I) PRIVACY POLICY

 

Macrocapital respects the privacy of all our customers and adheres to strict GDPR rules.

 

As was the case in the past, we possibly intend to operate again a secure, registered user section in this website. For this part use of cookies will possibly be employed only to store information such as your User ID and your session identifiers to enable us to identify whether you are registered on to the site and, if so, to shortcut your access to the site. We will only read cookies from your cookie file placed there through your web browser's interaction with the site.

Our site doesn't link to other websites, but beyond our control, may be hacked to link to such sites, in which case we are not responsible for their data policies or procedures or their content.

We endeavor to take all reasonable steps to protect your personal Data including the use of encryption technology, but cannot guarantee the security of any Data you disclose online to any other website. You accept the inherent security implications of the internet and will not hold us responsible for any breach of security unless we have been negligent or in wilful default.

Our responsibilities under Money Laundering legislation include verifying the identity of clients and may need to make certain enquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may pass on such information as we consider necessary to comply with any reporting requirements.

This privacy policy is in relation to the Macrocapital Ltd websites www.Macrocapital.com.

 

II) PILLAR 3 DISCLOSURE                                as of 30/06/2022

 

Macrocapital Limited, is registered in England and Wales with company number 04014398 and for over twenty-one years now (since March 2001) is authorised and regulated by the Financial Conduct Authority (IMRO and FSA in the past) as an Investment Manager (195463).

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Part of the regulatory requirements and in particular of the Capital Requirement Directive (‘CRD’), is to carry out an Internal Capital Adequacy Assessment Process (‘ICAAP’) at least in the end of its financial year. Since January 2022 the new IFPR – Investment Firms Prudential Regime changes come into force and with that new capital and risk calculations. These new calculation factors known as K factors will form the content of the Internal Capital Adequacy Risk Assessment (ICARA) which replaces the ICAAP.

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As far as capital requirements are concerned, Macrocapital Limited is a ‘BIPRU’ Limited License Firm, that doesn’t hold or control client money. This is explained in the Financial Conduct Authority (‘FCA’) Handbook and particularly within the FCA Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’).

This regulatory capital has 3 pillars of capital requirements that have to be followed:

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I] Pillar 1 is a variable capital requirement based on the sum of operational, market and credit risk requirements. Every firm must maintain at all times capital resources equal to or in excess of the amount specified.

II] Pillar 2 is an additional capital requirement related to risks not covered in Pillar 1. It requires firms and their supervisors to review whether additional capital should be held against risks not covered in Pillar 1 as well as instigate and oversee additional controls to mitigate such risks or a combination of these two approaches.

III] Pillar 3 is a requirement to publish certain details of capital and risk management and to review and update this information at least annually.

Under the current rules, a firm may omit one or more disclosures where the information provided by such disclosure is not regarded as material. As our services are offered to a very select set of customers and we are currently not marketing we do not disclose detailed information to the wider public.

The required Pillar 3 disclosures below apply solely to Macrocapital Limited as a legal, authorised, and regulated by the Financial Conduct Authority, entity.

Risk management
The company's risk management focuses on the major areas of market risk, operational risk, and business risk. The management of the firm has sufficient experience to manage risks appropriately and has a compliance director who regularly monitors risk by reviewing reports prepared by external compliance consultants.

Capital resources
The company's capital comprises of called up share capital and the audited profit and loss account.
A summary of the company's capital is as follows:  

                                                                        £'000
Tier 1
Called up share capital                                   380
Profit and loss account                                 (239)
Total capital                                                      141

Market, operational, and credit risk
The company is a small firm with a simple operational infrastructure and in the directors' opinion, the simplified standard approach to credit, market, and operational risk is appropriate.

As an SNI firm, we are required to maintain “own funds” that is the higher of a permanent minimum capital requirement (“PMR”) (which is £75,000) and a fixed overheads requirement (“FOR”) (an amount equal to one-quarter of its relevant expenditure in the previous year)
The company has assessed its Pillar 1 and Pillar 2 capital requirement to be £75K.

The Pillar 1 capital resource requirement is the higher of the permanent minimum capital requirement (a fixed number equal to £75,000) and the variable capital resource requirements.

