Newsletters,
June 8, 2026
We are pleased to share that our Founder & CEO of Sparrows Capital, Yariv Haim, has been recognised for another year running as a Recommended UHNW Wealth Manager in the Spears 500 Wealth Management Index...
Read MoreNewsletters,
February 6, 2026
February is a month that reminds us of care and attention; a subtle cue that even the most enduring commitments benefit from a little thoughtfulness. As the year gets underway, it’s also a natural time...
Read MoreNewsletters,
September 2, 2025
We’re excited to announce our partnership with model portfolio service (MPS) and multi-asset fund comparison provider Mabel Insights, enhancing adviser access to transparent performance insights and robust reporting tools. Supporting Advisers with Clear, Timely Data...
Read MoreNewsletters,
July 31, 2025
We’re pleased to announce the expansion of our Sparrows SCore MPS Market Range, now offering equity allocations in consistent 10% increments, from 0% (Bond Only) to 100% equity. This enhancement provides advisers with more flexibility...
Read MoreSparrows Papers,
April 15, 2025
In times of uncertainty, the value of discipline in investing becomes crystal clear. At Sparrows Capital, our belief in evidence-based investing isn’t just academic — it’s rooted in decades of data and countless market cycles....
Read MoreSparrows Papers,
April 2, 2025
In a world where market noise and short-term volatility often lead to costly mistakes, evidence-based investing offers a smarter, more disciplined approach. In this article for Professional Adviser, Yariv Haim, our CEO and Founder at...
Read MoreSparrows Papers,
March 19, 2025
We are proud to share that our very own Professor Elroy Dimson, Adviser to our board, has been honoured with the Lifetime Achievement Award at this year’s PAM Awards. The prestigious ceremony, held in London...
Read MoreSparrows Papers,
March 11, 2025
Spring is a season of renewal and growth, making it a great time to reflect on the importance of patience in investing. Just as well-tended gardens thrive over time, we believe investment portfolios benefit from...
Read MoreNewsletters,
March 5, 2025
At the end of February, we celebrated the 5th anniversary of our Sparrows SCore MPS. While we take a moment to reflect on our journey, our focus remains firmly on the future: helping advisers and...
Read MoreNewsletters,
February 25, 2025
We’re pleased to share that our suite of SCore Market portfolios are now risk-profiled by Dynamic Planner, making it even easier for advisers to integrate into their suitability process. This complements our Factor and Responsible...
Read MorePress/Video, Sparrows Papers,
February 10, 2025
In this recent Money Marketing article, our Compliance Officer, David Ogden, examines the conflicts of interest emerging as advisers align with consolidators and joint ventures. With the FCA reviewing the sector, key questions arise: Can...
Read MoreSparrows Papers,
November 6, 2024
Financial advisers increasingly face a choice between managed (or model) portfolio services (MPS) and multi-asset funds (MAFs) for client investments. In this article, Robin Powell explores this debate, highlighting recent data and trends. While MPS...
Read MoreSparrows Papers,
October 15, 2024
We have seen phenomenal growth in MPS assets under management, but we may now be seeing signs of equilibrium between platform model portfolios and traditional multi asset funds. Sparrows Capital's Mark Northway shares his view...
Read MoreSparrows Papers,
October 15, 2024
Sparrows Capital Limited's David Ogden has written an excellent analysis of the Financial Conduct Authority's announcement of its advice consolidation review - arguing why client outcomes and genuine independence should be at the heart of...
Read MoreSparrows Papers,
October 15, 2024
Arnie Millington explains the thought process behind Sparrows Capital Limited's ground-breaking pricing proposition. Our aim is to deliver the combined benefits of scale and technology directly to the end client.
Read MoreSparrows Papers,
September 30, 2024
We're delighted that the full SCore MPS suite is now available on the Elevate platform. This brings the number of live platforms to 15. SCore MPS is designed to help advisers serve their clients by:...
Read MoreNewsletters, Press/Video, Sparrows Papers,
September 20, 2024
LONDON – 10-09-2024 – Evidence-based investing pioneer Sparrows Capital has hired Helen Mason into a newly created Marketing Manager role, as the firm continues to expand its low-cost Model Portfolio Services. In recent months, Sparrows...
