Our people reflect our deeply held beliefs. Sparrows Capital brings together a wealth of knowledge and expertise spanning the academic, technical and practical elements of evidence based investment management.
Yariv has over ten years of experience in strategic investments, risk management and asset allocation. Yariv is the key executive and investment manager at Sparrows Capital. He has worked with the Eliashar family for more than 20 years.
Yariv is a sought-after lecturer in wealth management and efficient investment strategies. He holds a BA in Economics and an Executive MBA from Tel-Aviv University.Email
Until March 2012, Steven was managing partner of the London office of international law firm Dechert LLP, where he also served for many years as a board member. He was the senior partner at Titmuss Sainer before its merger in 2000.
He was Chair of Uropharma, a medical device company, until 2018 and a non-executive member of the board of international solicitors, King & Wood Mallesons, formerly SJ Berwin LLP until 2016. From 2008 to 2010 he was on the advisory board of surveyors CWM. He is currently on the board of the Family Office of the Landon Trusts.
As well as having served on the University of London’s Board of Trustees and currently advising on their estates strategy, Steven has also worked with a number of not-for-profit organisations, including the international wheelchair charity Motivation, the Freud Museum and the Hofesh Schechter Dance Company.Email
Professor Elroy Dimson
Consultant to the Board
Consultant to the Board
Elroy has chaired the Strategy Council for Norway’s Government Pension Fund Global and the Policy Committee for the FTSE Group. He co-directs the Centre for Endowment Asset Management at Cambridge Judge Business School and is Emeritus Professor of Finance at London Business School. His publications include Triumph of the Optimists, Endowment Asset Management, and the Global Investment Returns Yearbook. He has been an Associate Editor of Journal of Finance, Review of Finance and other journals.
A co-designer of the FTSE 100 index, Elroy chairs FTSE Russell Policy Advisory Board and serves on the Council of Financial Analysts Journal. He is on the investment committees of Guy’s & St Thomas’ Charity and the Foundation for Social Entrepreneurs. He is past President of the European Finance Association, and Honorary Fellow of the CFA Society of the UK (FSIP) and of the Institute of Actuaries. He has received the CFA Institute’s James Vertin award, the Moskowitz prize, and the Bernstein Fabozzi/Jacobs Levy award. He holds a PhD from London Business School, an MCom from the University of Birmingham, and a BA Economics from the University of Newcastle.Email
Independent Non-Executive Director
Claire is an experienced practitioner with over 20 years’ experience in the Asset Management and Investment Management industry. After four years as a Product Manager at Henderson Global Investors, Claire joined BlackRock in 2005 where she fulfilled a number of senior roles in distribution, concluding with her promotion to Managing Director, Head of DC, Unit-Linked and Platforms.
She serves as an Independent Non-Executive Director on the Boards of Artemis Fund Managers Limited and The Law Debenture Corporation plc. She is also a Governor of St. Joseph’s Catholic Primary School.
Claire holds a BA Hons in Modern Languages from the University of Leeds and an MSc in Finance from the University of London, Birkbeck College. She holds the IMC.Email
Independent Non-Executive Director
Rupert acts as a Strategic Adviser to global Private Equity firms, and serves as an Independent Non-Executive Director on the board of JP Morgan Elect plc and the Investment Committee of the National Trust for Scotland.
He is a member of The Institute of Chartered Accountants of Scotland, with a LLB (Hons) Law Degree and over 20 years’ experience in the Wealth and Investment Management industry.
After four years as an auditor at Deloitte, Rupert joined Barclays in 2000, where he spent 13 years in a number of senior roles ranging from Finance, Commercial and Product Development to Chief Operating Officer, before concluding with his promotion to CEO of Barclays Stockbrokers Limited and a Member of the Executive Committee of Barclays Wealth Management Division. During this time he also served as a Non-Executive Director on the boards of ABSA Stockbrokers and PIMFA (the trade association of UK Wealth Managers).Email
Mark is a seasoned practitioner in financial markets with wide ranging managerial and governance experience across credit, fixed income, equity and treasury markets. His knowledge spans multiple disciplines including marketing, trading, investment and the management of complex financial and regulatory risk.
Mark has previously worked for LBBW, Rabobank and Standard Chartered Bank, and chairs the UK Individual Shareholders Society (ShareSoc).
