IFPR regulatory disclosure
MIFIDPRU 8 Disclosure
Canada Life Asset Management Limited (CLAM) operates as a MiFID Investment Firm within the Canada Life UK group of companies.
As an FCA authorised and regulated firm, it is required to meet the FCA’s capital resource requirements set out in MIFIDPRU, including at all times to hold own funds and liquid assets which are adequate, both as to their amount and their quality. This is to ensure it can remain financially viable throughout the economic cycle, with the ability to address any material potential harm that may result from its ongoing activities and to ensure the business can be wound down in an orderly manner, minimising harm to consumers or to other market participants.
Business Background
CLAM is a subsidiary of Canada Life UK Holdings Limited and is part of Great-West Lifeco (GWL). The CLAM Board has four members, including one independent non-executive director. Whilst there is a day-to-day management team, CLAM operates as part of the Canada Life UK Division and shares a number of functions with other group companies. Staff are employed by CLFIS.
CLAM had a dual business model of, firstly, serving the balance sheet asset management needs of a number of Group companies within the wider Canada Life group and, secondly, providing asset management for external clients. On 1st October 2025, CLAM transferred the external client asset management service to Keyridge Asset Management Limited as part of a larger asset management restructure across the Canada Life companies in Europe.
CLAM supports Keyridge through the provision of fixed interest fund management solutions to their external clients in a sub-advisory role.
CLAM now focuses on managing balance sheet portfolios, working alongside the GWL investment teams in Canada and the US to source and manage assets to support the Group’s insurance clients around the world.
Governance, Diversity & Conflicts of Interest
CLAM is governed by its Board, comprised of directors who have the necessary skill and experience, and can commit sufficient time, to leading and controlling CLAM.
The Executive Management Committee meets regularly to review all aspects of CLAM’s business including business strategy, planning, and financial results. There is also a Risk Oversight Committee, overseeing the Enterprise Risk Management framework and the preparation of the ICARA, an Investment Management Committee, overseeing the general account and external mandate compliance and other key asset management activity, and a Change Steering Committee with is accountable for providing direction and oversight of strategic change.
The responsibilities of the Chief Risk Officer and the Chief Compliance Officer are set out in their respective mandates. The responsibilities of the 2nd Line Risk and Compliance function are described within their policies, standards, and operating procedures.
Through its Diversity Policy, the Board recognises and promotes the value of appointing individual directors who bring a variety of opinions, experience, skills and backgrounds to its discussions and decision-making processes.
CLAM maintains a Conflicts of Interest Policy and register, which serves to identify any potential conflicts of interest generated by its business activities and/or the conduct of colleagues, together with the appropriate management controls. Conflicts of Interest may arise for CLAM in areas such as trading and investment management including personal account dealing and gifts and hospitality. Controls include segregation of duties in respect of the trading and management of investments. The Conflicts of Interest Policy has a range of associated policies and standards, which together form a control framework, overseen by the Investment Governance team and an independent Risk and Compliance function.
Risk Management Objectives and Policies
CLAM operates under the CLUK Enterprise Risk Management (ERM) framework, which effected by the company’s Board of Directors, management, and other personnel, applied in conducting business, making business decisions and strategy setting, across all areas of the company. The ERM framework is designed to identify potential events or emerging issues that may cause harm to CLAM, its customers and/or the broader financial markets. The effective implementation and operation of the ERM framework allows CLAM to manage risks to be within its risk appetite and provide reasonable assurance regarding the risk consequences of achievement of CLAM’s objectives.
ERM encompasses aligning risk appetite and strategy, enhancing risk informed decisions, reducing operational surprises and losses, identifying, and managing multiple risks, seizing appropriate business opportunities, improving deployment of capital and feeds directly into the ICARA.
The ERM framework is the framework through which the Board and management establish CLAM’s risk strategy, articulate, and monitor adherence to the risk appetite and risk limits, and identify, measure, manage, monitor, and report on risks. The effective operation of CLAM’s ERM framework supports and facilitates successful delivery of its strategic business objectives, protects customers from harm and helps maintain the integrity and resilience of financial markets.
