PILLAR III DISCLOSURES

According to Directives DI144-2014-15 and DI144-2014-14 of the Cyprus Securities &Exchange Commission for the prudential supervision of investment firms and Part Eight ofRegulation (EU) No 575/2013 of the European Parliament and of the Council on prudential
requirements for credit institutions and investment firms

YEAR ENDED 31 DECEMBER 2018

April 20192018 Pillar III Disclosures Report

CONTENTS
1. Introduction .................................................................................................................................4
1.1 CIF Information .....................................................................................................................4
1.2. Scope of application .............................................................................................................5
1.3. Pillar III Regulatory Framework ..........................................................................................5
1.3.1. Overview ...................................................................................................................... 5
1.3.2. Disclosure Policy: Basis and Frequency of Disclosure / Location and verification .... 6
1.4. Risk management objectives and policies ............................................................................7
1.4.1. Risk Management Framework ..................................................................................... 8
1.4.2. Risk Appetite Statement ............................................................................................... 9
1.4.3. Risk Culture ............................................................................................................... 10
1.4.4. Capital Requirements ................................................................................................. 10
1.5. Declaration of the Management Body ................................................................................12
2. Corporate Governance ...............................................................................................................132.1. Organisational Structure .....................................................................................................132.2. The Board of Directors .......................................................................................................132.3. Number of Directorships held by members of the Board ...................................................142.4. Policy on Recruitment ........................................................................................................142.5. Policy on Diversity .............................................................................................................15
2.6. Governance Committees.....................................................................................................16
2.7. Other Governance Functions ..............................................................................................172.8. Information flow on risk to the management body ............................................................19
3. Own Funds .................................................................................................................................20
3.1. Tier 1 & Tier 2 Regulatory Capital ....................................................................................20
3.2. Main features of Common Equity Tier 1, Additional Tier 1 and Tier 2 instruments .........223.3. Balance Sheet Reconciliation .............................................................................................23
4. Compliance with Regulatory Capital and the overall Pillar II Rule ..........................................24
4.1. Internal Capital ...................................................................................................................24
4.2. Approach to assessing adequacy of Internal Capital ..........................................................24
5. Pillar I Capital Requirements ....................................................................................................26
5.1. Credit Risk ..........................................................................................................................26
5.1.1. Credit risk adjustments ............................................................................................... 26
5.1.2. Credit Risk – Risk Weighted Assets .......................................................................... 27
5.1.3. Credit Risk – Analysis of Average exposures and total amount of exposures after
accounting offsets................................................................................................................. 27
5.1.4. Credit Risk – Risk Weighted Assets by Geographical distribution of the exposure
classes ................................................................................................................................... 28
5.1.5. Credit Risk – Distribution of exposures by industry .................................................. 28
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
5.1.6 Residual maturity broken down by exposure classes .................................................. 29
5.2. Use of ECAIs ......................................................................................................................29
5.3. Securitisations .....................................................................................................................30
5.4. Counterparty Credit Risk ....................................................................................................30
5.5. Market Risk ........................................................................................................................31
5.5.1. Equity Risk ................................................................................................................. 32
5.5.2. Foreign Exchange Risk .............................................................................................. 32
5.5.3. Commodities Risk ...................................................................................................... 33
5.5.4. Interest Rate Risk ....................................................................................................... 33
5.6. Operational Risk .................................................................................................................33
6. Leverage Ratio ...........................................................................................................................36
7. Other Risks ................................................................................................................................37
7.1. Concentration Risk .............................................................................................................37
7.2. Reputation Risk ..................................................................................................................38
7.3. Strategic Risk ......................................................................................................................38
7.4. Business Risk ......................................................................................................................38
7.5. Capital Risk Management ..................................................................................................38
7.6. Regulatory Risk ..................................................................................................................39
7.7. Legal and Compliance Risk ................................................................................................39
7.8. IT Risk ................................................................................................................................40
7.9. Risk Reporting ....................................................................................................................40
7.10. Liquidity Risk ...................................................................................................................40
7.11. Conduct Risk ....................................................................................................................40
8. Remuneration policy..................................................................................................................428.1. Remuneration System .........................................................................................................428.2. Link between the pay and performance ..............................................................................43
8.3. Remuneration of Senior Management Personnel and Directors ........................................44

