Annual Disclosure Report

for the Financial Year 2023


This report is prepared in accordance with the regulatory disclosure requirements as applicable to Quay Financials (Gibraltar) Limited. It is designed to provide transparent and comprehensive information about our firm’s financial status, risk management policies, governance structure, and other relevant aspects as per the stipulated guidelines.

Section 1: Disclosure Timing and Methodology

Consistent with regulatory directives, Quay Financials (Gibraltar) Limited is disclosing the following information concurrently with the publication of our annual financial statements for the financial year 2023.

Section 2: Risk Management Objectives and Policies

At Quay Financials (Gibraltar) Limited, our approach to risk management is both comprehensive and proactive, ensuring alignment with IFPR framework and industry best practices. Our strategies and processes for managing various risk categories include:

  1. Market Risk Management: - Advanced analytical tools are employed to assess and mitigate market risks. This includes regular monitoring of market movements, stress testing, and scenario analysis.
  2. Credit Risk Assessment: - Thorough due diligence of counterparties, continuous creditworthiness assessment, and setting exposure limits are integral to managing default risks.
  3. Liquidity Risk Control: - We maintain sufficient liquidity buffers and conduct regular liquidity stress tests, ensuring our asset-liability management aligns with our operational needs.
  4. Operational Risk Oversight: - Robust internal controls, regular audits, and compliance checks are in place to manage technology, human resources, and external event risks.
  5. Compliance with Regulatory Requirements: - Continuous monitoring of regulatory standards is conducted to ensure compliance with MiFID regulations and other legal requirements.
  6. Conflict of Interest Management: - A strict policy is maintained to identify, prevent, and manage conflicts of interest, safeguarding the integrity of our operations and client interests.
  7. Investment Strategy Alignment: - Investment strategies are regularly reviewed to align with client risk tolerance, market conditions, and our business objectives. The Board of Directors oversees these risk management processes, ensuring integration into our corporate strategy and providing regular reports for informed decision-making.

Section 3: Governance


Edward le Feuvre: 10 Directorships Michael Bertges: 2 Directorships

b. Diversity Policy:

Quay Financials (Gibraltar) Limited is committed to fostering a diverse and inclusive workplace, especially within our management body. Our policy focuses on diversity in gender, age, cultural background, and professional experience.

c. Risk Management by the Board:

Risk management is overseen by the Board, which reviews and manages risks on a quarterly basis.

Section 4: Financial Disclosure

Own Funds as at 31 December 2023

as at 31 December 2023

OWN FUNDS Composition and quality of capital [1] £’000s
Tier 1 Capital 770
Tier 2 Capital 0
Deductions 0
Own Funds Total 770
CAPITAL REQUIREMENTS Quantitative requirements [2] £’000s
Minimum capital requirement 735
Fixed Overhead Requirements 99
K-Factor requirements 23

[1] Audited accounts as at 31 December
[2] Invoke return and ICARA effective date 31 December 2023

Compliance with Capital Requirements:

As of the reporting date, Quay Financials (Gibraltar) Limited remains fully compliant with all regulatory capital minimum requirements as set out in the IFPR. This compliance is ensured through rigorous internal controls and continuous monitoring of our capital levels. During the reported period, there were no breaches of external capital requirements, reflecting our firm’s strong commitment to maintaining financial stability and adhering to regulatory standards.

Risk Management Practices (K-Factors) and Fixed Overhead Requirement:

As set out above in the section 2 our risk management framework identifies, assesses, manages, and monitors each type of risk associated with our business activities in a format consistent with the IFPR, K-Factor and ICARA reporting. Our risk management strategy is integrated into the firm’s daily operations, overseen by the Risk Management Officer, which includes members from various senior management levels. Risk appetite as set out above remains extremely low when compared to own funds.

Additional financial disclosure is available upon request.

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Section 5: Remuneration Policy and Practices

  1. Introduction: - Quay Financials (Gibraltar) Limited’s Remuneration Policy adheres to the Investment Firm Prudential Regime (IFPR) in Gibraltar, aiming to align remuneration with risk management, promote responsible behaviour, and comply with regulatory requirements.

  2. Objectives: - Our objectives include aligning remuneration with our business scale and complexity, ensuring gender-neutral equal pay, promoting effective risk management, aligning with strategic goals, mitigating conflicts of interest, and enhancing risk awareness.

  3. Governance and Implementation: - The Board of Directors oversees the policy as the Remuneration Committee, conducting annual reviews and ensuring compliance with IFPR Regulations and the Remuneration Code.

  4. Guidance by Regulatory Authorities: - We follow guidance from regulatory authorities, including clear organizational structures, risk management, internal control mechanisms, and remuneration policies supporting risk management.

  5. Promotion of Effective Risk Management: - Our firm commits to remuneration practices that promote effective risk management, aligning remuneration with our risk posture.

  6. Covered Aspects of Remuneration: - The policy covers salaries, bonuses, options, hiring bonuses, severance packages, and pension arrangements, adhering to statutory duties regarding equal pay and non-discrimination.

  7. Bonus Pool Consideration: - The board assesses future risks and uncertainties in determining bonus pool allocations.

  8. Comprehensive and Proportionate Approach: - Our approach is comprehensive and proportionate to our activities, ensuring compliance with IFPR Regulations and the Remuneration Code.

  9. Record Keeping: - We maintain clear records of our remuneration policies, practices, and procedures.

  10. Remuneration Code Staff: - This includes senior management, risk takers, staff in control functions, and those significantly affecting the firm’s risk profile. Records are kept, and staff are informed of their status under the Remuneration Code.

  11. Fixed and Variable Remuneration: - Our policy distinguishes between fixed and variable remuneration, maintaining an appropriate balance and considering financial and non-financial criteria for performance assessment.

  12. Conclusion: - This policy underscores our commitment to responsible and risk-focused remuneration practices, essential for a sound and sustainable financial services operation.

Employee Category Total Remuneration for the year ended 31 December 2023 Variable Remuneration Deferred Percentage Notes
Executive Management 93,962 ~ 60,000 33,962 0.00% Focus on long-term risk management
Risk Control Executive 39,500 ~ 39,500 ~ 0.00% Focus on fixed salary to maintain independence
Other Employees ~ 132,431 123,292 9,139 0.00% Bonuses linked to financial performance and compliance
Total ~ 265,893 222,792 43,101 0.00% ~

Section 6: Compliance Statement

We, Quay Financials (Gibraltar) Limited, hereby affirm that all the information provided in this report is accurate and in full compliance with the regulatory disclosure requirements as of 31 December 2023.


Michael Bertges Director 31 April 2024