Promethion Limited

20 St. Dunstan's Hill

London EC3R 8HL

+44 20 3795 2330

Regulatory Notice

Promethion Limited is authorised and regulated by the Financial Conduct Authority to provide investment advice to professional clients and eligible counterparties.

Regulatory

The content of this website is issued and approved by Promethion Limited ("Promethion"), which is authorised and regulated by the Financial Conduct Authority (the "FCA") for the provision of investment advice to persons who can be categorised, in accordance with the FCA's rules, as "professional clients" and "eligible counter parties". The Firm does not provide investment services to retail clients and such persons should not seek to use or rely on any information provided in this website.

The information contained herein does not constitute an offer to sell or the solicitation of any offer to buy or sell securities and or any derivatives and may not be reproduced, further distributed or published by any recipient without prior permission from Promethion.

The information and opinions contained in this website are for background purposes only and do not purport to be full or complete. Nor does any content within this website constitute investment advice. No representation, warranty, or undertaking, express or limited is given as to the accuracy or completeness of the information or opinions contained in this document by any of Promethion, its directors or employees and no liability is accepted by such persons for the accuracy or completeness of any information or opinions.

Promethion is not registered as an investment advisor with the SEC and therefore this document is neither directed at nor intended for US investors.

Your Privacy Is Important To Promethion Limited ("PROMETHION").

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy.

PROMETHION provides this website as a source of information about its services. In order to provide you with this information PROMETHION may request personal information about you. Obtaining this information is important to our ability to provide you with the most relevant information and to ensure we deliver the highest level of service. Also, collecting your personal information helps us provide a service to you with which to achieve the strict compliance with all applicable laws and financial regulations as well as data protection ones.

The information do we collect.

PROMETHION may gather information in two ways either directly or indirectly. Direct collection of personal information comes primarily from the registration applications or other forms and materials you voluntarily submit. We will also collect data through "cookies" (small files of information which save and retrieve information about your visit such as how you entered our site, how you navigated through the site, and what information was of interest to you). Indirect collection of personal data will take the form of recording your access to the website, such as your Internet address.

Disclosures of Your Personal Information to Third Parties.

PROMETHION does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with companies that perform support services for your account or facilitate your transactions with PROMETHION, including those that provide professional, legal, or accounting advice to PROMETHION. As we take your privacy seriously we require third party companies to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that PROMETHION dictates.

Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a judicial order, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearing houses.

Data security

We take appropriate technical and organizational measures to maintain the security of your data we collect.

Pillar 3 Disclosure

Introduction

The Pillar 3 disclosure of Promethion Limited ("Promethion") is set out below as required by the FCA's Prudential Sourcebook for Banks, Building Societies and Investment Firms (BIPRU) specifically BIPRU 11.3.3 R. This follows the introduction of the Capital Requirements Directive (Basel II) which came into force on 1st January 2007 and these rules require Promethion to assess the adequacy of their capital resources given the risks they face in order to ensure the continued protection of investors.

From 1 January 2014, a new set of prudential requirements replaces the BIPRU sourcebook for investment firms subject to the EU's Capital Requirements Directive IV (CRD IV). Promethion does not intend to do placing of financial instruments without a firm commitment basis and consequently has applied to vary its permissions in a way that will allow it to remain on the existing FCA rules that implement CRD III and not be subject to the additional requirements placed upon CRDIV firms.

Frequency

Promethion will be making Pillar 3 disclosures annually. The disclosures will be as at the Accounting Reference Date "ARD".

Media and Location

The disclosure will be published on Promethion's website.

Materiality

Promethion regards information as material in disclosures if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions. If the Firm deems a certain disclosure to be immaterial, it may be omitted from this statement.

Confidentiality

Promethion regards information as proprietary if sharing that information with the public would undermine its competitive position. Proprietary information may include information on products or systems which, if shared with competitors, would render Promethion's investments therein less valuable. Further, the Firm must regard information as confidential if there are obligations to customers or other counterparty relationships binding Promethion to confidentiality. In the event that any such information is omitted, we shall disclose such and explain the grounds why it has not been disclosed.

Summary

The CRD requirements have three pillars. Pillar 1 deals with minimum capital requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process ("ICAAP") undertaken by a firm and the Supervisory Review and Evaluation Process through which Promethion and regulator satisfy themselves on the adequacy of capital held by Promethion in relation to the risks it faces and; Pillar 3 which deals with public disclosure of risk management policies, capital resources and capital requirements. The regulatory aim of the disclosure is to improve market discipline.

Promethion is an advisory business and has since Authorisation by the Financial Conduct Authority undertaken a range of assignments for clients. Promethion typically advises at CEO/COO level on a broad range of strategic business issues and has particular expertise in the alternative asset space and credit markets. Promethion has set-up and raised capital for hedge funds; advised on asset allocation, portfolio restructuring and operational infrastructure for funds and banks; and created analytical risk tools. In particular Promethion has expertise in the establishment of new asset management businesses and debt advisory and portfolio restructuring services. Promethion serves a wide range of financial institutions and public sector bodies, including: commercial banks, hedge funds, private banks, retail sales organizations and IFAs, insurance and reinsurance companies, public sector entities and sovereign wealth funds.

Promethion is required to disclose its risk management objectives and policies for each separate category of risk which include the strategies and processes to manage those risks; the structure and organisation of the relevant risk management function or other appropriate arrangement; the scope and nature of risk reporting and measurement systems.

