Regulatory Information and Disclaimer

Oakham Wealth Management Ltd is authorised and regulated in the UK by the Financial Conduct Authority (FCA No. 431206).  It is a limited liability company registered in England and Wales with number 05281855.  The firm’s registered offices are at Berkeley Square House, London W1J 6BD, UK.

The value of your investments and the income derived from them may go down as well as up.  You may not receive back your original investment.


As a regulated entity, and as part of our commitment to maintain market integrity, we believe in prioritising the interests of our clients.  We endeavour to resolve complaints fairly, courteously, and as quickly as possible.  This is in accordance with our complaints procedures and policies.   Copies of the firm’s complaints procedures are available via the link below.

If you have a Complaint

If you have a complaint regarding the service you have or have not received from us, please contact us.  You should email us at  Alternatively, please click on the link below for our complaints procedure.  This includes details of how to contact us in writing and who to contact in the event that your complaint is not resolved satisfactorily.

complaints procedure ›

Best Execution Monitoring Report

For the period 01/01/2018 to 31/12/2018, direct client trades were executed via Credo Capital Ltd.  This applies to trading in funds, equities, debt instruments, exchange traded products.

Credo Capital’s LEI is 213800NP668Y18LISX10.  Details of their Execution Policy and RTS28 Report can be found by following the link:

As part of our ongoing due diligence we regularly monitor the quality of execution provided by Credo Capital.
In selecting Credo Capital as our outsource partner the following factors were considered in relation to best execution:
– Access to multiple venues and markets
– Systems capabilities to facilitate speed of execution
– Expertise in order execution
– Proven track record in provision of best execution

Voting Rights Policy

UK Stewardship Code

June 2019

Policy Statement
This policy statement is designed to ensure that Oakham Wealth Management Ltd (‘Oakham’ and the ‘Investment Manager’) complies with all regulatory requirements relating to the exercise of voting rights and the appropriate recording and communication where these voting rights have been exercised.

COLL 6.6A.6R requires any investment manager of a UCITS scheme to have documented procedures for exercising voting rights of the assets held in the scheme.

This includes:
• identifying and responding to corporate events (e.g. rights issues in shares);
• deciding how and when voting rights should be exercised;
• ensuring that it is in accordance with the investment objectives and policy of the fund; and
• preventing or managing any conflicts of interest arising from the exercise of voting rights and acting in the exclusive interest of the fund and its investors.

Voting Strategy

Client trades are executed via Credo Capital, and their Stewardship Code can be found here:

Oakham also manages four UCITS compliant fund of fund OEICs as follows:

FP SCDavies Global Equity Fund
FP SCDavies Global Alternatives Fund
FP SCDavies Global Fixed Income Fund (Inc)
FP SCDavies Global Fixed Income Fund (Acc)

Given the nature of a fund of funds, it is rare for Oakham to be invited to vote. The vast majority of the investments are made via managed funds rather than direct into companies. Clearly the only occasions when Oakham are able to vote are when investments are made directly into the shares of a company, and this is rare.

However, on the occasion when Oakham does have the ability to vote, the investment managers may choose not to vote. If the managers did choose to vote, they would do so as they see fit – in line with general corporate governance and voting policy. If a vote is cast, appropriate records will always be retained showing, for each vote, the nature of the vote and how it was exercised with appropriate explanation.

Oakham, through its investment managers, owns the exercise of voting rights and it is the responsibility of the CEO to ensure that the Voting Rights Policy is maintained and updated if required.

The Authorised Corporate Director (‘ACD’) will be responsible for any updates that are required with respect to:
• the Prospectus;
• the Investment Management Agreement; and
• the Simplified Investor Document / Key Investor Information Document.

Periodic Review / Governance
Oakham is responsible for ensuring that the Voting Rights Policy and any voting instructions applied are reviewed at least annually and more frequently depending on regulatory changes or changes in business activity.

Management Reporting and Monitoring
Oakham, through its investment managers, is responsible for:
• monitoring relevant corporate events;
• ensuring that the exercise of voting rights is in accordance with the investment objectives and policy of the relevant UCITS; and
• preventing and managing any conflicts of interest arising in the exercise of voting rights (see also the Oakham’s Conflicts of Interest Policy).

