What We Do

Sparrows Capital adopts a rigorous evidence-based approach to investing.

This results in a style that can be described as:

  • Strategic
  • Risk Based
  • Factor Based
  • Cost Efficient

The intention is to harvest an enhanced market return across the full investment cycle. We achieve this by designing bespoke portfolios for our clients using selected highly efficient investment vehicles including ETFs and Index Funds.



Risk Profiling

We ask each of our clients to respond to a detailed, 57 question risk questionnaire. This has been designed in-house with a view to establishing both your attitude to risk, your financial capacity to tolerate market volatility and your objectives. The questionnaire, and subsequent discussion with you of its detailed output, forms the foundation of our personalised investment recommendation.

Risk questionnaire

57 questions founded in behavioural psychology designed to ensure that we have a clear, unambiguous picture of your risk tolerance, risk preferences, financial capacity, time horizon and objectives.

Risk tolerance

Risk is inherently subjective*. Two individuals presented with the same fact set may interpret the risks therein differently. Equally importantly, two people may display very different reactions to the same risk outcome, with consequent impact on their investment discipline.

* (reference Slovic, P., The Perception of Risk (London: Earthscan Publications Ltd., 2000): 392)

Financial capacity

A relatively objective measure of financial situation, taking account of your net worth, income, liabilities and objectives.


Analysis of your responses will allow us to build an initial model asset allocation to act as a basis for discussion. It will also highlight any anomalies in your answers and any notable risk preferences.

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Strategic Asset Allocation

We construct a bespoke asset allocation for each client, taking account of your individual risk profile. Asset classes are selected from across the investable universe and assembled to provide an optimal mix of risk / return characteristics. This asset and risk allocation is critical, as it will be the fundamental driver of your subsequent portfolio returns.

Initial asset allocation

We build the efficient frontier mix based on the output of the risk questionnaire.

Iterative discussion

The output of the risk questionnaire, together with the initial asset allocation, is discussed with you in detail. This allows us to fine tune our understanding of your risk profile, explore any anomalous output, and then to apply appropriate adjustments to the allocation. This may include currency hedges, factor tilts, inclusions or exclusions of specific risks.

Strategic asset allocation

Defines the risks to which the portfolio will be exposed, and therefore the future market returns.

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Screening, Selection and Execution

Your strategic asset allocation (SAA) is expressed in the market via a qualitative and quantitative selection of efficient investment vehicles, which are carefully screened and vetted by us.


Market screening

We screen the universe of ETFs and index tracker funds to identify the most appropriate investment vehicles. We identify those instruments which are most representative of each component of your strategic asset allocation, including any recommended factor tilts. We score the relevant instruments for tracking error, liquidity and cost.

Due diligence

We review the fund prospectus, with a focus on structure, methodology, counterparty risk, and lending policies.

Investment policy

Your SAA and agreed set of investment vehicles, together with execution, hedging and rebalancing strategy will be recorded in an investment policy for your agreement.


We provide transaction instructions to your custodian, and may make specific recommendations as to execution brokers, exchanges, conditions and timing. If appropriate, we may recommend a cost averaging execution strategy.

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Ongoing Monitoring, Rebalancing and Reporting

Our monitoring and review processes ensure that the portfolio performs as expected, that the risk allocation remains as intended, and that the underlying instruments remain relevant and best in class. We take action as appropriate, and we keep you updated.



We continuously monitor your portfolio and underlying investments. We analyse the effect of market moves to explain value changes and to control portfolio drift.


Market fluctuations will affect the asset allocation over time, with the result that the risk allocation can move away from the initial strategic asset allocation. We will effect rebalancing trades once the allocation exceeds pre-defined thresholds in order to maintain the intended risk exposure. This is an important element of strategic investing.


In addition to the online reporting available to you, we produce a quarterly investor pack outlining changes in portfolio values, explaining the drivers of returns, and reviewing the underlying holdings for continued relevance.

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Sparrows Capital Limited is authorised and regulated by the Financial Conduct Authority. Incorporated and registered in England and Wales Company Registration Number: 08623416. Registered Office: The Podium, 1 Eversholt Street, London, NW1 2DN

Important Information

To the extent that material on this Site is issued in the United Kingdom (“UK”), it is issued for the purposes of the UK Financial Services and Markets Act 2000 by Sparrows Capital Limited (“Sparrows”) which is authorised and regulated in the UK by the Financial Conduct Authority.

Use of Information and Material. The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by Sparrows and its associated companies to be reliable, but is not guaranteed as to its accuracy or completeness. This Site and the information herein is for general information purposes only. In addition, the information and materials contained in this Site and the terms and conditions of the access to and use of such information and materials are subject to change without notice. Not all advisory or management services are available in all geographic areas. Your eligibility for particular products and advisory or management services is subject to local law and regulation.

Risk Factors. Past performance is no indication of future performance, and nothing on this Site should be interpreted to state or imply otherwise. The value of investments may fall as well as rise and investors may not get back the full amount invested. Changes in rates of foreign exchange may cause the value of investments to go up or down. The levels and bases of and reliefs from taxation may change. Investors should consult their own tax adviser in order to understand any applicable tax consequences.

No Advice, Offers or Solicitations. The information and materials in this Site should not be construed as to provide tax, legal or investment advice. In addition, the information and materials herein shall not constitute an offer or solicitation, or an offer to sell, shares of any funds or any advisory or management service in any jurisdiction. The type of securities mentioned may not be suitable for everyone. USERS ARE URGED TO BASE THEIR INVESTMENT DECISIONS UPON A THOROUGH INVESTIGATION AND TO OBTAIN ALL NECESSARY PROFESSIONAL ADVICE.