A key component of an effective ERM framework is the Three Lines of Defence model. This introduces a clear delineation of responsibilities for risk management between the business areas, the Risk and Compliance function and Internal Audit. Such delineation allows appropriate ownership, oversight, and assurance. The three separate lines of defence provide the Board with greater comfort that the risk framework is comprehensive, suitable, and operates effectively.
Central to risk management within CLAM is the Risk and Compliance function. The Risk and Compliance function, headed by the Chief Risk Officer, has oversight responsibility for all aspects of the ERM framework.
Risk Appetite
CLAM willingly accepts and manages risk when doing so is necessary to achieve its business objectives. Qualitative Risk Appetite Statements are set, reflecting the Board’s view of key operational aspects, enabling the business to assign risk-related parameters to their strategic vision and goals, these are set out below:
- Maintaining a Strong Capital Position – CLAM ensures the delivery of obligations to customers by maintaining a strong balance sheet and not taking risks that would jeopardise the solvency of the company. CLAM will manage its business such that it will hold sufficient assets to cover its liabilities and regulatory capital requirement, even after stressed conditions. CLAM has established controls and Key Risk Indicators to monitor its Solvency Ratio and escalate any risks to the appropriate senior management and where required, the Board.
- Maintaining a Strong Liquidity Position – CLAM has sufficient asset liquidity in order to meet the demands of customers and financing obligations under normal and stressed conditions. CLAM maintains, monitors, and manages its liquidity in order that it can continue to meet its obligations under stressed conditions and has sufficient quality liquid assets to cover its Liquid Assets Threshold Requirement. CLAM has established controls and Key Risk Indicators to monitor its Liquidity Ratio and escalate any risks to the appropriate senior management and where required, the Board.
- Maintaining the Company’s Reputation – CLAM has no appetite for business practices which may damage the Company’s reputation. The potential impact on the reputation of the Company is considered in all business activities. Key Risk Indicators and Risk Indicators are used to summarise and aggregate metrics across relevant risk categories, which either directly or indirectly impact upon CLAM’s reputation.
- Good Customer Outcomes – CLAM will act to deliver good customer outcomes in a manner that ensures that customers are placed at the heart of the business.
Key Harms and Risks
CLAM has identified the key harms that could materialise because of the risks to which it is exposed. These risks and associated harms are described in the following section.
- Strategic Risk - CLAM is exposed to strategic risk through its business planning and execution of its strategy. Changes to the business environment and the introduction of new regulations will give rise to the need for further planning. The crystallisation of these risks could result in harm to CLAM and to its customers.
- Credit Risk - CLAM’s credit risk exposure is limited to cash deposits, money market funds and non-receipt of fee income. For cash deposits and money market funds, CLAM prioritises diversification of risk. Exposure to non-payment fee income is managed through robust contractual arrangements, where the level and frequency of fee income is specified and subsequently monitored. CLAM’s exposure to Credit Risk is low.
- Concentration Risk - As CLAM does not operate a trading book, concentration risk is limited to sources of earnings and the concentration of investments held as regulatory capital. The Executive Management Committee monitors and oversees both key sources of income from clients and concentration of invested assets held as capital, the latter being subject to internal Investment Policy restrictions.
- Operational & Conduct Risk - CLAM has put in place a Risk and Control Self-Assessment (RCSA) process to assure itself that all key operational risks to which it is exposed are effectively identified, assessed, and controlled to the appropriate level. CLAM’s Operational Risk Universe includes areas such as fraud, business continuity, legal & regulatory compliance, third party supplier, people, business process & reporting risks. The crystallisation of these risks could result in harm to CLAM and to its customers.
- Market Risk - CLAM does not hold any investments in its own name other than its own funds. CLAM’s exposure to Market Risk is low. The limited impact of this risk crystallising would cause harm only to CLAM.
- Liquidity - CLAM has a Liquidity Operating Policy which sets out how it consistently maintains sufficient liquid resources to meet its obligations from financial liabilities. CLAM’s exposure to Liquidity Risk is low. The limited impact of this risk crystallising would cause harm only to CLAM.