Read MorePress/Video, Sparrows Papers,
June 11, 2024
Robin Powell, editorial consultant to Sparrows Capital Limited, outlines eight fascinating retirement planning insights from Nobel laureate and revered academic William Sharpe.
Read MoreSparrows Papers,
April 3, 2024
Robin Powell, editorial consultant to Sparrows Capital Low-cost, evidence-based investment solutions have severely disrupted the traditional DFM market and are greatly improving outcomes for clients in the accumulation phase. But, says ROBIN POWELL, it’s...
Read MoreSparrows Papers,
January 10, 2024
Robin Powell, editorial consultant to Sparrows Capital There are few things more depressing than the thought of running out of money before we reach the end of our lives. Most of us would like to...
Read MoreSparrows Papers,
November 16, 2023
By Robin Powell, editorial consultant to Sparrows Capital "The four most dangerous words in investing,” the famous investor Sir John Templeton once said, “are 'this time it's different’.” Again and again, investors...
Read MoreNewsletters, Sparrows Papers,
August 10, 2023
Sparrows Capital is delighted to announce that Sarra Slegg has recently joined the SCore MPS team. She will be working with John Bennett and Jack Boon and Dan Smith and will be responsible for...
Read MoreNewsletters, Sparrows Papers,
July 20, 2023
Sparrows Capital is delighted to announce that Dan Smith has recently joined the SCore MPS team. He will be working with John Bennett and Jack Boon to expand our UK adviser network. Dan...
Read MoreNewsletters, Sparrows Papers,
June 27, 2023
Sparrows Capital, a multi-award-winning investment services firm, is delighted to announce the appointment of Adrian Durham as non-executive director. Adrian is the founder and Group CEO of FNZ Group and has overseen the development...
Read MoreNewsletters, Sparrows Papers,
June 16, 2023
Sparrows Capital is delighted to announce the appointment of Rupert Dickinson as chair of the board to lead the company through its next stage of development. The appointment is subject to regulatory approval. Rupert...
Read MoreNewsletters, Sparrows Papers,
May 31, 2023
Sparrows Capital has added a range of Market portfolios to its popular SCore MPS suite. The Market range comprises five portfolios ranging from 20% equity to 100% equity. The portfolios reflect a pure market capitalisation...
Read MoreNewsletters, Press/Video, Sparrows Papers,
April 28, 2023
28 April 2023, London: Sparrows Capital, a multi-award-winning investment services firm, has secured an investment from FNZ Ventures, the corporate venture unit of FNZ, the global wealth management platform, to further develop its low-cost evidence-based...
Read MoreSparrows Papers, White Papers,
January 30, 2023
Sparrows Capital's CEO, Yariv Haim, looks at the learning opportunities from 2022. Similar investment approaches produced very different outcomes in 2022 and, with a few exceptions in lower-risk portfolios, passive approaches outperformed active – in...
Read MoreSparrows Papers,
July 14, 2022
Innovation in MPS Award Winner – Sparrows...
Read MoreSparrows Papers,
July 13, 2022
The growth of MPS has been an important cog in the development wheel to democratise investment. It has done this by delivering cost-effective solutions for advisers which enable those clients with relatively smaller amounts to invest...
Read MoreNewsletters, Sparrows Papers,
June 24, 2021
If I knew then what I know now: The last 18 months have been something of a white-knuckle ride for many long-term investors. But for first-timers—particularly those in their twenties and thirties—...
Read MoreNewsletters, Sparrows Papers,
March 29, 2021
The logic of holding fixed income in your portfolio At $18 trillion and counting, the huge glut of global debt offering a negative yield is making fixed income look particularly unappealing. Why, the...
Read MoreSparrows Papers,
January 26, 2021
As the focus on responsible investing has grown, so the incorporation of ESG and SRI factors into investment strategies has been gathering pace over the last decade, supported and encouraged by governments and non-governmental...
Read MoreNewsletters, Sparrows Papers,
January 5, 2021
It is always hard to know what will happen with markets. We’re not in the business of offering predictions. Instead, like some of the successful sovereign and endowment funds whose approach we aspire to, we...
