W&W Investment Managers DAC, (“We” the “Firm” and “WWIM”) provides portfolio management and investment advisory services as regulated by the Central Bank of Ireland under MiFID. WWIM provides services to two eligible counterparties.

The CRD often referred to as Basel II, requires Investment Firms to publish certain information relating to their risk management and capital adequacy.

We believe that capital held by our business is more than sufficient to meet our needs in the next financial year and that procedures are in place to identify and manage the risks that we face.

This Pillar III disclosure will be made on an annual basis. There is no need to publish more frequently, given the nature, scale and complexity of the firm and given the Firm is abundantly capitalised.

Responsibility for the Management of Risk

The Firm recognises the importance of each employee having a role in managing risk and therefore operates a three lines of defence model.

Good risk management starts with good organisation and governance. The Firm’s Board of Directors sets the tone of risk management by putting in place the Firm’s Risk Management Policies and determining the Firm’s Risk Appetite relative to the Firm’s objectives and the nature, scale and complexity of the Firm.

Our Risk Management Framework, which is reviewed and approved by the Board, documents the risks facing both the Firm and the funds we service as well as detailing our policies and controls for managing those risks.

Balance and independence are important to the Firm; our Board has executive and non-executive director representation and consistent with our roots, the Firm’s parent company, W&W Asset Management GmbH is represented on the Firm’s Board.

In addition to the extensive risk management experience within the Firm, our three lines of defence model includes proven established partnerships with expert industry firms.

The Firm’s Board receives regular reporting from the senior management team. Where a breach of Firm policy or Risk Appetite has occurred, the Board receives detailed reporting of the incident in the periodic reporting. Where a material risk item has emerged, the senior management team will engage the Firm’s Board without delay.

Key Risks Faced by the Firm:

Credit Risk

As the Firm is abundantly capitalised, this capital is subject to credit risk. The Firm manages this credit risk by depositing capital with multiple credit institutions and an investment vehicle.

Operational Risk

The Firm manages the risk of loss from inadequate or failed internal processes by closely monitoring actual and potential events against defined quantitative and qualitative limits. WWIM has robust controls in place for the identification, mitigation and reporting of operational risks. Any incidents are assessed for root cause. The three lines of defence model ensures transparency and that remediation is subjected to adequate independent challenge.

Regulatory Compliance Risk

The risk of non-compliance with regulations can have a far-reaching negative impact on any investment firm. As such, compliance with regulations is a key focus for WWIM and we have robust systems and controls for the mitigation of regulatory compliance risk. The Firm monitors all actual and potential regulatory changes closely and relies on the high levels of experience of its employees and service providers.

Business Risk

WWIM’s business is providing investment management and advisory services. The firm is therefore exposed to the risk of adverse market conditions.

Capital Adequacy

We keep the Firm’s capital under ongoing review. Our ICAAP is approved by the Firm’s Board annually and the output of the ICAAP is considered quarterly by the Firm’s Board. WWIM is abundantly capitalised with respect to its regulatory capital requirements. As at 31st December 2020, the Firm’s Own Funds requirement was EUR1.7million and the Firm’s Regulatory Own Funds (and excess capital) was a multiple of this figure.