Monitoring of these reports and resulting actions will be undertaken periodically during the year by The Authorised Corporate Director (‘ACD’).

The monitoring approach will be to:
• confirm that the Investment Manager do have an appropriate policy and that this is regularly reviewed and updated;
• confirm what internal governance and reviews are done to ensure that the Investment Manager follows the policy; and
• ensure that the Investment Manager maintains retrospective records of the results of the voting policy for review by The Authorised Corporate Director (‘ACD’).

Escalation Route
In the event of any problems arising from the implementation or practice of the Voting Rights Policy, the ACD will be contacted immediately.

This document will be made available to investors on request. Details of any actions taken as a result of this policy should also be made available, free of charge, to any investor requesting them. It is the responsibility of the Compliance Officer at Oakham to provide such information.

Products Covered by this Policy
The Voting Rights Policy covers all regulated collective investment schemes (UCITS) managed or advised by Oakham.

Conflicts of Interest Policy

1 Purpose
This policy details how Oakham Wealth Management (the Firm) will identify, prevent and manage conflicts of interest in respect of its business activities.

The Firm is authorised by the Financial Conduct Authority (FCA) and, as such, will act in accordance to the Conflicts of Interest rules as defined in the FCA Handbook, which will take precedence over the requirements of this policy.

2 Review of Policy
This policy will be reviewed regularly, at least once a year, and amended as considered necessary by the Firm’s Management Body in the event of changing circumstances or regulations.

3 Responsibilities
The CEO of the Firm is responsible for ensuring that its systems, controls and procedures are able to identity, manage and control or prevent any potential and actual conflicts of interest that may arise.

4 Definition
A conflict of interest is a situation in which someone in a position of trust to the client has competing professional or personal interests. Such competing interests can make it difficult for individuals to fulfil their duties to their clients impartially. A conflict of interest may exist even if no unethical or improper act results from it.

Conflicts of interest arise when in the course of providing a service to a client, the Firm, its appointed representatives or its employees:
• Are likely make a financial gain or avoid a loss at the expense of the client
• Have an interest in the outcome of the service provided which is distinct from the client’s interest
• Have a financial or other incentive to favour the interests of another client over the interests of the client
• Carry on the same business as the client
• Receive, from a person other than the client, an inducement in relation to the service provided to the client, other than the standard commission or fee for that service

5 Identifying, managing and preventing conflicts of interest
The Firm has reviewed its business model and has identified the following potential conflicts of interest:
• Employee Roles and Responsibilities
• Management of Employees
• Remuneration
• Business interests
• Connected persons
• Means and Timing of Research
• Inducements including Gifts and Hospitality
• Personal account dealing
• Customer orders versus firm business or other customers orders
• Handling confidential and insider information flows
• Multiple responsibilities assigned to single managers due to the size of the company
The Firm will regularly review its business model to ensure any new potential conflicts of interest are noted and managed or prevented effectively.

5.1 Employee Roles & Responsibilities
As far as possible in an investment boutique, the firm maintains a clear segregation of roles and responsibilities within the Management Body to maintain an effective control environment and to avoid conflicts of interest in roles wherever possible. The governance structure is as follows:

Role Responsibilities:

CEO – Paul Denley

  • Corporate Strategy
  • Company Finances
  • Compliance Oversight
  • Anti Money Laundering Function
  • Client Relationship management
  • Human Resources Oversight

Associate Director – Richard Morrison

  • Investment Management
  • Investment Administration

5.2 Supervision and Management of Staff
Staff will be based in the London Office. Due to the number of UK based employees, it is not possible to physically segregate staff with access to sensitive data that may give rise to conflicts of interest at this time, however, as the business grows the requirement to establish such controls will be considered.
Employees involved in carrying out activities or providing services to clients will have a different management reporting line to employees carrying out activities or providing services to other clients who have different, potentially conflicting interests or activities for the Firm itself.
Employees will receive training on understanding their obligations in this area.

