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SUPPLY CHAINS IN BULK COMMODITY TRADE FINANCE
How can the role of alternative credit providers help prevent a Trade Finance crunch post pandemic? What lessons can be taken away from the last Global Financial Crisis (GFC)?
Commodity Trade Finance and the Evolving Role of Investment Banks
How to fill the trade finance gap in the global oil industry
Closing The Gap

Audentia Capital Management LLP
20 Arlington Street, London, SW1A 1RG
0203 927 8900
info@audentiaglobal.com

Privacy Policy

Privacy notice

The following privacy notice (the “notice”) is issued by Audentia Capital Management LLP and any holding company or subsidiary company as defined in section 1159 of the Companies Act 2006, referred to in this notice as “we”, “our”, “us” or “Audentia”, for Audentia and any fund to which Audentia has been appointed as investment manager.

For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). Audentia is responsible for ensuring that it uses your personal data in compliance with all applicable data protection laws and regulations.

Our Privacy Officer can be contacted using the details in the “Contact us” section below.

This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read and understand this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect from you

We will collect and use the following personal data about you and your representatives:

Information you give us

This is information about you (and your financial adviser/representative or beneficial owner which may include a child for whom you have parental responsibility, if applicable) that you (and/or your financial adviser/representative, if applicable) give us by filling in forms or by corresponding with us by phone, e-mail or otherwise.

We collect this information from you through various means, including, but not limited to, when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates^[1] or other non-affiliated companies.

The information you give us may include name, address, e-mail address and phone number, financial information, credit history, identification records.

Information we collect or generate about you and your representatives

We sometimes record telephone conversations and monitor email communications to resolve complaints, improve our service and to comply with our legal and regulatory requirements. We generate data to improve our service and to manage, administer and take decisions about your account. The information we capture in this way may include your name, address, e-mail address and phone number, financial and debit card information, credit history and identification records.

Information we receive from other sources

Verifying your identity – We will use information provided by third parties (e.g. fraud prevention agencies) when verifying your identity and when carrying out anti-money laundering checks. Such information may include some details about any criminal convictions and any allegations regarding criminal activity that relate to you, as well as details of your status as a politically exposed person. It may also include your nationality and identification records (e.g. passport information).
Intermediaries – We may receive information from dealers, brokers and introducers for the purposes of entering into and administering your agreement. This may include your name, address, e-mail address and phone number, financial and debit card information, credit history and identification records.
Public databases – We may obtain information about you from public databases.

How we use your personal data

Your personal data may be used by us in the following ways:

Background checks

To verify your identity as part of our client onboarding process
To detect and prevent fraud and money laundering
To identify politically exposed persons

Products and services

To manage and administer your accounts and holdings
To provide you with information on products or services where you have provided your consent to do so (to the extent such consent is required by law)

Reasons we might process your personal data

We will process your personal data in line with one of the following legal bases:

To perform our obligations under our contract with you
To comply with our legal and regulatory obligations
To establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings
For the prevention of fraud
Use of your personal data as described is necessary for our legitimate business interests such as:
- Enforcing the terms and conditions of any agreement we have with you
- The recovery of outstanding debts existing under an agreement with you
- To send promotional information about our products and services via the methods you specify (where you have provided consent to do so)

Sharing your personal data

We may disclose your personal data within Audentia and to third party service providers in the circumstances described below:

To ensure the delivery of products or services to you
To ensure the safety and security of our data
For internal research and statistical analysis purposes

We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.

We may also share your personal data outside of Audentia

We may also share your personal data outside of Audentia under the following circumstances:

To enforce or apply the terms of use and other agreements you have with us
With an insurer or insurers for administration, claims handling and fraud prevention (which could include passing it to other insurers)
With any broker or introducer of an agreement with us
With tracing and repossession agents
If we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes
If we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer
With third party agents for the purposes of providing services to us

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.

We may also share your personal data outside of Audentia to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including disclosures made to credit agencies and Companies House), and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area

The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for a company in Audentia or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

The recipient of the data might be a signatory to binding corporate rules
The country that we send the data to might be approved by the European Commission or a relevant data protection authority
The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data
Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases we will ensure that any transfer of your personal data is compliant with data protection law.

How long we keep your personal data

How long we hold your personal data will vary. The retention period will be determined by various criteria including:

The purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose
Legal obligations – laws or regulation may set a minimum period for which we have to store your personal data

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you
The right to withdraw your consent to our processing of your personal data at any time. Please note that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so

In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us

The right to request that we rectify your personal data if it is inaccurate or incomplete
The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it
The right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request
The right to object to our processing of your personal data where we process your personal data in line with our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request
The right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request
The right to object to the processing of your personal data for direct marketing purposes
The right to lodge a complaint with the data protection regulator (details of which are provided below), if you think that any of your rights have been infringed by us

You can exercise your rights by contacting us using the details set out in the “Contact us” section below.

You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching its website at https://ico.org.uk/.

Changes to our privacy policy

We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact us

We are registered in the UK and our registered address is: 20 Arlington Street, St James, London, SW1A 1RG.

Please contact us if you have any questions about our privacy policy or personal data we hold about you.

Write to us at: Audentia Capital Management LLP, 20 Arlington Street, St. James’s Street, London, SW1A 1RG

By telephone: 020 3927 8900

By email: info@audentiaglobal.com

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Pillar 3 Disclosure

Introduction

The following disclosures are provided in accordance with the Pillar 3 disclosure rules set out by the Financial Conduct Authority (“FCA”) in section 11 of its Prudential sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”). The Capital Requirements Directive (“Directive”) of the European sets out the regulatory capital adequacy standards and the associated supervisory framework across the European Union which represents the European Union’s application of Basel II. The Directive has been implemented in the UK by the FCA in BIPRU and the General Prudential Source book (“GENPRU”).

The FCA framework comprises of three pillars:

Pillar 1: sets out the minimum capital requirements for credit, market and operational risk.

Pillar 2: requires a firm to assess whether it needs to hold additional capital over and above that needed to satisfy Pillar 1 in order to protect against risks which the firm is, or may be, exposed to. To do this the firm must undertake an Internal Capital Adequacy Assessment (ICAAP).

Pillar 3: the public disclosure of a firm’s risks, the mitigating risk management process per applicable category and its capital position.

Audentia Capital Management LLP’s (“Audentia” or the “Firm”) Pillar 3 disclosure is based on the Firm’s financial position as at 31 December 2021 (the Firm’s accounting reference date).

This document is designed to meet the Firm’s Pillar 3 obligations. Audentia is required to update its Pillar 3 disclosure on an annual basis.

The information contained in this document has not been audited by the Firm’s external auditors, as this is not a requirement, and does not constitute any form of financial statement and must not be relied upon in making any judgment on the Firm.

Risk Management Objectives and Policies (BIPRU 11.5.1)

Given the nature of its business, Audentia is mainly exposed to business risk and operational risk. Audentia’s approach is to have in place processes and controls that are commensurate with the scale of the business operation. The Firm’s Pillar 2 assessment of business risk looks at a range of potential risks, and the Firm regularly assesses the likelihood of these risks and any controls in place to mitigate its exposure. Audentia’s operational risk exposure is typical for a business of its size and nature and it has established controls in place to mitigate the risk exposure accordingly. The Firm’s Chief Operating Officer, who is independent of the investment management business, has oversight of the operational risk of Audentia’s business. They are supported by the Firm’s Chief Compliance Officer in reviewing the operational risks of the business.

Scope of Application of the Requirement (BIPRU 11.5.2)

Audentia is incorporated in the UK and is authorised and regulated by the Financial Conduct Authority (the “FCA”) as a MiFID II investment management firm. The Firm is categorised under BIPRU as a “Limited Licence” and a “BIPRU €50K” base capital firm.

The disclosures contained in this document relate to Audentia’s business. The principal business is to provide discretionary investment management services to professional clients and eligible counterparties. The risks to which Audentia is exposed are principally business and operational in nature and are managed according to Audentia’s operational and compliance risk guidelines.

Capital Resources (BIPRU 11.5.3)

As at 31 December 2021, Audentia’s capital resource is £1457k and consists entirely of Tier 1 capital after deductions.

As Audentia is authorised and regulated by the FCA as a Limited License firm, Audentia’s capital requirements are the greater of:

• The base capital requirement of EURO 50,000; or
• The sum of its market and credit risk requirements; or
• The Fixed Overhead Requirement (“FOR”).

Audentia has calculated its capital requirement in accordance with the relevant FCA rules and the final level of capital is calculated as its FOR (a quarter of its annual expenses excluding variable costs).

As at 31 December 2021 Audentia has a FOR of £228k. Therefore, Audentia has excess resources of £1229k over its regulatory capital requirement.

Compliance with BIPRU 3, BIPRU 4, BIPRU 6, BIPRU 7, BIPRU 10 and overall Pillar 2 rule (BIPRU 11.5.4)

Audentia also carries out an Internal Capital Adequacy Assessment Process (“ICAAP”) to determine whether any additional capital is required for Pillar 2. The ICAAP process includes an assessment of specific risks to Audentia’s business, the likelihood of these occurring and the controls Audentia has put in place to mitigate these risks. This is an ongoing process. The ICAAP document is presented to senior management for formal review and approval. The data assumptions used in the assessment of risk and capital adequacy are regularly assessed and updated. This includes stress testing on various scenarios. As an investment manager the risks that Audentia is exposed to are business, operational and (to a limited extent) credit and market risk.

The following exposures are NOT applicable to Audentia’s business:

Retail Exposures (BIPRU 11.5.5): Audentia does not have any retail exposures;
Equity Exposures (BIPRU 11.5.6): Audentia does not have any equity exposures;
Counterparty Credit Risk Exposures (11.5.7): Audentia does not have any counterparty credit risk exposure;
Firms calculating risk weighted exposure amounts in accordance with the standardized approach (BIPRU 11.5.10): This section is not applicable as the Firm uses the simplified method of calculating risk weights;
Firms calculating risk weighted exposure amounts in accordance with IRB approach (BIPRU 11.5.11): This disclosure is not required as Audentia has not adopted the internal ratings based approach to credit and therefore is not affected by BIPRU 11.5.4R (3);
Non-trading book exposures in equities (BIPRU 11.5.15): Audentia does not have any non-trading book exposures in equities;
Exposures to interest rate risk in the non-trading book (BIPRU 11.5.16): Audentia does not have any external debt and therefore is currently unaffected by interest rate fluctuations. All cash balances are in GBP and USD;
Securitisation (BIPRU 11.5.17): Audentia does not securitise its assets.

Credit Risk and Dilution Risk (BIPRU 11.5.8)

Audentia is primarily exposed to credit risk from the risk of non-collection of management fees and performance fees. It holds all cash balances with banks assigned high credit ratings. Consequently, risk of past due or impaired exposures is minimal.

Value Adjustments and Provisions (BIPRU 11.5.9)

Audentia was not required to make any value adjustments or provisions.

Market Risk (BIPRU 11.5.12)

Audentia does not trade on its own account and therefore does not create any market risk in respect of its own business. Market risk is limited to management and performance fees received in foreign currencies. Market risk is calculated using the standardised approach.

Use of VaR Model for Calculation of Market Risk Capital Requirement (BIPRU 11.5.13)

Audentia does not use the VaR model for calculation of market risk as the Firm does not trade its own account and therefore does not create any market risk.

Operational Risk (BIPRU 11.5.14)

Audentia is subject to the FOR and is not required to calculate an operational risk charge. However, operational risk is considered in its ICAAP in identifying the level or risk-based capital required.

Audentia’s senior management is aware of the above risks which are discussed on a regular basis. The senior management consider the magnitude of the above risks to be within the Firm’s tolerance limits. Audentia has appropriate professional indemnity insurance in place.

Remuneration

Audentia has adopted a remuneration policy that complies with the requirements of chapter 19C of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook ("SYSC"), as interpreted in accordance with the FCA's guidance publication entitled "General Guidance on Proportionality: The Remuneration Code (SYSC 19C) & Pillar 3 Disclosures on Remuneration (BIPRU 11.5.18)", and subsequent items of guidance issued by the FCA, including its document entitled "Frequently Asked Questions on the Remuneration Code".

As a BIPRU Limited Licence firm, Audentia falls within proportionality Level 3. Audentia has concluded, based on its size and the nature scale and complexity of its legal structure and business, that it does not need to appoint a remuneration committee. Instead, Audentia’s senior management sets, and oversees compliance with Audentia’s remuneration policy including reviewing the terms of the policy at least annually.

Audentia currently sets the variable remuneration of its Remuneration Code Staff in a manner which takes into account individual employee performance and the overall results of Audentia. As permitted for firms falling within proportionality Level 3, Audentia takes into account the specific nature of its own activities (including the fee-based nature of its revenues).

The remuneration payable to Audentia’s Code Staff in respect of any accounting period is determined at the time the accounts for that period are finalised. The aggregate "remuneration" (as defined in the FCA Rules) awarded to its Remuneration Code Staff during the financial year ending on Audentia’s accounting reference date will be disclosed in the Firm’s accounts.

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UK Stewardship Code

Under COBS 2.2.3 of the Financial Conduct Authority Handbook, Audentia Capital Management LLP (“Audentia”) is required to make a public disclosure in relation to the nature of its commitment to the UK Stewardship Code (the “Code”) which was published by the Financial Reporting Council (“FRC”) in July 2010.

The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases, firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

Publicly disclose their policy on how they will discharge their stewardship responsibilities.
Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship.
Monitor their investee companies.
Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.
Be willing to act collectively with other investors where appropriate.
Have a clear policy voting and disclosure of voting activity.
Report periodically on their stewardship and voting activities.

Audentia Capital Management LLP does not currently comply with the Code for the following reasons:

Audentia is a private fund manager trading in the global commodities universe.
Solutions include: risk participation instrument(s), or other risk sharing instruments, with trade finance banks; commodity derivative contracts connected to those risk participation structures with trade finance banks or obligors of trade finance loans; and other credit and synthetic credit investments in physical commodity transactions but not equities.

Should any of the above factors change, Audentia will review its commitment to the Code at that time and make the appropriate disclosure.

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Disclaimer

This website www.audentiaglobal.com (“website”) is operated by Audentia Capital Management LLP (“Audentia”, “we”, “us”, “our”). We are registered in England and Wales under registration number OC417700 and have our registered office at The Wellsprings Wellsprings, Brightwell-Cum-Sotwell, Oxford, England, OX10 0RN. Our VAT number is GB294260002. By using this website, you the user (“you”, “user”, “client”, “customer”), are deemed to have read, and accepted these terms and conditions in full.

The Audentia website is intended solely to provide information about us and the work that we do. It gives potential clients an insight into our principles, our investment mandates (including the profile of companies we advise and investment in and the sectors we focus on), and our geographical reach. We do not offer any interactive services via this website. If you disagree with these terms and conditions or any part of these terms and conditions, you must not use this website.

Changes to these terms and website

We may revise these terms and conditions at any time by amending this page. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. By continuing to access our website once the revised terms and conditions have been posted, you agree to be bound by the revised terms and conditions. We may update our website from time to time, and may change the content at any time. However, please note that any of the content on our website may be out of date at any given time, and we are under no obligation to update it.

Accessing our website

Access to our website is not guaranteed. We may suspend, withdraw, discontinue or change all or any part of our website without notice. We will not be liable to you if for any reason our website is unavailable at any time or for any period.

Acceptable use

You must not use this website in any way that causes, or may cause, damage to the website or impairment of the availability or accessibility of the website; or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity, including but not limited to money laundering, terrorism or any other type of illegal activity of any sort. You must not conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to this website without Audentia’s express written consent. You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software. You must not misuse our website by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

Intellectual Property Rights

We are the owner or the licensee of all intellectual property rights in our website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. You may print off one copy, and may download extracts, of any page(s) from our website for your personal use and you may draw the attention of others within your organisation to content posted on our website. You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. Our status (and that of any identified contributors) as the authors of content on our website must always be acknowledged. You must not use any part of the content on our website for commercial purposes without obtaining a license to do so from us or our licensors.

If you print off, copy or download any part of our website in breach of these terms and conditions, your right to use our website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Linking to our website

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link to our website in any website that is not owned by you. Our website must not be framed on any other website, nor may you create a link to any part of our website other than the home page. We reserve the right to withdraw linking permission without notice.

Third party links and resources on our website

Where our website contains links to other websites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those websites or resources.

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Audentia Capital Management LLP is authorised
and regulated by the Financial Conduct Authority.

Privacy Policy | Pillar 3 Disclosure | UK Stewardship Code | Disclaimer

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