management requirement which is the Base Capital Requirement of €125k + 0.021% of AIF AUM in excess of €250m (but subject to a maximum of €10m); orThe sum of its market and credit risk requirements; orVariable Capital Requirement, which is the Fixed Overhead Requirement Plus whichever is applicable of:a) The professional negligence capital requirement; orb) The PII capital requirement.

Satisfaction of Capital Requirements

Pillar 2
Pillar 2 requires the Firm to take a view on whether the Firm needs to hold additional capital against firm-specific risks not adequately covered by Pillar 1.The Firm has a fairly simpler operational structure and it has concluded that the largest risk in capital terms is that of performing an orderly wind down of the business and the calculated costs for such a scenario is less than the Firm’s Pillar 1 capital requirement and the Firm has therefore concluded that no additional capital injections are necessary and the Firm expects to continue to be profitable.

Risk Management
It is the Firm’s view that its capital requirements are driven by its fixed overhead requirements. However as mentioned above, the firm has also identified and assessed the impact of business, operational, market and credit risks. The firm has also considered liquidity risk and deemed its impact on the firm immaterial.

Business Risk
The most significant business risk faced by the Firm is that of a substantial and sustained reduction in Funds under Management, caused by adverse market conditions or investor redemptions, resulting in a loss of management fee income. The firm has assessed those risks and it is able to mitigate using various means including by solidly capitalizing the business.

Operational Risk
This is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events, including legal risk.Albert Bridge seeks to mitigate all operational risks to acceptable levels, in accordance with its risk appetite, by maintaining a strong control environment, ensuring that its employees have appropriate skills and training and establishing an efficient and effective management structure.

Market Risk
Since the Firm holds no trading book positions on its own account, its market risk is limited to the impact of foreign exchange fluctuations on its receivables in foreign currency (such as the management and performance fees which are receivable in USD) and on the value of any foreign currency held in the bank. The firm maintains both GBP and USD bank accounts and is able to pay out of them directly, minimizing the cost of foreign currency trading.

Credit Risk
The main credit risk to which the Firm is exposed is in respect to the failure of its debtors to meet their contractual obligations. The Firm believes its credit risk exposure is limited since the Firm’s revenue is primarily related to management and or performance fees received from funds. Other credit exposures include bank deposits and office rental deposits (held with reputable institutions). As such, due to the low risk of non-payment from its counterparties, management is of the opinion that no provision is necessary.The Firm has adopted the standardised approach to credit risk, and therefore follows the provision within BIPRU 3 standardised credit risk of the FCA handbook. The Firm applies a credit risk capital component of 8% to its non-trading book risk weighted exposure. The Firm is obligated to use a risk weight of 100% to all non-trading book credit exposures, except cash and cash equivalents which currently attract a risk weighting of 20%. The Firm has calculated its credit risk capital component (8% of risk weighted exposure) to be £140,689. Having performed its assessment and calculations, the Firm has concluded that no additional capital in excess of its Pillar 1 capital requirement is necessary.

Remuneration Code
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19B of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”) and in accordance with ESMA’s Guidelines on sound remuneration policies under AIFMD as well as the FCA’s published guidance.The Company only has one "business area", namely its investment management business and as a CMPI, Albert Bridge falls within proportionality level 3. Albert Bridge currently sets the variable remuneration of its staff in a manner which takes into account individual employee as well as firm performance. As a UK AIFM the Firm has assessed the proportionality elements and it has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the senior management sets, and oversees compliance with, the Firm's remuneration policy including reviewing the terms of the policy at least annually.

RTS 28

Albert Bridge Capital LLP (“Albert Bridge” or the “Firm”) is required to provide an annual disclosure regarding execution venues and brokers that it uses for each asset class as well as information regarding the quality of execution received. This disclosure covers the following classes of financial instruments that were traded
during the period.

The Firm invests on behalf of its clients, primarily in equities and as such, the financial instruments traded in the period were equity shares, equity derivatives (such as equity swaps / cfds and listed single stock options) and currency derivatives (where foreign exchange forwards are traded for hedging purposes). For the purposes of this disclosure the firm is further required to present the equity share disclosure based on the defined “tick size liquidity bands”:

(i) Tick size liquidity bands 5 and 6 (from 2000 trades per day)
(ii) Tick size liquidity bands 3 and 4 (from 80 to 1999 trades per day)
(iii) Tick size liquidity band 1 and 2 (from 0 to 79 trades per day)

The Firm’s strategy is to trade in highly liquid, all listed stocks primarily in developed European markets although it may choose to trade certain U.S. stocks and therefore the large majority of stocks traded would fall into the “5 and 6” liquidity band.

The Firm continually assesses the list of counterparties it uses with the ultimate goal of obtaining the best result for our clients. Although the firm has pre-negotiated commissions and it maintains an internal transaction cost analysis, the commission rates are not always the most important factor when choosing an executing broker. As a significant proportion of orders are algorithmic in nature (such as VWAP), order size and likelihood of execution in the manner intended can be more important. All executions are monitored by the trader with an informal review performed by the portfolio manager.