(The latter is  the higher of i) the Fixed Overhead Requirement(13 weeks of the Firm’s annual expenses excluding variable costs) and ii) the sum of the Credit Risk and Market Risk Capital Requirements-which are very small for our company.)

The above takes into account the costs for orderly wind-down.

 

III) Disclosure of commitment to the Financial Reporting Council's Stewardship Code ("The Code") under FCA COBS 2.2.3R.
Macrocapital Limited ("The Firm") is an investment manager based in the United Kingdom and authorised and regulated by the Financial Conduct Authority.
We endeavour to apply our approach on stewardship to all companies that we invest in on behalf of our clients. Our approach is consistent with the Firm's overall aims, which are to provide good long-term performance to our clients, and to keep clients' interests paramount.
The Firm monitors all investee companies as part of its general investment policy and approach. The Firm takes action in line with its investment objectives where its research of publically available information warrants such action.
However, given the nature of our chosen investment strategy, this approach does not include active engagement with UK listed investee companies, nor do we consider that our clients would expect such engagement.
If our investment strategy changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.
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IV) SFDR  - Sustainable Finance Disclosure Regulation

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SFDR aims to increase transparency on how financial market participants integrate sustainability into their investment decisions and recommendations. It introduces a classification system with new disclosure requirements for investment products.
The aim of SFDR is to promote transparency by ensuring that fund managers disclose their approach to sustainability. Macrocapital Limited will include disclosures on its website, in its managed account prospectuses and in its annual report. The implementation of SFDR and other related sustainable finance regulations is expected to run from 10 March 2021 until at least the end of 2023, meaning that Macrocapital Limited will continue to implement and provide more transparency in the years to come. 

The SFDR applies to Macrocapital Limited because we manage managed accounts. We may also provide investment advice, which means we are a financial advisor for SFDR purposes.

Financial market participant Macrocapital Limited, with LEI: 213800OYOFGU1OAG2S92  does not consider principal adverse impacts of its investment decisions on sustainability factors. 

Reasoning:
All our discretionary strategies are based on technical-driven trading on listed futures and options on equity indices or currencies. Having thoroughly establishes what the sustainability impacts would be of these strategies we have found they are none, particularly for the size of trades we place and the holding period. Furthermore, most of our strategies are bearish or are long options that will benefit if equity markets fall. We believe we are looking at a period of substantial volatility and stagflation. God knows how bad it will be, but combined with geopolitical events, it could lead into a depression like the 1930's. Our strategies are designed to perform well in more global economic scenarios than most other strategies. However where sustainability criteria are concerned, although we do look at them, we do not market ourselves doing so as they will most likely, due to the market volatility, not be possible to implement in the coming years. For now, we are not looking to change that and integrate sustainability into our policies

The present statement is the consolidated principal adverse sustainability impacts statement of Macrocapital Limited. This principal adverse impacts statement covers the reference period from 1 January 2021 to 31 December 2023. 
 

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V) DISCLAIMER

The material on this website is provided for your general information only and does not constitute the giving of investment advice or an offer to sell or the solicitation of an offer to buy any investment. This communication does not constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and the handbook of rules and guidance issued from time to time by the FCA.

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Interests in any fund mentioned on this website, now or in the future, (a “Fund”) may not be purchased by US Persons as defined under Regulation S promulgated under the US Securities Act of 1933. The information and material on this website is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States.

The information and material on this website are intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any retransmission, dissemination, or other unauthorised use of this information by any person or entity is strictly prohibited.

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The information and material on this website have been provided to you for informational purposes only and may not be relied upon by you in evaluating the merits of investing in a Fund. Information and material on this website are not intended as, and is not to be taken as, an offer or solicitation with respect to the purchase or sale of interests in the Funds, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. Any decision to purchase interests in a Fund described on this website must be based solely upon the information contained in the prospectus of the relevant Fund.

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The information on this website should not be considered to be legal or tax advice, and each prospective investor should consult with its own legal counsel and tax advisers as to all matters concerning an investment in shares in the Funds. Although the information in this website is believed to be materially correct, no representation or warranty is given as to the accuracy of any of the information provided. Certain information included in this website concerns economic trends and performance and is based on or derived from information obtained from sources considered to be reliable. Macrocapital cannot guarantee the accuracy of information, however and has not independently verified the assumptions on which such information is based. Furthermore, to the extent permitted by law, neither Macrocapital nor any of its agents, service providers or professional advisers assumes any liability or responsibility nor owes any duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in this website or for any decision based on it.