Own Funds
CLAM has completed an assessment of the potential material harms and risks that apply to it and calculated the appropriate Own Funds that it needs to hold to comply with the requirements of the Overall Financial Adequacy Rule.
CLAM’s Own Funds requirement has been calculated based on a reasonable estimate of the own funds it needs to hold to address (1) any potential material harms that the firm has identified and in relation to which it has not taken any measures to reduce the impact of such harms; and (2) any residual potential material harms that remain after the firm has taken measures to reduce the impact of such harms.
As part of its ICARA process, CLAM has assessed its business model and identified all material harms that could result from (1) the ongoing operation of the firm’s business and, (2) the winding-down of the firm’s business.
The methodology and breakdown on how CLAM calculated the individual components required to assess the amount of Own Funds required was as follows:
- Identify and measure risk of harm
- Determine the capital requirement from on-going operations (Assessment A) by assessing the appropriate amount of residual risk from any material harms that could result from the ongoing operation of the firm and where additional owns funds are necessary over and above the K-factor requirement.
- Determine the capital requirement for wind-down (Assessment B) by starting with the fixed overhead requirement (FOR) and determining if the FOR is sufficient and if any additional owns funds are necessary
- Own Funds requirement is the higher of Assessment A and Assessment B
- Undertake Stress and Reverse Stress Testing to determine if any additional capital is required
|
Composition of regulatory own funds |
|
|
|
|
Item |
Amount |
Reference to the audited financial statements |
|
|
|
OWN FUNDS |
31,990 |
|
|
2 |
TIER 1 CAPITAL |
31,990 |
|
|
3 |
COMMON EQUITY TIER 1 CAPITAL |
31,990 |
|
|
4 |
Fully paid-up capital instruments |
2,250 |
Page 16 & 22 |
|
6 |
Retained earnings |
29,740 |
Page 16 |
|
19 |
CET1: Other capital elements, deductions and adjustments |
0 |
|
|
|
|
|
|
|
20 |
ADDITIONAL TIER 1 CAPITAL |
0 |
|
|
25 |
TIER 2 CAPITAL |
0 |
|
|
Own funds: reconciliation of regulatory own funds to balance sheet in the audited financial statements |
||||
|
|
a |
b |
c |
|
|
|
Balance sheet |
Under regulatory scope of consolidation |
Cross reference to OF1 |
|
|
|
As at 31.12.25 |
As at 31.12.25 |
|
|
|
Assets |
||||
|
1 |
Debtors |
1,784 |
|
|
|
2 |
Money Market Funds |
7,804 |
|
|
|
3 |
WS Canlife Sterling Liquidity Fund |
26,210 |
|
|
|
4 |
OEIC Investment |
129 |
|
|
|
5 |
Cash at bank |
59 |
|
|
|
|
Total Assets |
35,986 |
|
|
|
Liabilities |
||||
|
1 |
Creditors - Tax |
-225 |
|
|
|
2 |
Creditors - Interco |
4,000 |
|
|
|
3 |
Creditors |
221 |
|
|
|
|
Total Liabilities |
3,996 |
|
|
|
Shareholders’ Equity |
||||
|
1 |
Called up share capital |
2,250 |
|
4 |
|
2 |
Retained earnings |
29,740 |
|
6 |
|
|
Total Shareholders’ Equity |
31,996 |
|
3 |
|
Own funds: main features of own instruments issued by the firm |
||||
|
Own funds of Canada Life Asset Management is limited to £2.25m of called up share capital plus accumulated earnings (Retained Earnings) from previous years, not paid out as a dividend. |
||||
Own Funds Requirement
|
Own Funds Requirement (£,000) |
|
|
K-Factor Requirement |
|
|
K-AUM (Assets under Management) |
2,662 |
|
K-COH (Client Orders Held) |
310 |
|
Total K-Factors |
2,972 |
|
Additional Harms |
1,514 |
|
Total Assessment A |
4,486 |
|
Fixed Overhead Requirement (FOR) |
4,457 |
|
Wind-down |
3,733 |
|
Total Assessment B |
4,457 |
|
Own Funds Requirement |
4,486 |
Remuneration disclosure year ending 31 Dec 2025 - View PDF