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

1. INTRODUCTION
1.1 CIF Information
GBE Brokers Ltd (hereinafter, the “Company”) was incorporated in the Republic of Cyprus on 5
August 2013 as a limited liability company with registration number HE 324205 and it is a
Cyprus Investment Firm (hereinafter “CIF”). The Company was licensed by the Cyprus
Securities and Exchange Commission (hereinafter the “CySEC”) with number CIF 240/14 toprovide financial services, on 27 June 2014 and the licence was activated on 23 June 2015.
Table 1 below illustrates the current licence information of the Company:

Financial Instruments

Table 1: Company Licence Information (based on the First Appendix of the Law 87(I)/2017
as amended)

1
2
3
4
5
6
7
8
9
10
11

Investment Services and Activities
1
2
3
4
5
6
7
8
  
  
  
  
  
  
  
  
  
  
-

1










-

Ancillary Services
2
3
4
5
6











-

7
-

The Company is authorised to provide the following Investment Services, in accordance withPart Ι of the First Appendix of the Law 87(I)/2017, as amended:
1. Reception and transmission of orders in relation to one or more financial instruments
2. Execution of orders on behalf of clients
3. Dealing on own account
The Company is authorised to provide the following Ancillary Services, in accordance with Part
ΙI of the First Appendix of the Law 87(I)/2017, as amended:
1. Safekeeping and administration of financial instruments for the account of clients,
including custodianship and related services such as cash/collateral management
2. Granting credits or loans to one or more financial instruments, where the firm granting
the credit or loan is involved in the transaction
3. Foreign exchange services where these are connected to the provision of investment
services
The Company is authorised to provide the aforementioned investment and ancillary services, asapplicable for each service, for the following Financial Instruments, in accordance with Part IIIof the First Appendix of the Law 87(I)/2017, as amended:
1. Transferable Securities
2. Money Market Instruments
3. Units in Collective Investment Undertakings
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
4.

Options, futures, swaps, forward rate agreements and any other derivative contracts relating
to securities, currencies, interest rates or yields, or other derivatives instruments, financial
indices or financial measures which may be settled physically or in cash.
5. Options, futures, swaps, forward rate agreements and any other derivative contracts relating
to commodities that must be settled in cash or may be settled in cash at the option of one ofthe parties (otherwise than by reason of a default or other termination event).
6. Options, futures, swaps, and any other derivative contract relating to commodities that canbe physically settled provided that they are traded on a regulated market or/and an MTF
7. Options, futures, swaps, forwards and any other derivative contracts relating tocommodities, that can be physically settled not otherwise mentioned in point 6 of Part III
and not being for commercial purposes, which have the characteristics of other derivative
financial instruments, having regard to whether, inter alia, they are cleared and settled
through recognised clearing houses or are subject to regular margin calls
8. Derivative instruments for the transfer of credit risk
9. Financial contracts for differences
10. Options, futures, swaps, forward rate agreements and any other derivative contracts relating
to climatic variables, freight rates, emission allowances or inflation rates or other official
economic statistics that must be settled in cash or may be settled in cash at the option of oneof the parties (otherwise than by reason of a default or other termination event), as well as
any other derivative contract relating to assets, rights, obligations, indices and measures nototherwise mentioned in this Part, which have the characteristics of other derivative financial
instruments, having regard to whether, inter alia, they are traded on a regulated market or an
MTF, are cleared and settled through recognised clearing houses or are subject to regularmargin calls.
Moreover, pursuant to the Regulation (EU) 575/2013 (the “Regulation” or “CRR”) andfollowing the Licence extension to include the Dealing on Own Account investment service, theCompany is categorised as “Full Scope” CIF with minimum/initial capital requirement of€730,000.
1.2. Scope of application
The Company is publishing the disclosures on an individual (solo) basis. The Pillar III
disclosures is prepared in accordance with the Pillar 3 disclosure requirements as laid out in Part
Eight of the Regulation No. 575/2013 (CRR) and Capital Requirement Directive IV
The report is based on the Annual Reports and Financial Statements which are prepared inaccordance with International Financial Reporting Standards (IFRS) and the provisions of the
Cyprus Company Law, Cap. 113.
1.3. Pillar III Regulatory Framework
1.3.1. Overview
This Pillar III report (the ‘Report’) has been prepared in accordance with Section 4 (Paragraph.
32) of the CySEC Directive DI144-2014-14 of 2014 (the “Directive”) for the prudential
supervision of investment firms which implements the Regulation 575/2013 (the “Regulation” or“CRR”) and the European Directive 2013/36/EU (the “European Directive” or “CRD IV”), as
well as the relevant provisions of new Law 87(I)/2017 (hereinafter, the “Law”), as amended. It
is noted that the Law 144(I)/2007 has been replaced by Law 87(I)/2017, for the purpose of
harmonization with European Directive 2 2014/65/EU (“MIFID II”) which applies to Cypriot
investment firms (CIFs), market operators, data reporting service providers (DRSP), and third-