5.3 Remuneration
The remuneration of staff will be assessed annually in accordance with the Firm’s Remuneration Policy and appraisal process and will consist of a base salary review and sometimes a review of performance related variable compensation. The Firm strives to ensure our employees remain motivated whilst at the same time ensuring that this remuneration scheme does not encourage inappropriate behaviour. In order to prevent a conflict of interest, the remuneration of employees is not directly linked to sales and the remuneration structure takes into account a number of different factors including a good standard of compliance. The Firm’s Remuneration Policy is in place and will be adhered to.

5.4 Business Interests
The Firm recognises that our current and future employees may have an interest, relationship or arrangement whereby they act as a trustee, hold power of attorney or have a Directorship that may potentially create a conflict of interest. The Firm requires its employees to declare any such interests and will take the appropriate steps to manage or prevent any conflicts of interest that are identified. To manage such conflicts, the Firm requires its employees to disclose Directorships and interests in other companies and to disregard the interest, relationships or arrangements concerned when acting on behalf of clients.

5.5 Connected Persons
The Firm is aware of its duty to avoid a conflict of interest arising where an employee has an indirect interest through a connected person (e.g. adult child or spouse). Relevant employees are required to disclose any potential conflicts of interest through connected persons. To manage such conflicts the Firm requires its employees to disclose the interests and to disregard the interest when acting on behalf of clients. A register of these interests will be kept and will be updated regularly.

The Firm is not aware of any such conflicts at this time.

5.6 Inducements including Gifts and Hospitality
The Firm has a strict policy, which specifically prohibits employees from soliciting or accepting any inducements to conduct business in a specific manner that would give rise to a detriment to a client or to favour the interests of one client over another.

The Firm recognises that Gifts and Hospitality can lead to potential conflicts of interest. Employees are not permitted to accept, or give to, any person any gift or other benefit that cannot properly be regarded as justifiable in all circumstances or may give rise to the perception that in doing so, decisions may be influenced or may not be impartial. All employees are expected to act with the highest standards of integrity to avoid any allegations of conflicts of interests.

The Firm requires any employee who is offered any kind of gift or payment over an agreed limit from either inside or outside the Firm to report this to the Firm’s Nominated Officer for recording on the Gifts & Hospitality Register. In addition, any indications of expectation of support following a gift or hospitality of any value should be reported to the Nominated Officer.

The Nominated Officer will regularly review the Gifts & Hospitality Register to identify any conflicts of interest that may be occurring.

The Firm’s Gifts and Hospitality Policy contains further information and the agreed value limits set by the Management Body.

5.7 Personal Account Dealing Procedures
The Firm recognises that employees dealing on their own personal account may present conflicts of interests. The Firm is a Discretionary Investment and Fund Manager. In order to manage actual or potential conflicts that may arise from personal account dealing, the Firm has Personal Account Dealing Procedures in place.

5.8 Customer Orders
The Firm’s Order Execution Policy requires employees to take all reasonable steps to achieve the best overall trading result for clients; to exercise consistent standards; and operate the same processes across all markets, clients and financial instruments in which it operates.

The Firm’s Client Order Handling Policy explains how the Firm will handle client orders in relation to other clients’ orders and its own trading interests.

There may be occasions when clients’ orders may have a material effect on a relevant price. In order to ensure that a broker does not take advantage of the situation by dealing on his/her own account or encouraging a third party to deal, the Firm has a strict “no front running” policy.
In order to ensure a fair and orderly dealing environment within the market, the Firm requires its employees to comply with its Market Conduct Policy, as well as the relevant FCA Rules, which aim to prevent insider trading, the misuse of information and market manipulation.

5.9 Handling confidential & inside information flows
The Firm regularly receives handles and generate large amounts of confidential and inside information. In order to ensure that in no circumstances the clients’ interests are damaged and/or create adversely affected the Firm has designed and implemented adequate systems and controls to prevent the misuse of this information.

5.9.1 Insider List
The Firm has drawn and maintain a list of all persons who have access to inside information including those that have been made insider whereas not in the course of their employment and persons providing services to the Firm.
It has also drawn and maintains a list of all financial instruments/transactions the Firm know or ought to know to be inside information and any other it considers to be relevant to prevent and manage existing or potential Conflict of Interest.

The list is maintained and regularly updated by Compliance and is communicated to the Firm management body as appropriate.