He holds a BA (Exeter), an MBA (Open) and the IMC.Email
Dr. Raymond Backreedy
With over a decade of professional experience within the financial marketplace, Raymond combines PhD level mathematical, statistical and engineering skills with honed logic and reasoning. His experience includes hands-on research, development and management of quantitative models and portfolios in both the traditional passive and alternative asset classes. He was a founding partner at Evolutionary Trading and Tekio Capital.
Most recently Raymond acted as consultant to the executive committee and board of trustees of a large Dutch pension fund, where he was involved in quantifying the impact of regulatory changes on their investment processes.
Raymond has a PhD and MEng from the University of Leeds in Fuel and Energy Engineering.Email
John has an established financial services career spanning 30 years in the City of London. He has a broad range of experience having advised HNW individuals as Managing Director of the financial advisory arm of a top 20 accountancy practice. He then spent 10 years at alternative investment house Man Investments as Head of UK Retail Distribution and subsequently at UBS, managing UK distribution for their alternative investments platform.
More recently he was partner at systematic index engineer QLAB Invest AG and also spent time in the Fintech sector before joining Sparrows Capital.Email
Paul has over 30 years’ investment experience including 22 years with Schroders and GAM in London and Bermuda and more recently three years as a consultant to EFG Asset Management.
He specialises in working with fiduciaries, legal and tax advisers, investment consultants and family offices to provide specialist investment solutions for UK and international families’ private wealth and for charitable foundations.
A regular presenter at investment seminars for fiduciaries, Paul was invited by STEP to be a founding member of the Practitioners’ Group overseeing the Managed Portfolio Indices (MPI).
Paul holds a BSc in Banking and International Finance from Cass Business School, London.Email
John is a founding partner of Family Office Advisors LLP, a consulting
company which advises on Investment Strategy and Risk for UK and
multi jurisdictional Single Family Offices, families and trust companies.
In addition, he acts in a general advisory capacity, including Investment
Oversight and Reporting, to Single Family Offices, Trustees, family
operating companies, governance boards and family members.
John serves as Independent Non-Executive Director on the boards of
investment funds and companies and also advises on, establishes or
restructures investment and reporting solutions for regulated
investment & wealth managers.
Previously, John was Managing Director of Multi Manager Investment
Solutions for EMEA, within the Global Family Offices group at Northern
Trust in London, he established the Family Office Services business in
the UK for Mellon and also established the Investment Consulting
practice in the UK for EY.
David joined Sparrows Capital in 2020 and is responsible for the firm’s compliance function.
He was previously head of compliance at Seven Investment Management LLP since 2007. Prior to that headed compliance at ABN Amro Private Bank and AXA Investment Managers UK.
David is a Chartered Fellow (by Diploma) of the Chartered Institute for Securities and Investment.Email
Sophie has a comprehensive knowledge of the industry, with over 10 years’ experience of working with financial advice firms, platforms and DFMs.
Prior to moving into Business Development she worked as a paraplanner for a number of years, providing a strong understanding of the needs of financial advisers and their clients.
More recently, Sophie worked in the FinTech sector where she was responsible for managing the launch of a range of risk-rated model portfolios.
International Man of Mystery
Jason joined Sparrows Capital in early 2020 from Tanager Wealth Management.
He has a BSc in Economics and Business Management and an MBA.
He holds the CISI Investment Advice Diploma and Investment Management Certificate.Email
Alistair has over 30 years’ experience in financial markets as a broker, trader and fund manager. His areas of knowledge span Fixed Income, Equities and Derivatives of all types, working both in the City of London and more recently, for two Local Authority Pension funds.
In the last 5 years, he has been focussed on evidence based Index investing, catering to the IFA market, providing detailed investment advice and commentary to help them navigate the increasingly complex world of financial markets.
Alistair was a CFA charter holder from 2004-2019 and passed the IMC exam in 2016.
He holds a BA in Politics from Liverpool University.Email
International Man of Mystery
Gary is responsible for the IT infrastructure at Sparrows Capital.
He came to Sparrows Capital from FIXI plc, a global FX brokerage, and has previously worked at Infinity Capital Markets, Brevan Howard, Goldman Sachs, Morgan Stanley and UBS.
We don’t hold this against him!Email
She is fab!Email
We believe that investment decisions should be based on empirical evidence backed by robust academic studies.
Our disciplined, objective approach combines lessons from over a hundred years of market data with the insights from Nobel prize winning research.
Risk is the primary driver of returns. Risk appetite dictates portfolio construction, which in turn drives expected investment returns. Targets and benchmarks must be consistent with a bespoke risk profile. Certain risks are historically better rewarded than others, and careful blending of risks can improve portfolio performance across the cycle.