Read MoreAcademic Papers, Behavioural Finance, Factor Investing, Modern Portfolio Theory, Newsletters, Passive Investing, Sparrows Papers, White Papers,
November 24, 2020
Elroy is an acknowledged expert on long-horizon factor investing and on responsible investing, both of which have featured heavily in the press throughout the pandemic. He is also consultant to the board of Sparrows Capital....
Read MoreNewsletters, Sparrows Papers,
April 15, 2020
In this issue of our Bird's Eye View, Raymond reviews the experience of the first quarter in 2020 and examines the benefits to investors of a rule-based investment process.
Read MoreNewsletters, Sparrows Papers,
February 5, 2020
Alistair takes an irreverent look at the track record of some well known market forecasters.
Read MoreNewsletters, Sparrows Papers,
December 9, 2019
Yariv & Alistair review the benefits of diversification against the background of recent market disruptions.
Read MoreNewsletters, Sparrows Papers,
September 24, 2019
Alistair Meadows looks at Trump's options for stemming the inexorable rise of the US Dollar.
Read MoreNewsletters, Sparrows Papers,
June 20, 2019
Do active managers outperform passive managers in bear markets? Ray explores the persistent claim that active management outperforms in bear markets, and finds that the evidence suggests otherwise.
Read MoreNewsletters, Sparrows Papers,
June 11, 2019
Welcome to our Bird’s Eye View, in which Mark looks at the implications of the Woodford Equity Income Fund debacle.
Read MoreNewsletters, Sparrows Papers,
January 15, 2019
ESMA report on the cost and performance of investment products Yariv reviews the findings of this recently published report which again highlights issues with fee levels and value for money across the asset management industry....
Read MoreNewsletters, Sparrows Papers,
December 20, 2018
In this edition Raymond Backreedy looks at recent market volatility and advocates a steady hand.
Read MoreSparrows Papers, White Papers,
September 24, 2018
Sustainable investing is a growing focus for investors, who are increasingly looking to their money to do something positive at the same time as generating an investment return. The discipline goes beyond the traditional asset...
Read MoreSparrows Papers, White Papers,
June 28, 2018
One of Sparrows Capital’s consistent themes is the benefit to investors of creating a rule-based, low-cost control account, representing the strategic asset allocation, to sit alongside active portfolio components. This concept provides a real life,...
Read MoreNewsletters, Sparrows Papers,
May 10, 2018
Yariv takes a wry look at the philosophical issues affecting investment behaviour. The universe has a funny sense of humour!
Read MoreNewsletters, Sparrows Papers,
February 5, 2018
Raymond Backreedy discussed the difficulties of picking a market entry point - and the very real cost of being uninvested while doing so.
Read MoreNewsletters, Sparrows Papers,
December 21, 2017
The Price is Right! In this issue of our newsletter Yariv Haim takes a walk down memory lane...
Read MoreNewsletters, Press/Video, Sparrows Papers,
December 5, 2017
An evidence-based approach to trustees' fiduciary responsibility London, December 2017: Sparrows Capital, the evidence-based asset manager, has launched its new investment suite specifically designed for trustees looking to preserve and enhance the value of...
Read MoreNewsletters, Sparrows Papers,
November 9, 2017
In this issue of our newsletter Yariv Haim shares his insights from the Brexit experience so far.
Read MorePress/Video, Sparrows Papers,
October 16, 2017
The reality of the impact of investment skill Mark Northway looks at whether investment performance for charities is really generated by the skill of the fund manager and how passive strategies contribute to charity portfolios.
Read MoreNewsletters, Press/Video, Sparrows Papers,
September 26, 2017
The Public Employees Retirement System of Nevada (NVPERS) follows an approach which will sound remarkably familiar to our readers. The fund adopts a core and satellite approach to investing, with the 80% core portfolio expressed...
Read MoreNewsletters, Sparrows Papers,
September 6, 2017
Insights from the FCA Asset Management Market Study - Final Report The UK's Financial Conduct Authority recently published its final report on the state of the asset management industry, disappointing many spectators by softening some...