Although usually Operational and Business Risks are the main drivers for Pillar 2 Promethion has identified its greatest risk as market risk. Promethion has assessed market risks in its ICAAP and set out appropriate actions to manage them. The Directors have identified Promethion's material risks and assessed their impacts upon the Firm.They agreed that no additional capital would be required at this time to address any of their material risks above the current Pillar 1 Capital level of £47,000. They felt that with the current operational controls in place that their capital was adequate and in proportion to the size and complexity of their Firm.

Background to Promethion

Promethion Limited ("Promethion") is a private UK limited company established in November 2001. Promethion was authorised and regulated by the UK Financial Conduct Authority in April 2008 as a BIPRU €50K Firm. The Firm's permissions are managing investments, advising on investments (except pension opt outs and transfers), dealing in investments (as agent), arranging transactions in investments, making arrangements with a view to transactions in investments and arranging safeguarding and administration of investments. The Firm is authorised to deal with professional clients and eligible counterparties. The Firm does not have permissions to hold but may control client funds.

BIPRU 11.5.1: Risk Management Objectives and Policies

Promethion's general risk management objective is to develop systems and controls to mitigate risk to a level that does not require the allocation of Pillar 2 capital.

Governance Framework

Promethion's Managing Director has daily management and oversight responsibility of risk management, as well as assessing the effectiveness of the process. Promethion has implemented an effective, ongoing process to identify risks, to measure their potential impact and then to ensure that such risks are actively managed. Senior Management are accountable to the Board for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of the Firm.

Risk Framework

Risk information is available upon request.

BIPRU 11.5.4: Compliance with BIPRU 3

For its Pillar 1 regulatory capital calculation of Credit Risk, under the credit risk capital component Promethion has adopted the Standardized approach to Credit Risk (BIPRU 3.4) and Simplified Method of calculating risk weights (BIPRU 3.5).

BIPRU 4

Promethion does not adopt the IRB Approach and hence this is not applicable.

BIPRU 6

Promethion, being a Limited Licence Firm is not subject to the Operational Risk Requirement and, therefore, this is not applicable.

BIPRU 7

Promethion has only non-trading book potential exposure (BIPRU 7.4, 7.5).

BIPRU 10

Promethion monitors its non-trading book limits in line with BIPRU 10.5.2R to BIPRU 10.5.10R. The situation is monitored and assessed on a live basis. When Promethion has a single exposure exceeding 25 per cent of its capital resources, it is recorded internally and monitored until such time as is rectified upon receipt of fees.

Overall Pillar 2 Rule

Promethion has adopted the "Pillar 1 plus" approach to the calculation of its ICAAP Capital Resources Requirement.

BIPRU 11.5.8: Credit Risk and Dilution Risk

Promethion is primarily exposed to Credit Risk from the risk of non-collection of advisory fees. It holds all cash balances with Banks assigned high credit ratings. Consequently risk of past due or impaired exposures is minimal.

BIPRU 11.5.12: Market Risk

This disclosure is not required as Promethion has no market risk capital requirement.

BIPRU 11.5.2: Scope of application of directive requirements

This disclosure is not required as Promethion is not within scope of the Banking Consolidation Directive and is not a member of a UK Consolidation Group.

BIPRU 11.5.3: Capital Resources

Promethion is a BIPRU Investment Firm without an Investment Firm Consolidation Waiver deducting Material Holdings under GENPRU 2 Annex 4.

BIPRU 11.5.5 and 11.5.6

Equity risk exposures total £34,000.

BIPRU 11.5.7

This disclosure is not required as Promethion does not have a trading book.

Remuneration Disclosures

The FCA has amended the Prudential Sourcebook for Banks, Building Societies and Investment Firms (BIPRU), and specifically BIPRU 11, to now include a requirement for disclosure of Promethion Ltd's approach to linking remuneration to risk.

Promethion Ltd has a Remuneration Policy which appropriately addresses potential conflicts of interest and that Promethion Ltd's authorised persons are not rewarded for taking inappropriate levels of risk. Under the Remuneration Code, the firm is classified as a Tier Four firm, which allows it to disapply many of the technical requirements of the Code and proportionately apply the Code's rules and principles in establishing Promethion Ltd's policy.

Promethion Ltd is satisfied that the policies in place are appropriate to its size, internal organisation and the nature, the scope and the complexity of its activities.

The Decision Making Process

Promethion Ltd's Remuneration Policy is set by the company directors. Promethion Ltd has assessed its staff and concludes that only two qualify as Code Staff. Each year Promethion Ltd assesses the amount of capital it considers necessary to run its business and if necessary uses some or all of the profits available to increase its capital resources. If sufficient profits are available, a percentage of profits is paid into a bonus pool which covers the staff which is allocated based on the individual contribution

Quantitative Remuneration Data

We are required to disclose the following quantitative data:

BIPRU 11.5.18R(6) (aggregate quantitative information on remuneration, broken down by business area)

Investment Advisory Services: Less than or equal to £1,000,000

Investment Management Services: Less than or equal to £1,000,000

BIPRU 11.5.18R(7) (aggregate quantitative information, broken down by senior management and members of staff whose actions have material impact on the risk of the firm).

Senior Management: less than or equal to £1 million