Material Interests. Sparrows, its associated companies and its and their members and/or directors, officers and/or employees may have holdings in the investment funds referred to on this site and may otherwise be interested in transactions that you effect in those funds.

Data Protection. Sparrows is registered with the Information Commissioner’s Office as a data controller under the Data Protection Act 1998. We may hold and process personal information for purposes of staff administration, advertising, marketing & public relations, accounts & records and provision of investment management and advice. We may transfer data outside the European Economic Area (EEA) where it may not be as securely protected as in the EEA.

Cookies. Sparrows’ website uses cookies for collecting user information from certain pages of the website. By cookie we mean the small text file that is stored on the hard disk of a computer by the web browser of a computer. It contains information sent by the web server of the website that a user has visited. We use “Google analytics” in order to collect information about how visitors use our website, for instance which pages visitors go to most often and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. If cookies have been disabled on your computer, click on the “help” menu in your browser and follow the instructions given.

United Kingdom’s Stewardship Code. The Stewardship Code (the “Code”) was developed from the Walker Review on Corporate Governance in the UK and aims to enhance the quality of engagement between investors (and investment managers) and UK listed companies. Although the Code is voluntary, the Financial Conduct Authority requires Sparrows to include on this website a disclosure about its commitment to the Code or, where it does not so commit, its alternative strategy.

Sparrows is an independently owned investment firm which provides management services to substantial professional clients across the world. As stated elsewhere on this site, our overriding objective is to protect and increase the real wealth of our clients by investing using liquid and diversified ETF and Tracker funds, in order to capture market returns across all asset classes, irrespective of geographic location.

Consistent with that objective and aim, our principal strategy is to invest in funds which are managed by other investment managers (who may have committed to the Code).

Consequently we may, consistent with the level of risk, decide to exit an investment where we disagree with the manager’s strategy and reinvest elsewhere rather than committing to spend a long period trying to change the manager’s strategy.

Therefore, while we support the general objectives behind the Code, we do not consider that it is appropriate for us to commit to the Code.

No Liability. The information on this site has been prepared, approved and issued by Sparrows. The information and opinions contained in this site have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, no representation, warranty or undertaking, express or implied, is made by Sparrows, its associated companies or any other person as to the reliability, accuracy or completeness of the information contained on this site and no liability is accepted by such persons for the reliability, accuracy or completeness of such information. In no event will Sparrows or any of its associated companies or any of their directors or other employees be liable to any person for any direct, indirect, special or consequential losses or damages of any kind arising out of any use of this site or any other hyper-linked site or in reliance on the information and opinions contained in it from time to time, including without limitation, any loss of profit, business interruption, loss of programs or data on your equipment or otherwise. This does not exclude or restrict any duty or liability that Sparrows has to its customers under the regulatory system in the United Kingdom.

You should be aware that the Internet is not a completely reliable transmission medium. Neither Sparrows nor any of its associated companies accepts any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. In addition, neither Sparrows nor any of its associated companies accept any responsibility for the security or confidentiality of information transmitted across the Internet to or from Sparrows or any of its associated companies and any such transmission of information is entirely at your own risk. This does not exclude or restrict any duty or liability that Sparrows has to its customers under the regulatory system in the United Kingdom.

Copyright, Trademarks and Other Rights. Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Sparrows, its associated companies, their licensors or relevant third party content providers. You may use the information on this site and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means – electronic, mechanical, photocopying, recording or otherwise – without the prior written permission of Sparrows. Nothing on this site should be considered as granting any licence or right under any trademark of Sparrows, its associated companies or any third party.

Governing Law. You agree that your use of this site and any dispute arising in relation to this site is subject to English law and you submit to the jurisdiction of the English courts in connection with any such dispute.

Conditions of Use. By using our website you agree on the full terms and conditions stated above.

Privacy Policy

At Sparrows Capital we are committed to safeguarding and preserving the privacy of our visitors. This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you whilst you visit our site.

We do update this Policy from time to time so please do review this Policy regularly.

Information We Collect

In running and maintaining our website we may collect and process the following data about you:

  1. Information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.
  2. Information provided voluntarily by you. For example, when you register for information or make a purchase.
  3. Information that you provide when you communicate with us by any means.

Use of Cookies

Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website.

We may gather information about your general internet use by using the cookies. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever.

You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

Use of Your Information

We use the information that we collect from you to provide our services to you. In addition to this we may use the information to provide information to you that you request from us relating to our services and to inform you of any changes to our website or services.

Storing Your Personal Data

In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing. By providing your personal data to us, you agree to this transfer, storing or processing. We do our upmost to ensure that all reasonable steps are taken to make sure that your data is treated and stored securely.

Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically. Sending such information is entirely at your own risk.

Disclosing Your Information

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

  1. In the event that we sell any or all of our business to a buyer.
  2. Where we are legally required by law to disclose your personal information.
  3. To further fraud protection and reduce the risk of fraud.

Third Party Links

On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

Access to Information

In accordance with the Data Protection Act 1998 you have the right to access any information that we hold relating to you. Please note that we reserve the right to charge a fee of £10 to cover costs incurred by us in providing you with the information.

Contacting Us

Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at info@sparrowscapital.com.