GCW Global Customised Wealth LLP
(“GCW” or “the Firm”)
Complaints Handling Disclosure
March 2025
You should contact us immediately if you are dissatisfied with any aspect of the investment services provided to you by GCW Global Customised Wealth LLP.
Please write to:
Banshi Patel
1 Chesterfield Street
London
W1J 5JF
UNITED KINGDOM
We take every complaint seriously and your complaint will be handled in accordance with the relevant FCA rules, which may differ depending upon your status, although note that it is GCW Global Customised Wealth LLP’s policy to aim to resolve every complaint fairly and in a timely manner. GCW Global Customised Wealth LLP has a written internal complaints handling policy, as required by the FCA rules. You can obtain a copy of this upon request, and in the event you should have cause for complaint about the investment services that GCW Global Customised Wealth LLP provides to you, a copy of the policy will be sent to you.
In the event we fail to resolve a complaint to your satisfaction, or if we fail to do so within eight weeks of receiving your complaint, you may also be entitled to refer your complaint to the Financial Ombudsman Service:
The Financial Ombudsman Service
Exchange Tower
Harbour Exchange Square
London
E14 9SR
Telephone: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
Website: http://www.financial-ombudsman.org.uk/
Form ADV Part 2A
Form CRS
GCW Global Customised Wealth LLP is an investment adviser registered with the Securities and Exchange Commission.Services and fees of investment advisers and broker-dealers differ, and it is important to understand those differences.Simple tools for researching firms and financial professionals are freely available at www.Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.
MIFIDPRU Disclosure
Introduction
Regulatory Context
In accordance with MIFIDPRU 8 the regulatory aim of the disclosures is to enable stakeholders andmarket participants to have an insight into how GCW Global Customised Wealth LLP (“GCW” or the“Firm”) is run. They should also aim to help stakeholders make more informed decisions about theirrelationship with the Firm.
Frequency
This Disclosure covers the period 1 April 2023 to 31 March 2024, and subsequent updates will bemade on at least an annual basis as of the Accounting Reference Date (“ARD”), which is 31 March each year, and will be publicly disclosed when the Firm files its financial statements with CompaniesHouse.
The Firm may choose, at its own discretion, to make more frequent public disclosures where a particular circumstance requires this in the opinion of the Firm’s management.
Proportionality
The level of detail provided in the qualitative disclosures is proportionate to the size and internal organisation of the Firm and also proportionate to the nature, scope and complexity of the Firm’s business activities.
Media and Location
The disclosure will be published on the Firm’s website and will be free to obtain.
Changes to Information disclosed
This is the Firm’s first Disclosure under MIFIFPRU 8. Therefore, there are no significant changes oramendments for GCW to disclose.
Verification
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 judgement on the Firm.
Background
GCW is incorporated in the UK and is authorised and regulated by the FCA. The Firm is a SmallAuthorised UK AIFM (“Small AIFM”) as well as a MIFIDPRU Investment Firm. As a SNI MIFIDPRUinvestment firm, that has no additional tier 1 instruments in issue, the Firm is only required todisclose its remuneration policies and practices, as per MIFIPRU 8.1.These disclosures are made by the Firm on a solo basis as required by MIFIDPRU 8.1.7R. As a SmallAIFM, the Firm implements some of the AIFM remuneration rules. However, the Firm is not requiredto comply with the AIFM Remuneration Code in full and is instead subject to the ‘MIFIDPRURemuneration Code’.
MIFIDPRU 8.6 – Remuneration
Distributions to Senior Management and Owners
In accordance with the guidance in SYSC 19G.4.4, at the end of each year, the residual profits of thelimited liability partnership are distributed among the members. The level of ownership of eachmember is reflected in the proportion of ownership shares they have. As residual profits aredistributed according to the ownership shares and are not linked to work or performance, this is notconsidered to be remuneration for the purpose of the Firm’s Remuneration Policy.