Read MorePress/Video, Sparrows Papers,
September 5, 2017
Evidence-based investing does away with emotive decision making and focuses on robust risk management, says Danielle Levy. Selling out of poorly performing investments during a market sell-off is one of the most common mistakes investors...
Read MoreNewsletters, Sparrows Papers,
August 21, 2017
FCA Asset Management Market Study – Final Report The UK’s Financial Conduct Authority recently published its final report on the state of the asset management industry. Yariv Haim, CEO of Sparrows Capital, examines the implications...
Read MoreNewsletters, Sparrows Papers,
June 5, 2017
Evidence based portfolio design Can passive become the new active? Yariv Haim reviews lessons learned from active and passive investment approaches, and proposes an enhanced evidence-based portfolio design on the basis of his findings.
Read MoreNewsletters, Sparrows Papers,
April 20, 2017
Mark Northway looks at the rise of populist movements and the growing prominence of political risks.
Read MoreNewsletters, Sparrows Papers,
March 9, 2017
Buffett's Bet! Mark Northway reviews Warren Buffett’s illuminating annual letter to Berkshire Hathaway’s shareholders.
Read MoreNewsletters, Sparrows Papers,
December 31, 2016
Mark Northway delves into the FCA Asset Management Market Study and discovers that the regulator's findings represent a welcome vindication of Sparrows Capital's beliefs and philosophy.
Read MoreNewsletters, Sparrows Papers,
November 30, 2016
Most investors know that their portfolio should be diversified, but don’t understand what that really means, or why. Investors often misunderstand—and therefore misapply—the concept. That can leave them with more risk than necessary, or with...
Read MoreNewsletters, Sparrows Papers,
September 30, 2016
Coming back from their holiday, the Johnson family was disappointed. Their summer house had been under renovation for the past 6 months, and although it was supposed to be ready three weeks ago, they hadn’t...
Read MoreNewsletters, Sparrows Papers,
August 30, 2016
When panic selling hits a market, or even worse when a market is shut down for a long period of time to deal with a crisis or market dislocation events, we should always be monitoring...
Read MoreNewsletters, Sparrows Papers,
June 30, 2016
It has been two years since we opened the doors at Sparrows Capital. During this time we have looked to build a constructive dialogue to earn your trust and to form the basis of a...
Read MoreSparrows Papers, White Papers,
June 22, 2016
On March 25th 2016 the Financial Times published an article entitled “Smart beta not quite as clever as marketed”. The full article can be found at: http://on.ft.com/1pLRBle . The author, John Authers, raises questions...
Read MoreSparrows Papers, White Papers,
May 31, 2016
A Zero Interest Rate World Fahd Rachidy explores the theoretical and practical implications of the current low / zero rate interest environment What is fixed income pricing telling us about market expectations for asset prices?...
Read MoreNewsletters, Sparrows Papers,
March 31, 2016
John had come to the clear conclusion that he would be better off with a passive investment manager. He would have someone focused entirely on his needs, not on gambling his money on risky speculation....
Read MoreNewsletters, Sparrows Papers,
January 30, 2016
Bird's Eye View. January 2016. Months later John was still reading and trying to understand what the Efficient Market Hypothesis was, and what is an asset allocation. He now knew that ETF selection requires an...
Read MoreImportant Information
Material on this site is issued in the United Kingdom (“UK”) by Sparrows Capital Limited (“Sparrows”) which is authorised and regulated in the UK by the Financial Conduct Authority (“FCA”).
Use of Information and Material
The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by Sparrows and its associated companies to be reliable, but is not guaranteed as to its accuracy or completeness. This does not exclude or restrict any duty or liability that Sparrows has to its customers under the regulatory system in the United Kingdom. This Site and the information herein is for general information purposes only. Your eligibility for particular products and advisory or management services is subject to local law and regulation.
Risk Factors
Past performance is no indication of future performance. The value of investments may fall as well as rise and investors may not get back the full amount invested. Changes in rates of foreign exchange may cause the value of investments to go up or down.