5.9.2 Need-to-know principle
Need-to-know principle is a frequently used principle in the financial industry that includes the obligation for staff to only share confidential and inside information where certain criteria are met to ensure and/or mitigate the risks of (i) market abuse and inside dealing, (ii) prevent or manage appropriately conflicts of interest and (iii) preserve clients interest and personal data.

Where sharing such data/information all staff have to ensure that:
• The disclosure of confidential and inside information shall be accompanied by the imposition of confidentiality requirements on to whom the disclosure is made; and
• The disclosure is reasonable and shall enable the person to perform the proper functions of his/her employment, profession or duties; or
• The disclosure is reasonable, including for the purpose of facilitating any commercial, financial or investment transaction.

5.9.3 Information barriers
The Firm has implemented strict information barriers or “Chinese walls”. They may be tangible such as physical separation between different business lines (including desks located in different rooms) or intangible where accesses to specific files/data are controlled and accessible to only designated staff or granted on case by case basis by senior management and/or Compliance for a determine period of time.

6 Recording conflicts of interest
The Firm will record all conflicts of interest that arise, or may arise, on the Conflicts of Interest Register (Annex 1). It will be updated on a regular basis. The register will include the way the Firm prevents of manages the conflicts and the person responsible. The Register will be organised by business lines, services or activities carried out.
The Conflicts of Interest Register will be provided to the Management body for review at least annually.

7 Disclosure or declining to act
For conflicts of interest that the Firm cannot manage or prevent, the Firm will either inform the client or decline to act for the client.

7.1 Disclosure
As a last resort, where there is no other means of managing the conflict or where the measures in place do not, in the view of the Firm, sufficiently protect the interests of clients, the conflict of interest will be disclosed to clients, to enable an informed decision to be made by the client as to whether they wish to continue doing business with the Firm in that particular situation. The Firm must disclose to the client the general nature ort sources of conflicts of interest and the steps taken to mitigate those risks. The disclosures will be recorded on the Conflicts of Interest Disclosure Register.

The disclosure will be in writing and will include:
• A statement that the arrangement in place by the Firm are not sufficient to ensure that the risk of damage to the interests of the client will be prevented
• A description of the specific conflict of interest taking into account the nature of the client or group of client to whom the disclosure is made
• An explanation of the general nature and sources of the conflicts of interest, the risks to the client that arise as a result of the conflict of interest and the steps undertaken to mitigate those risks
• Sufficient detail to enable the client to make an informed decision as to whether to proceed or not.

7.2 Declining to Act
Where the Firm considers that it is not able to manage the conflict of interest in any other way, it may decline to act for a client.

8 Breaches of Conflicts of Interest Policy
Any breaches of the Conflicts of Interest rules will be recorded on the Firm’s breach log in conjunction with its Regulatory Breach policy.

Pillar 3 Disclosure

1 Introduction
Firms are required under the Senior Management Arrangements, Systems and Controls (SYSC) manual of the Financial Conduct Authority Handbook to have in place robust governance arrangements and effective procedures which allow it to identify, manage, monitor and report the risks it is or might be exposed to.

Oakham Wealth Management is authorised and regulated by the Financial Conduct Authority and this document sets out how the Firm complies with its obligations to identify, manage and mitigate risks.

2 Overview
The Capital Requirements Directive (‘CRD’) of the European Union created a regulatory capital framework across Europe governing how much capital financial services firms must retain. The rules are set out in the CRD under three pillars:

  • Pillar 1 sets out the minimum capital resource requirement firms are required to maintain to meet credit, market and operational risks
  • Pillar 2 requires firms to assess firm-specific risks not covered by Pillar 1 and, where necessary, maintain additional capital
  • Pillar 3 requires firms to disclose information regarding their risk assessment process and capital resources with the aim to encourage market discipline by allowing market participants to assess key information on risk exposure and the risk assessment process.

The rules in the FCA Prudential Sourcebook for BIPRU sets out the requirements for a Pillar 3 disclosure. The document is designed to meet Oakham Wealth Management’s Pillar 3 Disclosure obligations.

2.1 Frequency and location of disclosure
Future disclosures will be issued on an annual basis once they have been reviewed and approved by the Director. The disclosures are not subject to audit except where they are equivalent to those prepared under accounting requirements for inclusion in the financial statements.

The report and all future ones will be published on our Firm’s website.

