THE COMPANY

Antler Capital Partners LLP (Antler Capital) is a company registered in England and Wales with company number OC417240. Antler Capital is authorised and regulated by the Financial Conduct Authority (“FCA”) with Firm Reference Number 792820.

For the purposes of the General Data Protection Regulation (‘GDPR’), Antler Capital will be the ‘controller’ of the personal data you provide. Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data. Should you have any questions, please email us at amallet@antler-capital.com.

WHAT DATA PRIVACY PRINCIPLES DOES THE FIRM ADHERE TO?

• The Firm will process all personal data in a lawfully, fair and transparent manner;
• The Firm will only collect personal data where it is necessary;
  • For the Firm to provide a service to you;
  • For you to provide a service to the Firm;
  • For the Firm to keep you informed of its products and services; or
  • For the Firm to comply with its legal and regulatory obligations.
• The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
• The Firm will take all reasonable steps to ensure that personal data is accurate and, were necessary, kept up-to-date;
• The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
• The Firm will hold and process person data in a manner that ensures appropriate security;
• The Firm will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
• The Firm will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.

WHAT PERSONAL DATA DOES THE FIRM COLLECT AND WHY?

In the course of providing products/services to you, the Firm may collect information that is considered personal information (e.g. name, contact details, address, passport number, driving licence).

As a client, contact or employee of Antler Capital, we will require some personal information in order to verify your identity and have the applicable relationship with you. Some of this information may be required to satisfy legal obligations (e.g. to comply with obligations arising under the money laundering regulations whereas other information may be required in connection with the provision of services to you). The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:

• Personal information: Such as your name, date of birth, passport number or national insurance number;
• Contact information: Including your address, telephone number and email address.

WHERE DOES THE FIRM STORE MY PERSONAL DATA?

The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure, with these including:

• Data encryption;
• Firewalls;
• Intrusion detection;
• Antivirus and Antimalware services;
• Service monitoring;
• 24/7 physical protection of the facilities where your data is stored;
• Background checks for personnel that access physical facilities; and
• Security procedures across all service operations.

HOW LONG DOES THE FIRM RETAIN PERSONAL DATA?

As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.

Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.

HOW HAVE I BEEN CATEGORISED IN ACCORDANCE WITH GDPR?

The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:

• Clients – Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant);
• Service providers – Information is maintained on the basis of contractual obligation; and
• Database/marketing contacts – Information is maintained on the basis of legitimate interest.

WHAT ARE MY RIGHTS?

Once you have provided your details to the Firm, you have certain rights which apply, depending on your relationship with the Firm, the information you have shared with us and the Firm’s legal and regulatory obligations.

• You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at amallet@antler-capital.com . The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
• You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
• As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
• You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact amallet@antler-capital.com.
• You have the right to object to your information being processed, for example for direct marketing purposes.
• You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
• You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
• You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/) if you are not happy with the way that we manage or process personal data.

WILL I BE NOTIFIED OF CHANGES TO THIS POLICY?

The Firm may, from time to time, review and update this policy. The Firm will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.

WHO SHOULD I DIRECT QUESTIONS TO?

If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data, please email: amallet@antler-capital.com. Alternatively, you may write to: Antler Capital Partners LLP, Lansdowne House, Third floor, 57 Berkeley Square, London W1J 6ER.

INTRODUCTION

Antler Capital Partners LLP (“Antler” or the Firm) is required by the FCA to disclose information relating to the capital it holds and each material category of risk it faces in order to assist users of its accounts and to encourage market discipline.

The Capital Requirements Directive (CRD) created a revised regulatory capital framework across Europe covering how much capital financial services firms must retain. In the United Kingdom, rules and guidance are provided in the General Prudential Sourcebook (GENPRU) for Banks, Building Societies and Investments Firms (BIPRU).

The FCA framework consists of three "Pillars":

1. Pillar 1 sets out the minimum capital requirements that companies need to retain to meet their credit, market and operational risk;
2. Pillar 2 requires companies to assess whether their Pillar 1 capital is adequate to meet their risks and is subject to annual review by the FCA;
3. Pillar 3 requires companies to develop a set of disclosures which will allow market participants to assess key information about its underlying risks, risk management controls and capital position. These disclosures are seen as complimentary to Pillar 1 and Pillar 2.

Rule 11 of BIPRU sets out the provisions for Pillar 3 disclosure. The rules provide that companies may omit one or more of the required disclosures if such omission is regarded as immaterial. Information is considered material if its omission or misstatement could change or influence the decision of a user relying on the information. In addition, companies may also omit one or more of the required disclosures where such information is regarded as proprietary or confidential. The Firm believes that the disclosure of this document meets its obligation with respect to Pillar 3.

FIRM OVERVIEW

Antler is incorporated in the UK and is authorised and regulated by the FCA as an alternative investment fund manager, pursuant to the Alternative Investment Fund Managers Directive, giving the Firm a prudential categorization of a collective portfolio management investment firm, subject to IPRU-INV and BIPRU.

Antler is not part of a UK Consolidation Group and, as such, this Pillar 3 Disclosure has been produced on a solo basis.

The Governing Body of Antler has the daily management and oversight responsibility. It generally meets quarterly and is composed of:

1. Georges Gedeon

The Governing Body is responsible for the entire process of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Board decides Antler’s risk appetite or tolerance for risk and ensures that Antler has implemented an effective, ongoing process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed. Senior Management is accountable to the Governing Body for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of Antler.