No Advice, Offers or Solicitations
The information and materials in this Site should not be construed as providing tax, legal or investment advice. In addition, they do not constitute an offer or solicitation, or an offer to sell, shares of any funds or any advisory or management service.. The type of securities mentioned may not be suitable for everyone.
USERS ARE URGED TO BASE THEIR INVESTMENT DECISIONS UPON A THOROUGH INVESTIGATION AND TO OBTAIN ALL NECESSARY PROFESSIONAL ADVICE.
Material Interests
Staff and/or directors of Sparrows may have holdings in the investment funds referred to on this site.
United Kingdom Stewardship Code
The Stewardship Code (the “Code”) was developed from the Walker Review on Corporate Governance in the UK and aims to enhance the quality of engagement between investors (and investment managers) and UK listed companies.
Sparrows supports the principles enshrined in the Code. Although the Code is voluntary, the FCA requires Sparrows to include on this website a disclosure about its commitment to the Code or, where it does not so commit, its alternative strategy. The FCA and the Financial Reporting Council have acknowledged that certain aspects of the Code are not directly relevant to all investment firms.
Sparrows invests almost exclusively in rule-based ETFs and index funds in order to capture market returns across all asset classes globally. Sparrows does not directly invest in shares or bonds issued by UK listed companies and therefore has no direct interaction with the management of such companies and does not enjoy voting rights in relation to such companies. For this reason, the Code is not directly relevant to Sparrows and it is not practical for Sparrows to implement a policy of direct engagement.
Sparrows’ due diligence prior to investing in an ETF or index fund does, however, take specific account of the fund manager’s own commitment to the Code (or equivalent depending on jurisdiction) and the nature of their engagement and voting policies with regard to companies in which their funds invest.
Given both Sparrows’ and the ETF or index fund provider’s index tracking requirements, there is very limited scope for stewardship through selective allocation or de-allocation decisions. For this reason, Sparrows’ analysis focuses on stewardship through engagement and through the exercise of voting rights.
Copyright, Trademarks and Other Rights
Copyright and trademarks and all similar rights in this site are owned by Sparrows, or relevant third-party content providers. You may use the information on this site and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means – electronic, mechanical, photocopying, recording or otherwise – without the prior written permission of Sparrows.
Complaints
Any complaints about the Sparrows service or website should be directed to:
The Compliance Officer, Sparrows Capital Limited, Office 7, 35-37 Ludgate Hill, London, EC4M 7JN
If we are unable to resolve the matter to your satisfaction, you may have access to the Financial Ombudsman Service. The Financial Ombudsman Service’s website is at http://www.financial-ombudsman.org.uk/
Background
These are the Pillar 3 disclosures made by Sparrows Capital Limited (“Sparrows”) in accordance with the UK Financial Conduct Authority’s (“FCA”) Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”).
The European Union Capital Requirements Directive (“CRD”) created a regulatory capital framework consisting of three ‘pillars’ namely:
Pillar 1 – sets out the minimum capital requirements that firms are required to meet;
Pillar 2 – requires firms to take a view on whether additional capital should be held against capital risks not covered by Pillar 1; and
Pillar 3 – requires firms to publish certain details of their risks, capital and risk management process.
Disclosure policy
The rules in BIPRU 11 provide that Sparrows may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where Sparrows considers a disclosure to be immaterial, this will be stated in the relevant section.
Sparrows is also permitted to omit one or more of the required disclosures where it believes that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine Sparrows’ competitive position. Information is considered to be confidential where there are obligations binding Sparrows to confidentiality with its clients and counterparties.
Where Sparrows has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.
Unless stated as otherwise, all figures contained in this disclosure are based on Sparrows’ audited annual reports for the year ending 31 December 2025.
Frequency
These Pillar 3 disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of Sparrows’ Internal Capital Adequacy and Risk Assessment (“ICARA”) and its annual accounts.
Verification
The information contained in these disclosures has not been audited by Sparrows’ external auditors and does not constitute any form of financial statement.
Publication
Sparrows’ Pillar 3 disclosures are published on its website.
Scope and application of CRD requirements
These disclosures are made in respect of Sparrows, a BIPRU firm authorised and regulated by the FCA, providing financial advice and discretionary investment management services.
