Pillar 3

Pillar 3 of the Capital Requirement Directive (CRD) requires firms to make certain disclosures in relation to their risk management activities and allocation of capital.

Risk management in Harvest is a continuous and developing process which runs through the organisation and all its activities. It aims to methodically address all the risks surrounding the organisation’s activities, past, present and particularly in the future. The Board of Directors of Harvest recognises its obligations and responsibility for protecting the organisation, its clients, employees, assets and profits against the adverse consequences of risk.

The Board of Directors is responsible for determining the firm’s strategy, approving the firm’s business plans, reviewing operational performance, determining authority levels and the firm’s policies, ensuring adequate funding, and approving developments within the firm. It assumes overall responsibility for monitoring, identification and evaluation of risk management performance, and for providing control measures for the firm’s management to implement.

The board considers the firm’s risk to fall into the following broad categories: Commercial, Market, Credit, Operational, Concentration, Economic, Reputation, Compliance and Legal. The management of the firm applies various measures to mitigate against these risks, as it sees fit. The detail of these measures is regarded as proprietary to the firm.

The Board has delegated responsibility for the implementation and review of the risk policy to the Risk Committee. The Risk Committee assess the firm’s exposures to risk and makes recommendations to the Board at least annually or when there is a material change in the firm’s activities. The Risk Committee monitors the impact on the firm of the identified risk criteria and recommends adjustments to the firms risk appetite as appropriate.

The risk management policy is reviewed annually as part of the Internal Capital Adequacy Assessment Process (ICAAP) as determined by the CRD. The board of directors of Harvest confirms that the ICAAP for 2012 has been completed. The firm at all times maintains capital in excess of regulatory minimum requirements. The firm calculates minimum capital for operational risk in accordance with the basic indicator approach.

The firm declines to provide a detailed disclosure of Own Funds as it deems this information to be proprietary in nature.

Board of Directors
Harvest Financial Services Ltd
June 2012