All disclosures, unless otherwise stated, apply as at 31 March 2024, in line with the Firms’ financial year end.  All disclosures are for RIL-UK on a standalone or company basis.

The disclosures are prepared on an annual basis solely for the purposes of complying with FCA requirements.  The disclosures have not been audited and do not form part of the annual audited financial statements of the Firm.  However, they are subject to internal review and verification and are approved by RIL-UK’s Board of Directors.  The Firm may consider it appropriate to publish updated disclosures more frequently should a significant change in business or operating environment require this.

RIL-UK’s disclosures are considered to be appropriate to its size and internal organisation, and to the nature, scope and complexity of its activities.

The Board of Directors is the ultimate decision-making body for the Firm. The Board defines the purpose and values of the Firm, develops the Firm’s business strategy, and is responsible for directing the Firm’s business and the management of risks that arise in the course of doing business. The directors meet regularly and are collectively responsible for ensuring that the Firm’s operations are aligned to the strategy, regulatory compliance requirements and good governance practices, including how the Firm will act fairly with all stakeholders.  The Board met formally circa four times during the financial year. Meetings are minuted and the Board has a schedule of regular and standing agenda items.

As at 31 March 2024, the number of external directorships held by members of the Board were as follows:

RIL-UK’s primary objective is to ensure that our clients’ wealth is preserved and developed in a sustainable manner.  We also aim to minimise both our client and stakeholder risks to the greatest extent possible and strive to achieve this by adopting a prudent and conservative approach to risk-taking.  This approach allows us to minimise our exposure to reputational, compliance and financial risks, whilst accepting a degree of other risks in pursuit of our objectives.

We recognise that our appetite for risk varies according to the business activity undertaken and that our acceptance of risk is subject to always ensuring that potential benefits are fully understood before any new services or products are made available.  At the same time, we seek to implement sensible measures to mitigate the associated risks of such services and products.

Our risk appetite is guided by the following principles:

• We have a lower risk appetite for investments in high-risk jurisdictions. Our focus is to invest in jurisdictions that have a stable political and economic environment, transparent legal systems and robust regulatory frameworks.  Our investment strategies follow robust processes with clear parameters and strong governance-led oversight.  We note that while certain opportunities in high-risk jurisdictions may offer higher returns, they also pose a greater risk to our clients’ wealth and business reputation.
• We prioritise the safety and security of our clients’ assets. We only work with trusted and recognised third-party banks, custodians and service providers in order to ensure that our clients’ assets are held securely and are protected against fraud, theft and other material risks.
• We strive to maintain a strong financial position within our business and believe that a robust and transparent capital and liquidity policy is essential for maintaining our clients’ trust and confidence. We will always maintain sufficient regulatory capital and liquidity to ensure that we can meet our financial obligations, even in times of economic stress.
• We have zero-risk appetite for cryptocurrencies. While we recognise that these assets may offer potential for higher rates of return, we believe that the risks associated with them are too great for our clients.  As such, we do not recommend, or invest, in these assets on behalf of our clients.

RIL-UK manages its business operations on a reasoned risk and return basis, which serves as a guideline for acceptable credit, market and liquidity risks.  We also consider risks related to cyber, climate, regulatory and operational matters in order to provide our clients with the highest levels of service and security.

The Firms’ capital management strategy is to maintain sufficient capital resources for its size and complexity of business both in the present and in order to facilitate future growth.

RIL-UK monitors its financial adequacy regularly undertakes a formal internal capital and risk assessment at least annually to identify and manager its principle risks and capital requirements in both business-as-usual and stressed scenarios. 

This assessment has been conducted in accordance with the FCA’s Internal Capital Adequacy and Review Assessment (ICARA) requirements and expectations.

In accordance with the overall financial adequacy rule, RIL-UK manages and monitors its principle risks and considers the impact of stressed scenarios on its requirements to determine the amount of own funds and liquid assets, in terms of both amount and quality, it requires to remain financially viable throughout the economic cycle and to address any material potential harm that may result from its ongoing activities.  It also considers the amount of own funds and liquid assets it would require if, for whatever reason, RIL-UK decided to wind down to ensure that this would be done in an orderly manner, minimising harm to consumers or to other market participants.