St James Place : Investment Administration Limited – Investment Firms Prudential Regime Regulatory Disclosures 2022

St. James's Place

Investment Administration

Limited

Investment Firms Prudential Regime

Regulatory Disclosures 2022

Table of Contents

1	Introduction	3
2	Background	4
3	Governance arrangements	5
3.1	Group governance	5
3.2	SJPIA entity-level governance	5
3.3	Inclusion and diversity policies	6
4	Risk management	7
4.1	Overview	7
4.2	Risk management structure and operations	7
4.3	Individual Capital and Risk Assessment (ICARA)	7
4.4	Risk appetite	8
4.5	Risk profile	8
4.6	Assessing the effectiveness of the risk management process	10
5	Own Funds	11
6	Own Funds Requirements	13
7	Remuneration	14
7.1	Approach to remuneration	14
7.2	Eligibility	15
7.3	Governance and oversight	15
7.4	Material Risk Takers ('MRTs')	16
7.5	Key characteristics of SJP remuneration policies and practices	16
7.6	Quantitative information	18

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• Introduction

This regulatory disclosure report for St. James's Place Investment Administration Limited ("SJPIA" or the "Company") has been prepared in line with the requirements of the Investment Firms Prudential Regime (IFPR), which came into force on 1 January 2022. These requirements are set out in chapter 8 of the MIFIDPRU section of the Financial Conduct Authority's handbook, and require us to report annually on our:

• risk management objectives and policies
• governance arrangements
• own funds and capital requirements
• remuneration policy and practices

This report has been prepared on a solo-entity basis for SJPIA, based on information as at 31 December 2022, and supplements information provided in the Company's Annual Report and Accounts for the year (the "Company Report & Accounts"), a copy of which can be found at https://find-and- update.company-information.service.gov.uk/company/08764231/filing-history.

SJPIA is part of the wider St. James's Place group of companies, headed up by St. James's Place plc (the "Group"), and relevant information about the Company's business is also provided in the Group's Annual Report and Accounts for the year ended 31 December 2022 (the "Group Report & Accounts"), a copy of which can be found at https://www.sjp.co.uk/shareholders/reports-presentation-and-webcasts.

Where appropriate we will refer readers to these additional documents.

This disclosure report has been reviewed internally and approved by the Board of SJPIA. It has not been externally audited, except to the extent that it reproduces information also included within the Company Report & Accounts or the Group Annual Report & Accounts.

These disclosures do not constitute financial statements and should not be relied upon in making judgements about SJPIA, or for any other purpose other than that for which they are intended.

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2 Background

St. James's Place plc

St. James's Place plc is a FTSE 100 financial advice business. We provide holistic financial planning and wealth management services, working in partnership to plan, grow and protect clients' financial futures. Our services are delivered exclusively by a team of 4,693 highly skilled advisers within the St. James's Place Partnership. We want our clients to feel confident about their finances, so we provide a broad range of products and services to meet their needs, both for today and for the future.

To complement the provision of sound, long-term financial advice we have a distinctive investment management approach, where we design and build our own range of investment funds and portfolios, but contract some of the world's best external managers to manage them.

We aim to give all of our stakeholders the confidence to create the future they want.

St. James's Place Investment Administration Limited

SJPIA is investment firm which administers investments in the Group's range of unit trusts, both UK UCITS funds and NURS funds, and acts as an ISA manager.

SJPIA is a wholly owned subsidiary of St. James's Place Wealth Management Group Limited, which in turn is a wholly owned subsidiary of St. James's Place plc (SJP), the ultimate parent company of the Group. An overview of the Group structure, and SJPIA's role within this, is included in the Strategic Report within the Company Report & Accounts.

SJPIA is domiciled in England and Wales (Company Registration No. 08764231) and its registered address is St. James's Place House, 1 Tetbury Road, Cirencester, Gloucestershire GL7 1FP.

SJPIA is authorised in the UK by the Financial Conduct Authority (FCA). Under the rules set out in the MIFIDPRU section of the FCA rulebook, SJPIA is classed as a "non-SNI MIFIDPRU investment firm" (i.e. it is not considered to be small and non-interconnected).

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3 Governance arrangements

3.1 Group governance

The business performance of each of the regulated entities within the Group, including SJPIA, is ultimately linked with that of the Group as a whole and the majority of risks impact more than one of the regulated entities. The governance structure is designed to reflect this high level of integration and interconnectedness, with the business of the Group being governed by a unified Group board committee structure for SJP plc.

The Board of directors of SJP plc (the "Group Board") is responsible for setting the risk appetite of the Group and approving the strategy. The Chief Executive (the "CEO") of SJP has appointed an executive board (the "Executive Board"), which supports him in fulfilling his responsibilities for:

• developing strategy
• communicating and implementing the Group's business plan objectives
• ensuring that resources are in place to achieve the strategy and objectives, and
• managing the day-to-day operational activities of the Group.

Each member of the Executive Board has individual responsibility for a number of divisions within the Group, providing smooth and effective reporting structures and delegations of authority. Additionally, the Group Board has delegated certain responsibilities to board committees, whose members are non- executive.

In line with the centralised governance structure, the key functions are organised as Group functions, ensuring consistent implementation of systems and procedures across the Group.

Further information on the Group Board and the Group's System of Governance is provided in the Corporate Governance Report within the Group Report & Accounts.

3.2 SJPIA entity-level governance

SJP's key governance, strategy, planning and risk management processes, and, to a large extent, senior operational management, operate at a Group level rather than at the level of the individual subsidiaries. However, the Group Board is cognisant of the fact that the subsidiary entities are subject to differing regulatory requirements reflecting the nature of their activities and domiciles, and due care and attention is also given to governance of the separate legal entities.

In particular, certain decisions and key matters must be considered directly by the Board of SJPIA. Such matters include:

• Those required by law (e.g. matters under the Companies Act 2006 (such as dividend payments) and accounting and auditing legislation (such as approving annual accounts));
• Those required by regulators (e.g. approval of relevant internal capital assessments and regulatory disclosures); and
• Other commercial matters the directors of SJPIA deem, in view of their fiduciary duties, they should consider directly (e.g. entering into key agreements).

SJPIA is not required to maintain its own entity level Nomination, Risk and Remuneration Committees; these committees operate at a Group level.

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