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 2022.

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

Financial disclosure 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.

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 [Date of Report].


Michael Bertges