We harvest strategic beta (the market return) in a highly cost efficient manner across the core liquid portion of our clients’ portfolios, leaving them free to identify and select complementary satellite investments.
The compound effect of management and transaction fees has the capacity to substantially erode portfolio performance over time. We use low cost, rule-based investment vehicles for maximum efficiency.
Loss aversion is a natural human behaviour, one which is often responsible for underperformance through ill-timed intervention and consequent lost opportunity. Our approach uses systematic rebalancing to maintain consistency of risk throughout the cycle.
At Sparrows Capital we provide full transparency to ensure consistency of understanding and to reduce client workload and stress. Our clients’ assets are held on their chosen platforms under their direct ownership. Reporting is clear, simple and intuitive.
Diversification acts to reduce overall portfolio risk without sacrificing long term expected return. We build in multi-layered diversification at asset class, geographic and underlying security level.
We invest primarily via ETFs and Index Funds. All our holdings benefit from full daily liquidity to ensure that access is unrestricted and that clients can retrieve their money at any time.
Making investing simpler and more efficient.
A leader in providing excellent investment portfolios at exceptional value for money for investors and their advisers.
These are the Pillar 3 disclosures made by Sparrows Capital Limited (“Sparrows”) in accordance with the UK Financial Conduct Authority’s (“FCA”) Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”).
The European Union Capital Requirements Directive (“CRD”) created a regulatory capital framework consisting of three ‘pillars’ namely:
Pillar 1 – sets out the minimum capital requirements that firms are required to meet;
Pillar 2 – requires firms to take a view on whether additional capital should be held against capital risks not covered by Pillar 1; and
Pillar 3 – requires firms to publish certain details of their risks, capital and risk management process.
The rules in BIPRU 11 provide that Sparrows may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where Sparrows considers a disclosure to be immaterial, this will be stated in the relevant section.
Sparrows is also permitted to omit one or more of the required disclosures where it believes that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine Sparrows’ competitive position. Information is considered to be confidential where there are obligations binding Sparrows to confidentiality with its clients and counterparties.
Where Sparrows has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.
Unless stated as otherwise, all figures contained in this disclosure are based on Sparrows’ audited annual reports for the year ending 31 December 2020.
These Pillar 3 disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of Sparrows’ Internal Capital Adequacy Assessment Process (“ICAAP”) and its annual accounts.
The information contained in these disclosures has not been audited by Sparrows’ external auditors and does not constitute any form of financial statement.
Sparrows’ Pillar 3 disclosures are published on its website.
Scope and application of CRD requirements
These disclosures are made in respect of Sparrows, a BIPRU firm authorised and regulated by the FCA, providing financial advice and discretionary investment management services.
Risk management objectives and policies
Sparrows’ risk management policy reflects the FCA requirement that it must manage a number of different categories of risk. These include: liquidity; credit; interest rate; market; and operational risks.
Sparrows manages all cash and borrowing requirements to maximise potential interest income whilst ensuring it has sufficient liquid resources to meet the continued operating needs of its business. This is supported by a robust budgeting and forecasting process that has the full involvement of the senior management team.
The main credit risk for Sparrows relates to income from fees, the risk being that a client does not pay amounts due for services provided by Sparrows. In most cases, management fees are charged to clients on a quarterly basis. Concentration risk is defined as the risk of loss of income through external changes having a disproportionate impact on overall income due to a reliance on revenue from certain sectoral, geographic areas and/or businesses. Credit risk concentrations include significant exposure to an individual client or group of clients and credit exposures to clients in the same economic sector or geographic region.
A significant proportion of Sparrows’ income is received from clients that are part of the same group as Sparrows’ major shareholders. This ongoing interest in the activities of Sparrows by the group mitigates the risk of the group jeopardising Sparrows’ income flow.
Sparrows is exposed to country risk as a number of clients are based in a non-European Economic Area country. As these clients are all high net worth or ultra-high net worth long-term investors with spare capital invested in globally diversified liquid financial instruments, the risk of being unable to meet unforeseen financial needs and payment of Sparrows’ fees is low.
Based on the analysis of concentration risk, the risk of non-payment of fees has been assessed as minimal.
Sparrows has no exposure to interest rate risk as it has no debt, no margin, and no client cash deposits.
The main market risk for Sparrows relates to falls in the value of assets under management following a market downturn, which would lead to lower management fees. To mitigate its market risk, Sparrows regularly analyses various different economic scenarios to model the impact of economic downturns on its financial position.
Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.
Major potential sources of operational risk include outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.