CAPITAL RESOURCES & REQUIREMENTS

CAPITAL RESOURCES

PILLAR 1

As of 31 December 2021, the Firm on a solo basis held regulatory capital resources of £151,930, comprised solely of core Tier 1 capital of members' original capital contributions.

The Firm’s capital requirements are the greater of:

1. Its base capital requirement of €50,000;
2. The sum of its market and credit risk requirements; or
3. Its fixed overhead requirement (FOR).

The firm is required to as a CPMI firm to maintain at all times ‘own funds’ which equal or exceed the higher of:

1. Funds under management requirement of €125,000 plus 0.02% of the amount by which FUM exceed €250,000)
2. The sum of its market and credit risk OR Own funds based on FOR
3. Plus PII Capital requirement based on the excess for professional liability risk

As at 31 December 2021, the Firm's Pillar 1 capital requirement was £115,042.

SATISFACTION OF CAPITAL REQUIREMENTS

PILLAR 2

The Firm has adopted the “Structured” approach to the calculation of its Pillar 2 Minimum Capital Requirement as outlined in the Committee of European Banking Supervisors Paper, 27 March 2006 which takes the higher of Pillar 1 and 2 as the ICAAP capital requirement. It has assessed Business Risks by modeling the effect on its capital planning forecasts and assessed Operational Risk by considering if Pillar 2 capital is required taking into account the adequacy of its mitigation.

Since the Firm's Internal Capital Adequacy Assessment Process (ICAAP or Pillar 2) process has not identified capital to be held over and above the Pillar 1 requirement, the capital resources detailed above are considered adequate to continue to finance the Firm over the next year. No additional capital injections are considered necessary and the Firm expects to continue to be profitable.

RISK MANAGEMENT

The Firm has established a risk management process in order to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the Firm's members.

As risks are identified within the business, appropriate controls are put in place to mitigate these and compliance with them is monitored on a regular basis. The frequency of monitoring in respect of each risk area is determined by the significance of the risk. The Firm does not intend to take any risks with its own capital and ensures that risk taken within the portfolios that it provides advice to is closely monitored. The results of the compliance monitoring performed is reported to the partners by the Compliance Officer.

OPERATIONAL RISK

The Firm places strong reliance on the operational procedures and controls that it has in place in order to mitigate risk and seeks to ensure that all personnel are aware of their responsibilities in this respect.

The Firm has identified a number of key operational risks. These relate to disruption of the office facilities, system failures, trade failures and failure of third party service providers. Appropriate policies are in place to mitigate against risks, including appropriate insurance policies and business continuity plans.

CREDIT RISK

The main credit risk to which the Firm is exposed is in respect to the failure of its debtors to meet their contractual obligations. The majority of the Firm's receivable is related to investment management activities. The Firm believes its credit risk exposure is limited since the Firm’s revenue is ultimately related to management fees received from funds. These management fees are drawn throughout the year from the funds managed. Other credit exposures include bank deposits and office rental deposits.

The Firm undertakes periodic impairment reviews of its receivables. All amounts due to the Firm are current and none have been overdue during the year. As such, due to the low risk of non-payment from its counterparties, management is of the opinion that no provision is necessary. A financial asset is overdue when the counterparty has failed to make a payment when contractually due. Impairment is defined as a reduction in the recoverable amount of a fixed asset or goodwill below its carrying amount.

The Firm has adopted the standardised approach to credit risk, and therefore follows the provision within BIPRU 3 standardised credit risk of the FCA handbook. The Firm applies a credit risk capital component of 8% to its non-trading book risk weighted exposure. As the Firm does not make use of an external credit rating agency, it is obligated to use a risk weight of 100% to all non-trading book credit exposures, except cash and cash equivalents which are held by investment grade firms and currently attract a risk weighting of 20%.

The table below sets forth the Firm's credit exposures and corresponding capital resource requirements as of 31 December 2020:

MARKET RISK

Since the Firm holds no trading book positions on its own account, and all bank accounts are in GBP and all advisory fee income is in GBP, the Firm’s exposure to foreign currency risk is not significant. Since the settlement of debtor balances take place without undue delay, the timing of the amount becoming payable and subsequently being paid is such that it is not considered to present a material risk to the Firm. The Firm has excluded Market risk on the basis that it is not a material risk to the Firm.

REMUNERATION CODE

The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19B of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (SYSC and in accordance with ESMA’s Guidelines on sound remuneration policies). The Firm have considered all the proportionality elements in line with the FCA Guidance.

Remuneration is designed to ensure that the firm does not encourage excessive risk taking and staff interests are aligned with those of the clients. Variable remuneration is adjusted in line with capital and liquidity requirements as well as the Firm’s performance. The Governing Body will review the remuneration strategy on an annual basis together with the Remuneration (“Code Staff”).

As a UK AIFM the Firm has assessed the proportionality elements and disapplies the Pay Out Process Rules. Furthermore, the Firm has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the Governing Body sets, and oversees compliance with, the Firm's remuneration policy including reviewing the terms of the policy at least annually.

The Firm ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all Code and Non-Code staff. Total Remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit. The Firm will monitor the fixed to variable compensation to ensure SYSC 19B is adhered to with respect to Total Compensation where applicable.

In accordance with SYSC 19B, the Firm makes the following quantitative remuneration disclosure:

Code Staff Quantitative Remuneration as of 31/12/20

The Firm is required to disclose aggregate information on remuneration in respect of its Code Staff, broken down by business area and by senior management and other Code Staff. Senior management and members of staff whose actions have a material impact on the risk profile of the Firm are classified as Code Staff.

Code Staff Remuneration