Client Classification

The Firm has no Retail Clients and it only deals with Professional Clients.

Close Links

There are no close links, common ownership that would give rise to any conflicts of interests with any of the execution venues or brokers used. Additionally, none of our clients have discretion over the counterparties used to trade

Special Arrangements

The Firm does not have any special arrangements in place not does it receive a discount on these services. Although we may on occasion receive short term market colour from our execution providers, it does not influence the choice of executing broker.

Changes to Execution Brokers and Venues

Counterparties are continually assessed and the Firm may at its discretion remove or add from the authorized broker list depending on results of its execution and broker reviews as well as trading requirements. Albert Bridge has not used RTS 27 reports or RTS 28 reports produced by execution venues or brokers during
the period under review (2019), as these were not available.

Legal and Regulatory

This website is issued by Albert Bridge Capital LLP, a limited liability partnership incorporated in England & Wales (Partnership number OC401275) which is authorised and regulated by the UK Financial Conduct Authority (FCA) [Insert FRN]. The entire content of Albert Bridge Capital LLP’s web site (the "Website") is subject to copyright with all rights reserved. You may download or print individual sections of the site for your personal use and information only provided that you retain all copyright and other proprietary notices. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the Website without the prior written permission of Albert Bridge Capital LLP (the "Company").

The information contained within this website is issued by Albert Bridge Capital LLP to sophisticated investors who are professional clients or eligible counterparties under the rules of the FCA. The information within this site is unsuitable for any other party, who should exit the Website immediately. The contents of this website are for information purposes only. It is not and should not be construed as an offer or a solicitation to offer to purchase or sell any investment or investment services or to provide investment advice. Any reference to individual securities does not constitute a recommendation to purchase, sell or hold that security.

The Website may contain links to other websites or information provided by third parties. When you access any third party website, you do so at your own risk and Albert Bridge Capital LLP does not endorse the contents of any such website, nor provide any representation or warranty as to its accuracy or completeness.

This Website is established in England by the Company in accordance with and shall be governed by, and your browsing in and use of the Website shall be deemed acceptance of, the laws of England and Wales. A condition of using the Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.Each time you use the site, a condition of use is that you comply with the above terms.

Privacy Policy

Albert Bridge Capital LLP (“we”, “our” or “us”) recognises the importance of protecting your personal data when you visit our website.  

Please read this Privacy Policy, which includes our Cookies Policy, and which explains our approach to data protection and how we use any personal data which we hold.

Categories of Information We May Collect

We may collect and process the following information:

- personally identifiable information such as names and addresses from people who have voluntarily input such information either when registering to use certain sections of the website and/or in order to contact us;

- if you contact us, we may keep a record of that correspondence as well as your e-mail address;  

- our computers automatically collect certain non-personally identifiable information when you visit our website, such as the type of browser you are using or the domain name of your Internet service provider.

We may also collect aggregate information on the site pages our users visit and how long you visited for.


Like many websites, we may use “cookies.” A cookie is a piece of data stored on a user’s device containing information about the user’s visit. Cookies make it easier for you to log on to and use our website during future visits.  

They also help us to improve our website by enabling us to monitor website traffic, to store information about your preferences, to speed up your searches and to recognise you when you return to this website.You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies.

If you choose to change your settings, you may find that certain functions and features will not work as intended.  All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.

We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org or www.allaboutcookies.org.

How We Use Your Information That We Collect

The personal data we hold is kept securely and is only accessed by authorised personnel. We will not sell, lease or distribute your personal information to third parties unless we have your permission or are required by law to do so.

We may use your information to improve our website and the information that we provide or to respond to your requests or questions.  Security and safe storage of your personal informationWe restrict access to personal information about our customers to those employees and agents who need to know that information in order to provide products and services to you.  

We maintain physical, electronic and procedural safeguards to protect your personal information.  Unfortunately, the transmission of information via the internet is not completely secure.  Therefore, although we have implemented security controls, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk.

If we choose to dispose of any personal information that we are not legally bound to maintain, then we will do so in a manner that reasonably protects such information from unauthorised access.

How Long Do We Keep Your Data?

How long we hold your personal information for will vary and will depend principally on:the purpose for which we are using your personal information - we will need to keep the information for as long as is necessary for the relevant purpose, and legal obligations - laws or regulation may set a minimum period for which we have to keep your personal information.

How can you access your information?

You have the right to access information held about you and may request that we amend, delete or update such information.

You may submit a request to ABCompliance@albertbridgecapital.com.  

Please note that there may be circumstances where we cannot delete information that we hold about you because of our legal obligations.  Additionally, we may charge a reasonable fee in order to meet our costs in actioning your request. If you have concerns about the way we handle your personal data, you can contact the ICO or raise a complaint.

Comments and questions

For questions about this Privacy Policy, please email us ABCompliance@albertbridgecapital.com.