Sparrows operates a robust risk management process that is regularly reviewed and updated by its Board. The Board formally reviews all significant risk issues at least annually as part of the ICAAP.
All senior members of staff bear responsibility for internal controls and the management of business risk as part of their accountability to the Board. All staff are responsible for identifying the risks surrounding their work, implementing controls over those risks and reporting areas of concern to their senior member of staff.
Sparrows operates a simple business model. Accordingly, many of the specific risks identified by the FCA do not apply. For example, the firm has no material outsourcing arrangements and does not hold client assets.
Pillar 1 requirement
In accordance with the FCA rule GENPRU 2.1.45R (calculation of variable capital requirement for a BIPRU firm), Sparrows’ capital requirement has been determined as being its fixed overhead requirement and not the sum of its credit risk capital requirement and its market risk capital requirement.
The Pillar 1 capital requirement for Sparrows was £384,000 as at 31 December 2020.
Pillar 2 requirement
Sparrows’ overall approach to assessing the adequacy of its internal capital is set out in its ICAAP report. The ICAAP involves separate consideration of risks to Sparrows’ capital, combined with stress testing using scenario analysis. The level of capital required to cover risks is a function of impact and probability. Sparrows assesses impact by modelling the changes in its income and expenses caused by various potential risks over a 1-year time horizon. Probability is assessed subjectively. In addition, Sparrows has reviewed the outputs of its risk reviews to quantify any risks identified. This has identified a number of key business risks, which (having reviewed the guidance in BIPRU 2.2.61-65) Sparrows has classified against the risk categories outlined in FCA rule GENPRU 1.2.30R.
Sparrows Pillar 2 capital requirement, which is its own assessment of the minimum amount of capital that it believes is adequate against the risks identified, has been assessed as no greater than its Pillar 1 requirement.
There is a considerable surplus of reserves above the capital resource requirement deemed necessary to cover the risks identified.
The main features of Sparrows’ capital resources for regulatory purposes, as at 31 December 2020 are as follows:
|Tier 1 capital (called up share capital, share premium account, profit and loss account, externally verified interim net profits)||1,140|
|Total of Tier 2 and Tier 3 capital (broadly long and short term subordinated loans)||–|
|Deductions from Tier 1 and Tier 2 capital||–|
|Total capital resources, net of deductions||1,140|
Sparrows holds regulatory capital in accordance with the CRD. All such capital is classified as Tier 1 capital and is therefore of the highest quality.
Remuneration Code Disclosures
Sparrows is subject to the BIPRU Remuneration Code. This section provides further information on Sparrows’ remuneration policy.
BIPRU Remuneration Code Staff
Sparrows has identified, and maintains a record of, BIPRU Remuneration Code staff (“Code staff”), i.e. staff to whom the BIPRU Remuneration Code applies. This includes senior management and members of staff whose actions may have a material impact on Sparrows’ risk profile. All of Sparrows’ Code staff fall into the “senior management” category of Code staff (rather than the “risk taker” category) for the purposes of the BIPRU Remuneration Code.
Decision Making / Remuneration Committee
Sparrows does not have and is not required to have a Remuneration Committee. The Board is responsible for Sparrows’ remuneration policy including determining the framework and policy for remuneration and ensuring it does not encourage undue risk-taking; agreeing any major changes in remuneration structures; reviewing the terms and conditions of any new incentive schemes and in particular, considering the appropriate targets for any performance-related remuneration schemes; and considering and recommending the remuneration policy for senior staff taking into account the appropriate mix of salary, discretionary bonus and share-based remuneration.
In determining remuneration arrangements, the Board will give due regard to best practice and any relevant legal or regulatory requirements including the BIPRU Remuneration Code.
Link between pay & performance
There is a discretionary variable pay element to the Sparrows’ remuneration package.
Quantitative information on remuneration
The FCA rules require certain firms to disclose aggregate information on remuneration in respect of its BIPRU Remuneration Code staff broken down by business area, senior management and other Code staff, including “risk takers”.
Sparrows has only one business area – investment management & advice.
Sparrows has 5 Directors but no material “risk takers”. Director remuneration is agreed formally at Board meetings. The link between performance and pay is inevitable in a small firm, but Sparrows’ risk-averse strategy and robust risk management systems mitigate any risks.
We do update this Policy from time to time so please do review this Policy regularly.
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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.
In accordance with the General Data Protection Regulation (GDPR) you have the right to access any information that we hold relating to you. Please note that a reasonable charge may be payable.