Disclaimers and Disclosures
GDPR – Statement of Compliance for Job Applicants
Epoch Capital takes your privacy seriously and we will only use your personal information for the purposes described herein. Your personal information consists of any information that relates to you, whether provided by you or your recruitment agent, a third party or generated by us during the recruitment process.
We will record and process your personal information throughout the recruitment process. We must retain your data for 12 months from the date of receipt in order to fulfil our legal obligations and to protect our legal interests.
Typically, the data we hold on any job applicant consists of:
- CV
- References
- Interview Notes
- Results of online tests
- Results of background checks
- Hiring decision
We may store some of your data outside of the EU. We ensure compliance with the EU General Data Protection Regulation (“GDPR”) in these cases.
Epoch may send your data to companies outside the EU. We verify that all of these companies including our affiliate in Australia agree to conditions that allow us to preserve your rights to privacy.
By applying for a role with Epoch, you are consenting to us recording and processing your information as per the statement above. We will only be able to continue with the recruitment process if you confirm your agreement.
You may request access, rectification and erasure of your data. You may request partial restrictions or make a complaint about any use of your data. Where relevant, you have a right to data portability. We will respond appropriately and fully to all requests.
We would like to keep your data for a period of time and then it will expire – please let us know if you would prefer us not to do this.
Pillar 3 Disclosure
Background
The Pillar 3 disclosure for Epoch Capital Limited (the “Firm”) has been subject to internal review procedures. The information has not been audited by the firm’s external auditors.
Policy
Pursuant to BIPRU 11, the firm has omitted any required disclosures where it believes the information is immaterial. Information is deemed material if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions.
All figures contained in this disclosure are based on the firm’s audited annual reports for the year ending 30th June 2021, except where stated otherwise.
Frequency
Pillar 3 disclosures are published annually as soon as practical, following the publication of the firm’s annual reports and approval of the ICAAP.
Scope and Application
These disclosures are made in respect of Epoch Capital Limited, which is authorised and regulated by the Financial Conduct Authority and which is classified as a BIPRU limited licence firm.
Policies for hedging and mitigating risk
The Firm’s risk management framework is based on a review of the FCA requirement to manage different categories of risk, including liquidity risk, operational risk, credit risk, reputational risk, business risk, market risk, interest rate risk and concentration risk.
Liquidity risk
The Firm generates cash from its operations and holds sufficient cash reserves to meet the firm’s continued operating needs. This is supported by a forecasting process which has full involvement of the directors.
Business risk
The firm assesses its risk by considering a general downturn in the market or other scenario that affects the financial position of the Epoch group of companies. To mitigate business risk we analyse various scenarios to consider the impact of a downturn in the group’s financial position.
Operational risk
The firm considers operational risk at the group level with participation from UK senior managers in the group’s Risk Committee. Risk management processes are regularly reviewed and are implemented throughout the firm.
Other risks
The firm’s business model means that many specific risks identified by the FCA do not apply.
Capital adequacy
The firm’s Pillar 1 capital requirement is the Fixed Overhead Requirement under GENPRU. This was calculated based on forecast expenses for the year ended 30th June 2021. The Pillar 1 requirement was calculated on this basis at £184,983.
On 30th June 2021, the Firm held a total of £924,450 tier one capital, giving it a surplus of £739,467.
Remuneration Code
Basic salaries are reviewed in line with individual performance. Bonuses are discretionary and are linked to the firm’s overall financial position.
Epoch Capital can be contacted at:
dataprotection@epochcapital.co.uk
Whistleblowing
Epoch is committed to maintaining the highest standards of honesty, openness and accountability and recognises that its associates, suppliers, employees and ex-employees have an important role to play in achieving this goal.
Epoch does not believe that it is in anyone’s interest to remain silent in the face of wrongdoing. If you are aware of any wrongdoing relating to Epoch, then we encourage you to make a disclosure. If you make a qualifying disclosure, you are entitled to legal protections.
How to make a disclosure
You can make a disclosure in writing via email or post, or you can contact us by phone.
Our contact details are:
The Whistleblower Protection Officer
Epoch Capital
Level 5, 88 George Street, The Rocks NSW 2000
Email: whistle@epochcapital.com.au
Tel: + 61 2 8070 3800
You can make a disclosure anonymously if you wish. We recommend that you maintain ongoing two-way communication with Epoch so that we can ask follow-up questions or provide feedback. We suggest the use of a throw-away email address or a pseudonym for this purpose.
If you do disclose your identity, we will not disclose it to anyone else, even internally without your express permission.
You may wish to consult an independent legal adviser to seek additional information before making a disclosure. Disclosures made to a legal practitioner for the purposes of obtaining legal advice or legal representation are protected even if you the legal practitioner concludes that the disclosure does not relate to a disclosable matter.
You can make a disclosure to a regulator. Guidance on how to do so can be found here.
Protections
You will be protected if you make a disclosure to a regulator, including ASIC, APRA, AUSTRAC or ATO.
Your identity will be protected by Epoch. You will be protected from detrimental acts and omissions. You will be protected from any of the following in relation to your disclosure:
- civil liability (e.g. any legal action against you for breach of an employment contract, duty of confidentiality or another contractual obligation);
- criminal liability (e.g. attempted prosecution for unlawfully releasing information, or other use of the disclosure against you in a prosecution (other than for making a false disclosure)); and
- administrative liability (e.g. disciplinary action for making the disclosure).
These protections do not grant immunity for any misconduct that you have engaged in that is revealed in your disclosure.
Complaints
If you wish to complain about the way your disclosure has been handled, please email
The Compliance Manager
Epoch Capital
Level 5, 88 George Street, The Rocks NSW 2000
