Ashmore Investment Management Limited
Investment Firm Prudential Regime (IFPR) Disclosure
For the year ended 30 June 2025
Contents
Overview 3
Basis and frequency of disclosure 3
Media and location of disclosures 3
Validation and sign-off 3
Group structure 4
Risk management objectives and policies 5
Risk management framework and governance 5
AIML risk appetite statement (RAS) 7
Principal risks and their management 7
Own funds, Concentration risk and Liquidity requirements 9
Governance arrangements 10
Governance framework 10
AIML Board Committees 11
Directorships 12
Diversity and inclusion 12
Own funds 13
Composition of regulatory own funds 13
Reconciliation of own funds to the audited financial statements 14
Main features of own instruments 14
Own funds regulatory requirements 15
Own funds requirement 15
Liquid assets requirement 16
Approach to assessing OFAR 16
OFAR compliance 17
Remuneration policy and practices 18
Remuneration Committee 18
Remuneration policy and principles 18
Components of remuneration and ex-ante risk adjustment 19
Material risk takers and ex-post risk adjustment 20
Guaranteed variable remuneration and termination payments 21
Quantitative disclosure 21
Overview
The purpose of this document is to set out the Investment Firm Prudential Regime ("IFPR") disclosure for Ashmore Investment Management Limited ("AIML" or "the Firm") in accordance with the Financial Conduct Authority ("FCA") Prudential Sourcebook for Investment Firms chapter 8 ("MIFIDPRU 8").
AIML is a wholly owned subsidiary of Ashmore Group plc ("Ashmore", the "Group") and a MIFIDPRU Investment Firm authorised and regulated by the FCA (Firm Reference Number 185402).
The prudential disclosures in this document are solely in respect of AIML for the financial year ended 30 June 2025.
Basis and frequency of disclosure
AIML is required to publish disclosures in accordance with the provisions outlined in MIFIDPRU 8. Under IFPR, AIML is categorised as a non-small non-interconnected ("non-SNI") MIFIDPRU investment firm.
The prudential disclosures for the Firm are published at least annually, and the frequency of disclosure is assessed on an ongoing basis considering any material changes in either the nature or scale of the Firm's or Ashmore's business operations.
The prudential disclosures as at 30 June 2025 (the "reference date") are consistent with the published financial statements for the Firm. The disclosed information is proportionate to AIML's size and organisation, and to the nature, scope, and complexity of its business activities.
AIML meets the conditions under MIFIDPRU 7.1.4R. The Firm's average assets over the preceding four-year period are less than £300 million and the Firm has no trading book business or derivative exposures. Therefore, the disclosure obligations relating to Investment Policy set out in MIFIDPRU 8.7 do not apply.
Media and location of disclosures
These prudential disclosures are published on the Ashmore website:
https://ir.ashmoregroup.com/corporate-governance
Validation and sign-off
This document has been subject to internal verification and approved by the AIML Board ("Board") to ensure compliance with the regulatory requirements contained in MIFIDPRU 8. The prudential disclosures contained in this document are not required to be verified by an external auditor.
Group structure
AIML is a wholly owned subsidiary of Ashmore Group plc, a UK parent company listed on the London Stock Exchange since 2006. Ashmore is a specialist Emerging Markets investment manager and AIML is responsible for managing the majority of Ashmore's assets under management. The Firm therefore plays an important role in the execution of the Group's strategy, which is focused on growing and diversifying Ashmore's business and creating value for its clients and shareholders.
As at 30 June 2025, AIML managed funds totalling US$41.3bn of assets under management ("AuM"), equivalent to 87% of Ashmore's total AuM. The funds are managed across Ashmore's Emerging Markets investment themes, described below.
External debt Local currency Corporate debtInvests in debt instruments issued by sovereigns and quasi-sovereigns and denominated in foreign currencies.
Invests in local currencies and local currency-denominated instruments issued by
sovereigns, quasi-sovereigns and companies.
Invests in debt instruments issued by public and private sector companies.
Blended debt Equities AlternativesAsset allocation across the external debt, local currency and corporate debt investment themes, measured against tailor-made blended indices.
Invests in equity and equity-related instruments including global, regional, country, small cap, frontier and multi-asset opportunities.
Invests in private equity (healthcare, infrastructure, education), infrastructure debt and distressed debt opportunities.
Risk management objectives and policies
AIML recognises that its strategy and business model have inherent risks, with the potential for harm to the firm, its clients and the markets in which it operates. Therefore, the Firm identifies, evaluates and manages principal and emerging risks through an established and effective internal control framework supported by an embedded risk management culture.
Potential for harm
The material potential harms associated with AIML's business are as follows:
Harm to clients: this could result from operational incidents or errors resulting in disruption of investment management activities for a fund or investors in a fund.
Harm to firm: the Firm may be required to compensate clients due to operational incidents or errors, suffer reputational damage and loss of clients and revenue.
Harm to market: a material detriment or disruption to the public markets in which AIML operates could arise through failure to meet expected market standards, obligations to counterparties or through a material regulatory breach or evidence of market abuse which could undermine the reputation of the asset management industry.
Risk management framework and governance
Ashmore's strategy, business model and related processes and controls include the investment activity and operations conducted by AIML. As such, Ashmore's systems of internal controls and risk management encompass AIML related activities. Accordingly, the management of risk within AIML forms part of the overall Ashmore risk management framework, which sets out to identify, monitor, report and manage risk throughout the Group. The framework is designed to embed an awareness of risk into all strategic and operational business decisions.
Ashmore's risk management structure is shown below.
Ashmore Group plc Board ("Ashmore Board")
The Ashmore Board is ultimately responsible for risk management including setting and monitoring the Group's risk appetite, which determines the types and levels of risks that the Group is prepared to take in pursuit of its strategic objectives. In practice, the Ashmore Board delegated authority to carry day-to-day functions to Executive Directors
Executive Directors
The Executive Directors have established a number of specialised committees, as shown in the corporate governance framework. One such committee is the RCC, which maintains a sound risk management and internal control environment and assesses the impact of the Group's activities on it regulatory and operational exposures.
Group Risk and Compliance Committee
RCC Chairman
Head of Risk Management and Control
Chief Executive Office Chief Finance Director Group Head of Compliance Resources
Group General Counsel
Group Head of IT
Head of Fund Operations
Head of Internal Audit Group Head of Finance
Head of Investment Operations Group Head of Human
Group Head of Distribution
Members