Risk management objectives and policies
Sparrows’ risk management policy reflects the FCA requirement that it must manage a number of different categories of risk. These include: liquidity; credit; interest rate; market; and operational risks.
Sparrows manages all cash and borrowing requirements to maximise potential interest income whilst ensuring it has sufficient liquid resources to meet the continued operating needs of its business. This is supported by a robust budgeting and forecasting process which has the full involvement of the senior management team.
The main credit risk for Sparrows relates to income from fees, the risk being that a client does not pay amounts due for services provided by Sparrows. In most cases, quarterly management fees are charged to clients based on a percentage of the client’s assets under management. Concentration risk is defined as the risk of loss of income through external changes having a disproportionate impact on overall income due to a reliance on revenue from certain sectoral, geographic areas and/or businesses. Credit risk concentrations include significant exposure to an individual client or group of clients and credit exposures to clients in the same economic sector or geographic region.
A significant proportion of Sparrows’ income is received from clients that are part of the same group as Sparrows’ major shareholders. This ongoing interest in the activities of Sparrows by the group mitigates the risk of the group jeopardising Sparrows’ income flow.
Sparrows is exposed to country risk as a number of clients are based in a non-European Economic Area country. As these clients are all high net worth or ultra-high net worth long-term investors with spare capital invested in globally diversified liquid financial instruments, the risk of being unable to meet unforeseen financial needs and payment of Sparrows’ fees is low.
Based on the analysis of concentration risk, the risk of non-payment of fees has been assessed as minimal.
Sparrows has no exposure to interest rate risk as it has no debt and no client cash deposits.
The main market risk for Sparrows relates to falls in value of assets under management following a market downturn, which would lead to lower management fees. To mitigate its market risk, Sparrows regularly analyses various different economic scenarios to model the impact of economic downturns on its financial position.
Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.
Major sources of potential operational risk include: Outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.
Sparrows operates a robust risk management process which is regularly reviewed and updated by its Board. The Board formally reviews all significant risk issues at least annually as part of the ICARA.
All senior members of staff bear responsibility for internal controls and the management of business risk as part of their accountability to the Board. All staff are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their senior member of staff.
Sparrows operates a simple business model. Accordingly, many of the specific risks identified by the FCA do not apply. For example, it has no material outsourcing arrangements and does not hold any client assets.
Capital resources
Pillar 1 requirement
In accordance with the FCA rule GENPRU 2.1.45R (calculation of variable capital requirement for a BIPRU firm), Sparrows’ capital requirement has been determined as being its fixed overhead requirement and not the sum of its credit risk capital requirement and its market risk capital requirement.
The Pillar 1 capital requirement for Sparrows was £688,000 as at 31 December 2025.
Pillar 2 requirement
Sparrows’ overall approach to assessing the adequacy of its internal capital is set out in its ICARA report. The ICARA involves separate consideration of risks to Sparrows’ capital, combined with stress testing using scenario analysis. The level of capital required to cover risks is a function of impact and probability. Sparrows assesses impact by modelling the changes in its income and expenses caused by various potential risks over a 1-year time horizon. Probability is assessed subjectively. In addition, Sparrows has reviewed the outputs of its risk reviews to quantify any risks identified. This has identified a number of key business risks, which (having reviewed the guidance in BIPRU 2.2.61-65) Sparrows has classified against the risk categories outlined in FCA rule GENPRU 1.2.30R.
Sparrows Pillar 2 capital requirement, which is its own assessment of the minimum amount of capital that it believe is adequate against the risks identified, has been assessed as greater than its Pillar 1 requirement.
There is a considerable surplus of reserves above the capital resource requirement deemed necessary to cover the risks identified.
Regulatory capital
The main features of Sparrows’ capital resources for regulatory purposes, as at 31 December 2025 are as follows:
| Capital item: | £000 |
| Tier 1 capital (called up share capital, share premium account, profit and loss account, externally verified interim net profits) | 1,157 |
| Total of Tier 2 and Tier 3 capital (broadly long and short term subordinated loans) | – |
| Deductions from Tier 1 and Tier 2 capital | – |
| Total capital resources, net of deductions | 1,157
|
Sparrows holds regulatory capital in accordance with the CRD. All such capital is classified as Tier 1 capital and is therefore of the highest quality.