2.2 Scope of disclosure
Oakham Wealth Management predominantly provides discretionary investment management and advisory services to customers categorised as Retail Clients and Professional Clients. The Firm is classified as a BIPRU Firm as it carries out the activity of portfolio management and investment advice but does not provide safekeeping and administration of financial instruments.

3 Governance Arrangements

3.1 The Management Body
The Director is responsible for the Firm’s risk management governance structure and how the Firm’s risk exposure must be managed in line with the Firm’s overall business objectives and within its stated risk appetite. This includes the governance of the process for identifying, evaluating, managing and reporting the significant risks faced by the Firm.

The Director is ultimately responsible for ensuring that the Firm maintains sufficient capital and liquidity resources to meet its regulatory capital and liquidity requirements and to support its growth and strategic objectives. Risk management is embedded throughout the business, with the overall risk appetite and risk management strategy approved by the Director propagated down throughout the business as appropriate.

4 Capital Adequacy and ICAAP
The Firm’s overall approach to assessing the adequacy of its internal capital is documented in the Internal Capital Adequacy Assessment Process (“ICAAP”).

The ICAAP process includes an assessment of all material risks faced by the Firm and the controls in place to identify, manage and mitigate these risks. The risks identified are stress-tested against various scenarios to determine the level of capital that needs to be held.

Where risks can be mitigated by capital, the Firm has adopted the CRD requirements for Pillar 1. Where the Director considers that the Pillar 1 calculations do not adequately reflect the risk, additional capital is added on in Pillar 2.

Whilst the ICAAP is formally reviewed by the Director once a year, although risks are reviewed and the required capital more frequently and will particularly do so when there is a planned change impacting risks and capital or when changes are expected in the business environment potentially impacting the ability to generate income.

4.1 Capital Resources
The Firm is a BIPRU firm because it manages individual portfolios and funds and provides investment advice and does not provide safekeeping and administration of financial instruments or deal in any instruments on its own account.

A BIPRU firm must maintain at all times capital resources equal to or in excess of the base requirement (€50K). The Pillar 1 capital requirement for a BIPRU firm is the higher of:

1. Base Capital Requirement OR
2. Credit Risk plus Market Risk plus Counterparty Risk Capital Requirements OR
3. Fixed Overhead Requirement

The Firm has no innovative Tier 1 capital instruments or deductions.

The Firm must maintain at all times capital resources equal to or in excess of the Pillar 1 requirement. During the 12 month accounting period to 31st October 2018 the Company complied fully with all capital requirements and operated well within regulatory requirements. At the accounting reference date, the Firm held the following capital position:

Amount (£ 000’s)
Ordinary share capital = 213
Share Premium = 42
Other Reserves = 0
Retained Earnings = -68
Regulatory Adjustments = 0
Core Tier 1 Capital = 188
Tier 2 Capital = 0
Total Capital Resources = 188
Credit Risk Capital Requirement @ 8% = 21
Market Risk Capital Requirement @8% = 0
Fixed Overhead Requirement = 96
Base Capital Requirement = 43
Total Pillar 1 Requirement = 96
Total Pillar 2 Requirement = 0
Total Capital Requirement = 188
Surplus capital over minimum requirement = 88

The Director is therefore comfortable that the Firm is, and has been throughout the financial year, adequately capitalised for Pillar 1 purposes. The Firm holds approximately £84,000 in cash and cash equivalents as at year end. The Director is comfortable that this will ensure prudent capitalisation and cover for market downturns and other risks that may materialise in the short to medium term.

The Director constantly monitors the performance of the Firm and capital adequacy is regularly assessed by them. The Firm will also monitor risks throughout the year and decide if additional capital should be held against them. Additional risks that supplement the Pillar 1 requirements are detailed below and, where necessary, additional capital will be provided.

5 Management of Risk Framework

5.1 Risk Profile
Oakham Wealth Management has identified the following core risk categories: Strategic, Credit Risk, Market Risk, Operational Risk, Liquidity Risk and Reputational Risk.