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Reportcountry firms providing investment services or activities through the establishment of a branch in
the Republic.
The CRR establishes the prudential requirements for capital, liquidity and leverage that entities
need to abide by. Furthermore, CRR introduces significant changes in the prudential regulatory
regime applicable to institutions including amended minimum capital ratios, changes to thedefinition of capital and the calculation or risk weighted assets and the introduction of new
measures relating to leverage, liquidity and funding. Additionally, CRR permits a transition
period for certain of the enhanced capital requirements and certain other measures, such as theleverage ratio, which are not expected to be fully implemented until 2018. CRR is immediately
binding on all EU member states. CRD IV governs access to internal governance arrangements
including remuneration, Board of Directors (the “Board”) composition and transparency.
The Regulatory framework consists of a three “Pillar” approach:Pillar I - Establishes minimum capital requirements, defines eligible capital instruments,
and prescribes rules for calculating RWA for credit risk, market risk and operational risk.
Pillar II – Requires firms and supervisors to take a view on whether a firm should holdadditional capital against: risks considered under Pillar I that are not fully captured by the
Pillar I process (e.g. credit concentration risk), risks not taken into account by the Pillar I
process (e.g. interest rate risk in the banking book, business and strategic risk) and factors
external to the firm (e.g. business cycle effects). Pillar II connects the regulatory capitalrequirements to the Company’s Internal Capital Adequacy Assessment Process(“ICAAP”) and to the reliability of its internal control structures. The function of Pillar II
is to provide communication between supervisors and institutions on a continuous basis
and to evaluate how well the institutions are assessing their capital needs relative to theirrisks. If a deficiency arises, prompt and decisive action is taken to restore the appropriate
relationship of capital to risk.
Pillar III - Market Discipline requires the disclosure of information regarding the risk
management policies of the Company, as well as the results of the calculations ofminimum capital requirements, together with concise information as to the compositionof original own funds.

1.3.2. Disclosure Policy: Basis and Frequency of Disclosure / Location and verification
The Company has a formal policy, approved by the Board, which details its approach incomplying fully with the Pillar 3 disclosure requirements as laid out in Part Eight of the CRR.
According to the Directive, the risk management disclosures should be included in either thefinancial statements of the CIFs if these are published, or on their websites. The Pillar III
disclosure requirements are contained in Articles 431 to 455 of the Regulation. In addition, these
disclosures must be verified by the external auditors of the CIF. The CIF will be responsible tosubmit its external auditors’ verification report to CySEC. The Company has included its risk
management disclosures as per the Directive on its website as it does not publish its financial
statements. Verification of these disclosures has been made by the external auditors and sent to
CySEC.
The Regulation provides that institutions may omit one or more disclosures, if such disclosures
are not regarded as material, except for the following disclosures: Regarding the policy on diversity with regard to selection of members of the management
body, its objectives and any relevant targets set out in that policy, and the extent to whichthese objectives and targets have been achieved (Article 435(2)(c) of CRR).
 Own funds (Article 437 of CRR).
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures ReportRemuneration policy (Article 450 of CRR).

Materiality of Disclosures
Materiality is based on the criterion that the omission or misstatement of information would be
likely to change or influence the decision of a reader relying on that information for the purposeof making economic decisions. Where the Company has considered a disclosure to beimmaterial, this was not included in the document.
Disclosures and Confidential Information
The Regulation also provides that institutions may omit one or more disclosures, if suchdisclosures are regarded as confidential or proprietary. The CRR defines proprietary as if sharingthat information with the public would undermine its competitive position. It may include
information on products or systems which, if shared with competitors, would render an
institution’s investments therein less valuable.
Information is regarded as confidential if there are obligations to customers or other counterparty
relationships binding an institution to confidentiality. Under the light of the above, the Company
avoided to disclose such confidential information in this report.
Frequency
The Company’s policy is to publish the disclosures required on an annual basis. The frequency
of disclosure will be reviewed should there be a material change in approach used for the
calculation of capital, business structure or regulatory requirements.
Medium and location of publication
Institutions may determine the appropriate medium, location and means of verification to comply
effectively with the disclosure requirements. In this respect, the Company’s Pillar III disclosures
are published on the Company’s websites:

www.gbebrokers.com
www.gbeprime.com
www.discountfx.com

Verification
The Company’s Pillar III disclosures are subject to internal review and validation prior to being
submitted to the Board for approval. The Company’s Pillar III disclosures have been reviewed
and approved by the Board. In addition, the Remuneration disclosures have been reviewed by the
Risk Management Committee.
1.4. Risk management objectives and policies
To ensure effective risk management, the Company has adopted the Three Lines of Defence
model, with clearly defined roles and responsibilities.
First Line of Defence: Managers are responsible for establishing an effective control framework
within their area of operation and identifying and controlling all risks so that they are operating
within the organisational risk appetite and are fully compliant with Company’s policies andwhere appropriate defined thresholds. First Line of Defence acts as an early warning mechanism
for identifying (or remedying) risks or failures.
Second Line of Defence – The Risk Management Function is responsible for proposing to theBoard appropriate objectives and measures to define the Company’s risk appetite and for
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Reportdevising the suite of policies necessary to control the business including the overarchingframework and for independently monitoring the risk profile, providing additional assurance
where required. The Risk Management Function will leverage their expertise by providing
frameworks, tools and techniques to assist management in meeting their responsibilities, as wellas acting as a central coordinator to identify enterprise wide risks and make recommendations toaddress them. Integral to the mission of Second Line of Defence is identifying risk areas,
detecting situations/activities, in need of monitoring and developing policies to formalise risk
assessment, mitigation and monitoring.
Third Line of Defence - Comprises by the Internal Audit Function which is responsible forproviding assurance to the Board on the adequacy of design and operational effectiveness of thesystems of internal controls. Internal Audit undertakes on-site inspections/visits to ensure that the
responsibilities of each Function are discharged properly (i.e. soundly, honestly andprofessionally) as well as reviews the Company’s relevant policies and procedures. Internal
Audit works closely with both the First and Second Lines of Defence to ensure that its findings
and recommendations are taken into consideration and followed, as applicable.
1.4.1. Risk Management Framework
Managing risk effectively in a Company operating in a continuously changing risk environment,
requires a strong risk management culture. As a result, the Company has established an effective
risk oversight structure and the necessary internal organisational controls to ensure that theCompany undertakes the following:The adequate risk identification and management
The establishment of the necessary policies and procedures
The setting and monitoring of the relevant limits andCompliance with the applicable legislation