Remuneration Code Disclosures
Sparrows is subject to the BIPRU Remuneration Code. This section provides further information on Sparrows’ remuneration policy.
BIPRU Remuneration Code Staff
Sparrows has identified, and maintains a record of, BIPRU Remuneration Code staff (“Code staff”), i.e. staff to whom the BIPRU Remuneration Code applies. This includes senior management and members of staff whose actions may have a material impact on Sparrows’ risk profile. All of Sparrows’ Code staff fall into the “senior management” category of Code staff (rather than the “risk taker” category) for the purposes of the BIPRU Remuneration Code.
Decision Making / Remuneration Committee
Sparrows does not have and is not required to have a Remuneration Committee. The Board is responsible for Sparrows’ remuneration policy including determining the framework and policy for remuneration and ensuring it does not encourage undue risk taking; agreeing any major changes in remuneration structures; reviewing the terms and conditions of any new incentive schemes and in particular, considering the appropriate targets for any performance related remuneration schemes; and considering and recommending the remuneration policy for senior staff taking into account the appropriate mix of salary, discretionary bonus and share based remuneration.
In determining remuneration arrangements, the Board will give due regard to best practice and any relevant legal or regulatory requirements including the BIPRU Remuneration Code.
Link between pay & performance
There is ostensibly a discretionary variable pay element to the Sparrows’ remuneration package.
Quantitative information on remuneration
The FCA rules require certain firms to disclose aggregate information on remuneration in respect of its BIPRU Remuneration Code staff broken down by business area, senior management and other Code staff, including “risk takers”.
Sparrows has only one business area – investment management & advice.
Sparrows has 4 Directors but no material “risk takers”. Director remuneration is agreed formally at Board meetings. The link between performance and pay is inevitable in a small firm, but Sparrows’ risk-averse strategy and robust risk management systems mitigate risks.
At Sparrows Capital we are committed to safeguarding and preserving the privacy of our visitors. This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you whilst you visit our site.
We do update this Policy from time to time so please do review this Policy regularly.
In running and maintaining our website we may collect and process the following data about you:
Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website.
We may gather information about your general internet use by using the cookies. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever.
You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.
We use the information that we collect from you to provide our services to you. In addition to this we may use the information to provide information to you that you request from us relating to our services and to inform you of any changes to our website or services.
In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing. By providing your personal data to us, you agree to this transfer, storing or processing. We do our upmost to ensure that all reasonable steps are taken to make sure that your data is treated and stored securely.
Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically. Sending such information is entirely at your own risk.
We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:
On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.
In accordance with the General Data Protection Regulation (GDPR) you have the right to access any information that we hold relating to you. Please note that a reasonable charge may be payable.
Cross-Device Tracking and Ad Targeting
We may engage in cross-device tracking and ad targeting to provide you with personalised advertising experiences across your devices. This means that we may collect information about your activities on our website and other online platforms, as well as on your various devices such as your computer, smartphone, or tablet. The information collected may include but is not limited to, your browsing history, interactions with advertisements, and device identifiers.
The purpose of cross-device tracking and ad targeting is to tailor advertisements to your interests and preferences, making them more relevant to you. This helps us to deliver a more personalised and engaging experience while also allowing us to measure the effectiveness of our advertising campaigns.
We may work with third-party advertising partners and service providers who assist us in delivering targeted advertisements. These partners may use cookies, web beacons, and other tracking technologies to collect information about your activities across different websites and devices to provide you with targeted advertisements.
You can opt-out of targeted advertising by adjusting your device settings or by using opt-out tools provided by third-party advertisers and ad networks. Please note that opting out of targeted advertising does not mean you will no longer see advertisements, but rather that the advertisements you see may be less relevant to your interests.
By continuing to use our website and services, you consent to the use of cross-device tracking and ad targeting as described in this Privacy Policy.
Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at info@sparrowscapital.com.