Oakham Wealth Management profile of these risks is continually evolving and is generally driven by:

Changes to the market in which we operate;

  • Oakham Wealth Management strategies and business objectives and;
  • Oakham Wealth Management business/operating models
  • Oakham Wealth Management will seek to generate positive returns through carefully considered risk taking and robust risk management. As such the effective management and control of both the upside of risk taking and its potential downside is a fundamental core competency of the Firm.

5.2 Risk Appetite
The Director is responsible for setting the Firm’s risk appetite, defining the type and level of risk that the Firm is willing to accept in pursuit of its business objectives.

5.3 Risk Assessment Framework
The Director is responsible for approving the Risk Assessment Framework, which is used to ensure that the Firm has a comprehensive understanding of its risk profile, including both existing and emerging risks facing the Firm, and to enable it to assess the adequacy of its risk management in the context of the Firm’s risk appetite.

Strategic Risk

  • Principal Risks: The risk that arises decisions that fail to reflect the full business operating environment and the impact of failing to adequately identify changes to the business model.
  • Appetite: The Firm will remain competitive by identifying opportunities and assessing the risks, rewards and costs associated with them before proceeding
  • Key Drivers: Regulatory landscape impacting the business. Commercial/market conditions. Internal business/operating model
  • Mitigation: Due diligence is carried out prior to any new business opportunity and a full assessment of the potential and actual risks taken into account. Appointment of external compliance consultants

Credit Risk

  • Principal Risks: The risk of financial loss due to the failure of a creditors to meet their obligations to settle outstanding amounts
  • Appetite: The Firm is exposed to credit risk on receivables from third parties, all relating to management and performance fees, and exposure to banks where the Firm maintains deposits.
  • Key Drivers: Market conditions. Client and third parties credit worthiness
  • Mitigation: Creditors are monitored monthly. The Firm uses the standardised method of calculating Credit Risk

Market risk:

  • Principal Risks: Risk of losses in on and off balance sheet positions arising from adverse movements in market prices
  • Appetite: The Firm does not engage in propriety trading and does not actively seek market exposure.
  • Key Drivers: Volume and complexity of trading. Market movements. Liquidity
  • Mitigation: The firm does not have any positions nor hold any other currency aside from GBP sterling. If it ever did the firm would use the standard calculating for market risk

Liquidity Risk

  • Principle Risks: The risk that the Firm does not have sufficient liquid resources or is unable to deploy such resources to meet its actual or potential obligations in a timely manner as they fall due
  • Appetite: The Firm will have sufficient and accessible financial resources as to meet any financial obligations as they fall due
  • Key Drivers: Operational risk. Credit risk events. Internal business operating model
  • Mitigation: The firm will periodically review its financial resources and have contingency funding arrangements in place.

Operational Risk

  • Principal Risks: The risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events
  • Appetite: The Firm will actively identify and manage the risk of its people, processes or systems failing. Operational risk is inherent in any business however the Firm will take steps to prevent such risks from increasing operating costs
  • Key Drivers: Internal business operating model. External threats. Market conditions
  • Mitigation: All employees are provided training and guidance on their obligations and significant human and resources are in place to mitigate exposure in this area.


  • Principal Risks: The risk arising from defective transactions, failing to take appropriate measures to protect assets, changes in law and claims resulting in a liability or loss to the Firm.
  • Appetite: The Firm will appoint external legal advisors however the Firm does not have any appetite for legal breaches
  • Key Drivers: Regulatory regime. Legislative framework
  • Mitigation: The firm regularly monitor changes in law and the implications to the Firm

Reputational Risk

  • Principal Risks: The risk of loss resulting from damages to a firm’s reputation.
  • Appetite: The firm ensure the clients understand the methodology of our process and having a clear long term plan.
  • Key Drivers: Conduct of Business. Operational Risk
  • Mitigation: All clients are provided with full disclosure as to the extent of its services and the methodology.  The firm carefully screen our advisor partners to ensure the quality of and customer service is in line with our offering.

6 Remuneration Policy
Oakham Wealth Management Remuneration Policy complies with the Remuneration Code in relation to its size, nature, scope and complexity of our activities.

The Policy is aligned to the Firms’ business strategy, objectives, values and long term interests in respect of performance and effective risk management in line with the Firm’s risk appetite.

A copy of the Firm’s Remuneration Policy is available via our website and sets out how the Firm complies with the Remuneration Code.