However, fixed profit shares, or fixed draws, received by partners in anticipation of the Firm makinga profit over the course of the year, as a result of which such drawings may have to be paid back inthe event of a shortfall in profits, are considered to be fixed remuneration. Discretionary shares ofprofits received by partners based on performance of the individual or their business unit areconsidered to constitute variable remuneration. However, partners are not entitled to adiscretionary share of profits at GCW
Qualitative Disclosures
The Firm has in place a Remuneration Policy which is approved by the Management Committee at least annually. The remuneration policy overarching aim is the promotion of sound and effective risk management, whilst reducing conflicts of interests and encouraging good conduct amongst employees. The purpose of the remuneration policy is to set out how the Firm will provide remuneration in a manner that is consistent with the MIFIDPRU remuneration code as outlined above, with the main objective of the financial incentives being to attract, motivate and maintain high-calibre employees.
In summary, the key objectives of the remuneration framework in place are:
- the consistent promotion of sound and effective risk management of client portfolios;
- ensuring that excessive risk taking is not encouraged;
- ensuring compliance with the Firm’s conflicts of interest and outside business interest policiesand procedures, such that appropriate disclosure and mitigation are achieved, as appropriate; and
- alignment with the Firm’s business strategy, regulatory obligations, objectives, values, and long-term interests.
Due to its size and the nature of its activities, the Firm does not believe it is proportionate to have a Remuneration Committee.
Staff members who are not also partners, are entitled to receive variable remuneration at the Firm’s discretion. The Firm’s approach to the payment of variable remuneration to eligible staff includes an assessment of:
- the performance of individual staff members with respect to quantitative financial metrics;
- assessment of the performance of personnel against non-financial metrics, which we define most broadly as contribution to the Firm’s mission;
- the performance of the Firm; and
- GCW’s regulatory capital and liquidity position and the maintenance of an appropriate surplus of capital and liquidity.
All remuneration payments take the form of cash payments.
Quantitative Disclosures
The Firm considers that it has a single business area (investment management), and the total remuneration paid to Staff, as required under MIFIDPRU 8.6.8R (4), can be found below. The variable remuneration reflects such remuneration paid with respect to performance over the financial year (even if paid following the end of the year).
SRD II Code
Under COBS 2.2B.5R of the FCA Handbook, the Firm is required to develop and publicly disclose an Engagement Policy (per COBS 2.2B.6R) and make subsequent annual disclosures of the implementation of that Engagement Policy, OR publicly disclose a clear and reasoned explanation of why the Firm has chosen not to do so.
GCW pursues a number of investment strategies, which in general aim to help individuals preserve and grow their wealth, depending on their risk profiles. In the case of direct investments in companies, GCW may engage with the management of those companies, including voting on matters which we consider material to the interests of our clients. In such cases, our diligence and analysis enable us to form views on the activities, strategy and performance of those companies, and to use our voting rights and access to management to express these views. We may also engage with other shareholders and stakeholders, where it is appropriate and consistent with our strategy and the interests of our clients. However, many of our investments are in fund vehicles and not direct investments in companies.
We may also engage with other shareholders and stakeholders, where it is appropriate AND consistent with our strategy and the interests of our client(s).
The Firm is considering its position on an ongoing basis with respect to its obligations above, however, at this point, the Firm does not consider that it is appropriate for it to have a formal Engagement Policy, due to its investment approach and size.
Stewardship Code Disclosure
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, GCW is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.
The Code is a voluntary code, first published in 2010 and subsequently subjected to updates in 2012 and 2020. The more recent UK Stewardship Code 2020 (“The Code”), sets high standards by way of Principles which should be applied by asset owners and service providers (in some cases), as well as asset managers, such as GCW.
GCW pursues a number of investment strategies, which in general aim to help individuals preserve and grow their wealth, depending on their risk profiles. In the case of direct investments in companies, GCW may engage with the management of those companies, including voting on matters which we consider material to the interests of our clients. In such cases, our diligence and analysis enable us to form views on the activities, strategy, and performance of those companies, and to use our voting rights and access to management to express these views. We may also engage with other shareholders and stakeholders, where it is appropriate and consistent with our strategy and the interests of our clients. However, many of our investments are in fund vehicles and not direct investments in companies.
While we agree with the aspirations of the Code, given that many of our investments are in fund vehicles and not direct investments in companies, we have made the decision not to sign up to it formally. We consider Stewardship issues on a case-by-case basis and, where relevant, make decisions in the best interests of our clients, as we determine using our reasonable commercial judgement.
1 Chesterfield Street, London W1J 5JF