Disclosures

VAR Capital Limited – Stewardship Code AND Shareholder Rights Directive (SRD) Engagement Policy

Please click here for our Stewardship Code AND Shareholder Rights Directive (SRD) Engagement Policy

VAR Capital Limited – Complaints Policy

Please click here for our Complaints Policy

Website Disclaimer

The contents of this website are communicated by, and the property of, VAR Capital Limited (“VAR”) which is authorised and regulated in the UK by the Financial Conduct Authority (“FCA”) under reference 718558.

Products and Services

The information contained herein is current at the date of publication, but is subject to change without notice. VAR has expressed its own views and opinions on this website, and these may change without notice. This website is not directed at you if VAR is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use that would be contrary to local law or regulation. None of the information contained on this website is intended to constitute any offer to sell or an invitation or solicitation of an offer to buy any product or service by VAR and must not be relied upon in connection with any investment decision. Products or services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Accordingly persons are required to inform themselves of and observe any such restrictions. Nothing in this website should be construed as investment, tax, legal or other advice.

Risk Warning

Past performance is not necessarily a guide to future performance. The value of investments and the income of any financial instruments mentioned in the website may fall as well as rise, and investors may get back less than the amount originally invested. Fluctuations in exchange rates may have a positive or an adverse effect on the value of foreign-currency denominated securities and financial instruments. Certain investments involve an above-average degree of risk and should be seen as long-term in nature. The investment products and services described in the website may have tax consequences. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. You acknowledge that levels and bases of taxation may change, and that VAR does not provides tax advice. You should consult your own tax advisor in order to understand the tax consequences of the products and services described in the website.

VAR Best Execution Policy

Please click here for VAR’s Best Execution Policy.

Privacy and Data Protection

All information or data sent to VAR via this site, by email or in any other way connected with consulting this site will be handled in accordance with statutory and regulatory requirements. As a visitor to, or person using, this site, you hereby agree VAR and its relevant associated entities may record, retain and process any personal data that relates to you for the following purposes: the management of VAR clients, including new business prospects, management of the contractual relationship, the prevention of irregularities, generating statistics and tests and for marketing purposes for relevant financial products and services. VAR may ask you to provide your name and personal contact details if you wish to access tools and models via this site. Access to personal data gathered via this site is restricted to those persons who require this data in order to carry out their duties. You also agree that this data may be passed on to all entities associated with VAR for the same purposes or to other persons in order to comply with any statutory obligation or in the event of legal interests. VAR abides by the General Data Protection Regulation (“GDPR”). VAR will generally be a data controller in respect of your relationship with VAR. VAR may process your personal data ourselves or through others acting as data processors on our behalf. VAR may share your personal VAR data with a third party where this is required by law or where we have another legitimate interest in doing so. VAR may transfer your data to non-EEA countries, should we do so, unless an exemption applies, we will seek to put in place appropriate safeguards, such as the EU-approved standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EU and UK laws on data protection.

Copyright

The copyright and all other rights in all of the material on this website are owned by VAR or the material is included with the permission of the rights owner. The information contained in this website is intended solely for the use of the person who has accessed this information and may not be reproduced, distributed or published to any other person. You may copy material on this website for your own private or domestic use only. All other copying is prohibited.

Links to other websites

On this website you may be offered automatic links to other non-VAR websites. These links are provided only as convenience. VAR does not accept any responsibility for the content of those websites or your use or inability to use such websites, the owners of which do not necessarily have any link, commercial or otherwise, with VAR. The inclusion of any link does not imply affiliation, sponsorship, endorsement, verification or monitoring or approval by VAR of any information contained in any non-VAR website. You should also be aware that the terms and conditions of such website and the website’s statement relating to the collection and use of your personal information may be different from those applicable to your use of this website.

Disclaimer

It is the responsibility of the individual user to consider his or her legal and regulatory position in the relevant jurisdiction, the risks associated with trading such products and to ensure that the use of the content and the subsequent making of any investment does not contravene any such restrictions or applicable laws and regulations of any jurisdiction. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific security, index, report, opinion, advice or other content. This does not exclude or restrict any duty or liability that VAR has to its clients under the Financial Services and Markets Act 2000 (as amended from time to time) or any other regulatory system under the laws of applicable jurisdictions.

VAR, its subsidiaries, associated entities, directors, employees, representatives or suppliers will not be liable, on any grounds whatsoever, contractually or not, for any direct or indirect damage that may arise as the result of it being possible or impossible to gain access to this site, the accessing, visiting or use of this site and/or the information provided, the sending, or receiving of information via this site and/or the operation or non-operation of this site, except in the event of intentional or serious blame on its part. The information contained on this site, including any third party data is published in good faith and VAR believes that the information is accurate at the time of publication but no representation or warranty, express or implied, is made by VAR as to its accuracy or completeness and it should not be relied on as such.

VAR shall therefore have no liability, save for any liability that VAR may have under the UK Financial Services and Markets Act 2000, for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. Nor will VAR, its subsidiaries, associated entities, directors, employees, representatives or suppliers be, under any circumstances, liable for any corruption of data that may occur as the result of technical problems (e.g. transmission errors, technical failures, breakdowns, intervention of third parties, etc.) and/or for any damage or loss relating to software or hardware that is the result of any virus, defect or malfunction in relation to access or use of the site.

MIFIDPRU Public Disclosure 2024

Introduction

VAR Capital Limited (“VAR”) is authorised and regulated by Financial Conduct Authority (“FCA”) as MIFID Investment Firm. Given this, the Firm has to satisfy the FCA’s Overall Financial Adequacy Rule by at least annually carrying out an Internal Capital Adequacy and Risk Assessment (“ICARA”) process which formally documents how VAR assesses its own funds and liquidity requirements.  

Alongside the ICARA, the Firm is required to make at least an annual public “MIFIDPRU Public Disclosure” based on its audited financial statements for each financial year end.  This MIFIDPRU Disclosure is for the period to 31st March 2024.  

In terms of the FCA’s prudential rules, VAR’s relatively non-complex business model and limited scope of permissions means it is treated as a Small Non-Interconnected Firm (“SNI”). Therefore, the FCA rules allow the Firm to apply proportionality in terms of the information provided in its disclosures. 

As VAR meet its Own Funds requirement exclusively through the use of Common Equity Tier 1 capital (“CET1”), it is only required to make a disclosure on its remuneration policies and practices.   

Remuneration Policy & Practice

VAR adheres to the MIFIDPRU Remuneration Code (FCA Handbook SYSC 19G) and is entitled to apply the remuneration proportionality rule.  

Qualitative Disclosures

VAR’s Board also act as the Remuneration Committee and is responsible for the Firm’s remuneration policy. They approve and ongoing oversight with the aim of ensuring that all remuneration is consistent and fully supports decision making and performance that promotes adherence to the Firm’s overall risk appetite.

The Board believe their Remuneration Policy is proportionate and appropriate for the size and complexity of the business as it supports and encourages individual and corporate performance which delivers sounds risk management and the best outcomes for clients, counterparties and the market.  It uses financial and non-financial criteria when assessing individual remuneration.

As with all organisations VAR uses financial incentives (such as changes in overall compensation and benefits like bonuses) as part of its Remuneration Code to reward employees fairly and as a tool to retain and recruit staff.  It is also used to encourage and reward high standards of personal and professional conduct and support sound risk management.

The Firm utilises external consultants who provide an independent third-party review for the purpose of assisting in the maintenance of the Remuneration Policy. 

1. Qualitative Disclosures

In the financial year ending 31st December 2023: