For the year ended 31 March 2026
1. Overview
This disclosure has been prepared by BBB Investment Services Limited ("BBB‑IS" or the "Firm") in accordance with the Handbook rules of the Financial Conduct Authority, specifically MiFIDPRU 8.
The Firm is authorised and regulated by the Financial Conduct Authority, is classified as a Small and Non‑Interconnected (SNI) investment firm and applies disclosure requirements on a proportionate basis.
This disclosure reports on the Firm’s Internal Capital Adequacy and Risk Assessment (ICARA), which underpins the Firm’s assessment of compliance with the Overall Financial Adequacy Rule. This disclosure also reports on the Firm’s remuneration practices and policy.
2. Governance and risk management
The Firm’s Board of Directors is responsible for overseeing strategy, risk management and financial adequacy. The ICARA is owned and approved by the Board, with preparation delegated to the Risk, Compliance and Finance functions.
The Firm operates within a Group Risk Management Framework incorporating a ‘three lines of defence’ model, risk reporting, escalation processes and independent oversight.
2.1 Key risks identified
Through the ICARA process the Firm has identified material potential risks including conflicts of interest, outsourcing failure, regulatory compliance risk, and financial crime risk. Additional capital requirements are allocated to these risks.
| Risk type | Description | Capital (£'000) |
|---|---|---|
| Risk to client | Conflicts/outsourcing | 900 |
| Risk to firm | Financial crime/regulatory | 1,200 |
| Total | 2,100 |
2. Risk appetite
The Firm maintains a low risk appetite. A 20% management buffer is applied above capital and liquidity thresholds and a minimum £3m liquidity level is maintained.
3. Own funds
The Firm’s own funds consist entirely of Common Equity Tier 1 capital.
| £'000 | |
|---|---|
| Share capital | 16,000 |
| Retained earnings | (3,058) |
| Total | 12,942 |
4. Own funds requirements
The Firm’s Own Funds Threshold Requirement (OFTR) is the higher of the ongoing operations requirement and wind-down requirement: £3.5m.
| Requirement | £'000 |
|---|---|
| Permanent Minimum Requirement | 75 |
| Fixed overheads requirement | 1,674 |
| Ongoing operations requirement (ICARA) | 2,100 |
| Wind-down requirement | 3,539 |
5. Capital adequacy
The Firm maintains surplus capital over its OFTR.
| £'000 | |
|---|---|
| Own funds | 12,942 |
| OFTR | 3,539 |
| Surplus | 9,403 |
| Coverage | 366% |
6. Liquidity
The Firm’s Liquid Assets Threshold Requirement (LATR) is calculated as the amount of liquid capital required to maintain operations in the event of the top two ICARA risks crystallising at the same time. This has been calculated as £1.9m. The firm maintains a minimum £3m cash balance and applies a management buffer above its liquidity requirement.
| £'000 | |
|---|---|
| Liquid assets | 3,000 |
| LATR | 1,858 |
| Surplus | 1,142 |
| Coverage | 161% |
7. Stress testing and wind‑down
The Firm has modelled severe but plausible stress scenarios including economic downturn, cyber incident, outsourcing failure and failure to meet investor expectations.
Under all stress scenarios the Firm remains above both its OFTR and LATR.
The wind‑down plan assumes an 18‑month orderly wind‑down period with a capital requirement of £3.5m.
8. Remuneration
The Firm maintains a remuneration framework designed to support its business strategy, long‑term performance and alignment with its risk appetite and ICARA outcomes.
8.1 Governance
Remuneration is overseen by the Board, taking advice from the Group Remuneration Committee. The Board is responsible for reviewing and approving the Firm’s remuneration policy and its alignment with risk management objectives.
The Risk and Compliance function provides independent input into remuneration outcomes, including consideration of risk outcomes and conduct.
8.2 Structure of remuneration
Remuneration comprises fixed and variable components.
Fixed remuneration includes base salary and benefits and is set at a level sufficient to attract and retain staff without reliance on variable remuneration.
Variable remuneration is discretionary and reflects both financial and non‑financial performance at Firm, business and individual level.
8.3 Performance assessment
Performance is assessed using a balanced scorecard of financial and non‑financial criteria, including conduct, risk management and adherence to regulatory standards.
Non‑financial factors are given appropriate weighting to ensure alignment with the Firm’s obligations and culture.
8.4 Risk adjustment
Variable remuneration is subject to ex‑ante and ex‑post risk adjustment.
This includes the application of malus and clawback provisions in circumstances including misconduct, failure of risk management, regulatory breach or material financial restatement.
8.5 Alignment with ICARA
The remuneration approach supports the Firm’s ICARA by ensuring that remuneration outcomes are consistent with the Firm’s capital and liquidity position.
The Firm does not permit variable remuneration that would compromise its ability to maintain adequate financial resources or comply with the Overall Financial Adequacy Rule.
8.6 Control functions
Employees engaged in control functions are remunerated predominantly through fixed compensation and are assessed independently of the business units they oversee.
8.7 Quantitative remuneration disclosures
For the financial year 2025-26 the total amount of remuneration awarded to all staff was £1,902,003, of which £1,675,832 comprised the fixed component of remuneration and £226,170 comprised the variable component. The Firm does not directly employ any staff. For the purposes of this disclosure, remuneration data includes appropriate allocations of BBB group employee remuneration where their roles wholly or materially contribute to the delivery of services in support of the Firm.
9. Publication
This disclosure is published annually and approved by the BBB-IS Board.