 

You should always bear in mind that:

              a) the value of investments and any income from them may go down as well as up. You may not get back all of your original investment.
              b) past performance should not be seen as an indication of future performance.
              c) indications of past performance displayed on this website will not necessarily be repeated in the future.
              d) rates of exchange may cause the value of underlying investments to go up or down.
              e) applications to invest in any product referred to on this website must only be made on the basis of the documentation relating to the specific investment.

 

If you are in any doubt about the information contained on this website please contact us or consult your usual professional financial adviser, if you have one.

 

Opinions and any other information on this website are provided by Macrocapital Ltd for personal use and informational purposes only. No information provided on this website in relation to any product or investment should be construed as advice to you on the suitability or otherwise of that product or investment for you or any other person, such suitability depending on all the circumstances of the person concerned. Nothing contained on the website constitutes investment, legal, tax or other advice nor is it to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.

Terms of use

You must NOT use this website (or permit or procure others to use it) as follows:

a. for any unlawful, improper or illegal purpose or activity;
b. to violate Macrocapital’s or any third party's copyright, trademark, proprietary or other intellectual property rights;
c. to damage Macrocapital’s name or reputation or that of Macrocapital’s affiliated companies or any third parties;
d. to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into this website or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from this website is free from such items; and/or
e. to transmit confidential or proprietary information, except solely at your own risk.
When using this website, you must comply with all applicable local, national and international laws and regulations, including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on this website in certain countries and Macrocapital and its affiliated companies disclaim all responsibility if you download any information from this website in breach of any law or regulation of the country in which you reside.

The entire contents of this website are subject to copyright with all rights reserved. The copyright, trademarks and all similar rights of this website and the contents, including all information, graphics, code, text and design, are owned by Macrocapital (or its licensors).

You may download or print individual sections of the site for your personal use and information only provided that you ensure that all copyright notices and other proprietary notices are displayed on such downloaded or printed sections. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the site without the prior written permission of Macrocapital.

Nothing on this website should be construed as granting any licence or right in relation to any of our trademarks or those of our affiliated companies or any third party.

This website, including information and materials contained in this website, text, graphics, software, links and other items are provided "as is", "as available". Macrocapital does not warrant the accuracy, adequacy, completeness, timeliness or availability of the information and data contained in this website, and expressly disclaims liability for errors or omissions in this website. There is no warranty of merchantability, no warranty of fitness for a particular purpose, no warranty of non-infringement, no warranty of any kind, implied, express or statutory, in conjunction with this website.

To the extent permitted by applicable laws and regulations, in no event will Macrocapital be liable for any damages, including, without limitation, direct or indirect, special, incidental, or consequential damages, losses or expenses arising in connection with this website or use or misuse thereof or the inability by any party to use such website, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if Macrocapital, or representatives thereof, are advised of the possibility of such damages, losses or expenses.

As a condition of your use of this website, you agree to indemnify and hold harmless Macrocapital and its affiliates, and the directors and employees of Macrocapital and its affiliates from and against any and all liabilities, claims, damages, losses or expenses, including legal fees and expenses, (together, "Losses") arising out of your access to or use of this website, save to the extent that Macrocapital may not exclude or limit its own liability for such Losses pursuant to applicable laws or regulations.

This website is established in England by Macrocapital in accordance with and shall be governed by, and your browsing in and use of this website shall be deemed acceptance of, the laws of England and Wales. A condition of using this website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.

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Macrocapital Limited is not affiliated with any other company called Macrocapital Limited, Macrocapital Ltd, Macro Capital S.A. etc., anywhere in the world. It has never had and never intends to have retail clients and has never maintained any Facebook pages or WhatsApp presence.

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Macrocapital may revise these Terms at any time by amending this page. You are expected to check this page from time to time to take notice of any changes Macrocapital makes, as they are binding on you.

Each time you use this website, a condition of use is that you comply with the above Terms.