The Board meets on a regular basis, and receives updates on risk and regulatory capital mattersfrom management. The Board reviews regularly (at least annually) written reports concerningcompliance, risk management and internal audit policies, procedures and work as well as theCompany’s risk management policies and procedures as implemented by Management.
As part of its business activities, the Company faces a variety of risks, the most significant of
which are described further below. The Company holds regulatory capital against three allencompassing main types of risk: credit risk, market risk and operational risk.
Risk Policy Statement (PS-01-2019):
The Policy Statement (PS-01-2019) provides public guidance on CySEC’s approach on the risk
management arrangements of those Cypriot Investment Firms (“CIFs”) providing investment
services and/or performing investment activities in financial contract for differences (“CFDs”).
The European Securities and Markets Authority (ESMA) has adopted new intervention measureson the provision of CFDs including the Negative Balance Protection (NBP) Requirement forprotecting retail clients exposed to the consequences of trading in CFD. The purpose of thisarrangement is to ensure that the maximum loss for the clients from trading CFDs never exceeds
the client’s available funds in the specific amount when the “margin close-out protection” cannot
be effectively applied.
Following the implementation of the ESMA decision and following a market-wide review of
CFD CIFS, the Cyprus Securities and Exchange Commission (CySEC) has imposed Risk
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures ReportManagement Transferring Arrangements in order to enhance the market structure for CFD CIFs
and monitor the compliance with the new requirements.
Further to the above, all CFD CIFs operating under a €730k Licence are required to maintain an
additional of CET 1 Capital of either a) €2.000.000, or b) 2% of their total risk exposure,whichever is higher unless they collaborate and have in place Liquidity and Contractual
Arrangements with entities (Credit Institutions or Investment Firms) domiciled in a third country
listed in Annex I of the Commission Implementing Decisions (EU) 2016/230 and/or EEA
regulated entities and/or entities domiciled in a member of G20.
The Company is not required to restructure its LP Contractual Arrangements since it iscategorised as a Full Scope CFD CIF. Moreover, the Company maintains contractual agreementswith solely EU entities and as such is not required to hold additional capital as per the provisionsof the Policy Statement.
Recovery and Resolution Plan
According to the Paragraph 4 of the Directive DI144-14-2014, CIFs must put in place, recovery
plans for the restoration of their financial situation following a significant deterioration, andresolution plans. In additions, CIFs shall cooperate closely with resolution authorities and must
provide them with all information necessary for the preparation and drafting of viable resolutionplans.
1.4.2. Risk Appetite Statement
Risk appetite is the level and type of risk a firm is able and willing to assume in its exposuresand business activities, given its business objectives and obligations to stakeholders. Risk
appetite is generally expressed through both quantitative and qualitative means and should
consider extreme conditions, events and outcomes. In addition, risk appetite should reflectpotential impact on earnings, capital and funding/liquidity.
The company has a low risk appetite in respect to investing and to managing business andoperational activities.
According to Financial Stability Board (FSB) an appropriate risk appetite framework (RAF)should enable risk capacity, risk appetite, risk limits, and risk profile to be considered forbusiness lines and legal entities as relevant, and within the group context. The Risk appetite
framework is defined as the overall approach, including policies, processes, controls, andsystems through which risk appetite is established, communicated, and monitored. It includes arisk appetite statement, risk limits, and an outline of the roles and responsibilities of thoseoverseeing the implementation and monitoring of the RAF.
The RAF should consider material risks to the financial institution, as well as to the institution’s
reputation vis-à-vis policyholders, depositors, investors and customers. The RAF aligns with theinstitution's strategy.
The company is assessing its risk appetite in respect to investing and to managing business andoperational activities while the Company’s Risk Appetite Statement is prepared by the Risk
Manager and approved by the Board of Directors.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
Table 2 - Risk Appetite areas
Risk Area
Risk Types
Financial Credit Risk
 Market Risk
 Liquidity Risk
Reputational
 Conduct Risk
 Customer Risk
 Regulatory Risk
 External reputational Risk
Operational & People
The risk associated with the failure of key processes or systems
and the risks of not having the right quality and quantity ofpeople to operate those processes
The Risk Appetite framework has been designed to create links to the strategic long term plan,
capital planning and the Company’s risk management framework.
The Board approves the Company’s corporate strategy, business plans, budget, long term planand ICAAP. The Company employs hedging and mitigation techniques defined within the
Company’s policies, to ensure risks are managed within Risk Appetite.
1.4.3. Risk Culture
Risk culture is a critical element in the Company’s risk management framework and procedures.
Management considers risk awareness and risk culture within the Company as an important partof the effective risk management process. Ethical behaviour is a key component of the strongrisk culture and its importance is also continuously emphasised by the management.
The Company is committed to embedding a strong risk culture throughout the business where
everyone understands the risks they personally manage and are empowered and qualified to takeaccountability for them. The Company embraces a culture where each of the business areas isencouraged to take risk–based decisions, while knowing when to escalate or seek advice.
1.4.4. Capital Requirements
Regulatory Capital Buffers
CRD IV is transposed into national laws, which allows national regulators to impose additional
capital buffer requirements. Based on the provisions of the Macroprudential oversight ofInstitutions Law of 2015 which came into force on 1 January 2016, the Central Bank of Cyprus(the “CBC”) is the designated Authority responsible for setting the macroprudential buffers thatderive from the CRD IV.
Further to the above, the Macroprudential Authority has decided to activate the capitalconservation buffer (the “CCB”) having exercised its power. The CCB will be phased-in
gradually, starting from 1 July 2016 at 0.625% and increasing by 0.625% every year thereafter,
until being fully implemented (2.5%) on 1 January 2019. The Company was obliged to maintaina 1.875% CCB in addition to the CET1 capital maintained for the year 2018 to meet the own
funds requirement imposed by Article 92 of the CRR while for the year 2019 the Company isrequired to maintain a 2.5% CCB in addition to the CET1 capital buffer.
According to paragraph 52(2) of the Directive, the Macroprudential Authority may exempt small
and medium sized CIFs from holding an institution specific CCyB, in addition to their CET 1
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
Capital. Based on the assessment made, using the latest financial data available, theMacroprudential Authority has decided that the Company meets the definition of a small andmedium CIF and thus is exempted from the requirement to maintain an institution specificCCyB.
In accordance with the provisions of this law, the CBC sets, on a quarterly basis, theCountercyclical Capital Buffer (the “CCyB”) level in accordance with the methodology
described in this law. The CCyB is effective as from 1 January 2016 and is determined by the
CBC ahead of the beginning of each quarter. The CBC has set the level of the CCyB rate for
Cyprus at 0% for 2018.
In addition, full scope CIFs are required to maintain an institution specific CCyB equivalent totheir total risk exposure amount multiplied by the weighted average of the countercyclical buffer
rates. At present, based on ESRB and BIS website, the countries that have adopted a positive
countercyclical capital buffer rate are as shown in the map below:

The Macroprudential Oversight of Institutions Law, 2015, also requires the maintenance ofadditional capital buffer by the systemically important credit institutions and investment firms
either at the national level, or at the EU level, referred to as Other Systemically Important
Institutions (“O-SII”).
The O-SII capital buffer reflects the cost for an institution of being systemically important andreduces the moral hazard from the support of the institution from the state and the taxpayers andcompensates for the higher risk it represents for the national financial system and the potential
consequences of its failure. The Company is not obliged to maintain a O-SII capital buffer as it is
not a O-SII institution.
The Cyprus Macroprudential Authority (Central Bank of Cyprus) decided the adoption of amacroprudential measure adopted by Estonia. This measure constitutes a 1% systemic risk buffer
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Reportrate, applied in accordance with Article 134 of Directive 2013/36/EU, on all exposures located in
Estonia of CIFs incorporated in the Republic of Cyprus and offering the investment service of
dealing on own account and/or underwriting of financial instruments and/or placing of financial
instruments on a firm commitment basis. Consequently, CIFs with exposures located in Estonia
must comply with the decision of the Central Bank of Cyprus when calculating their Capital
Requirements pursuant CySEC’s Circular C222. As at 31 December 2018 there were no
exposures in Estonia.
The below table illustrates the transitional increase of the applicable buffers up to the year 2019:

Regulatory Capital Buffers up to 201912.00%
10.00%
8.00%
6.00%
4.00%
2.00%
0.00%
Conservation Buffer
Tier II
Additional Tier I
Common Equity Tier I
Total Capital Ratio

2013
0%
3.50%
1.00%
3.50%
8.00%

2014
0%
2.50%
1.50%
4.00%
8.00%

2015
0%
2.00%
1.50%
4.50%
8.00%

2016
2017
2018
2019
0.625% 1.250% 1.875% 2.500%
2.00% 2.00% 2.00% 2.00%
1.50% 1.50% 1.50% 1.50%
4.50% 4.50% 4.50% 4.50%
8.63% 9.25% 9.88% 10.50%

According to the Policy Statement, Full Scope CIFs that maintain LP Contractual Arrangementswith entities located in non-equivalent third countries are required to maintain an additional
capital buffer. In this respect, since the Company’s Liquidity provider is located in an EU
Country, the Company is not required to hold additional capital as per the provisions of the
Policy Statement. Moreover, the Company has considered and addressed the risks emanatingfrom the NBP in the context of their ICAAP.
1.5. Declaration of the Management Body
The Board is responsible for reviewing the effectiveness of the Company’s risk management
arrangements and systems of financial and internal control. These are designed to manage rather
than eliminate the risks of not achieving business objectives, and – as such – offer reasonable but
not absolute assurance against fraud, material misstatement and loss. The Board considers that it
has in place adequate systems and controls with regard to the Company’s profile and strategy
and an appropriate array of assurance mechanisms, properly resourced and skilled, to avoid or
minimise loss.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

2. CORPORATE GOVERNANCE
The Company’s systems of risk management and internal control include risk assessment,
management or mitigation of risks, including the use of control processes, information andcommunication systems and processes for monitoring and reviewing their continuing
effectiveness.
The risk management and internal control systems are embedded in the operations of theCompany and are capable of responding quickly to evolving business risks, whether they arise
from factors within the Company or from changes in the business environment.
2.1. Organisational Structure
The Company’s latest organizational structure is as follow:

Committee
5. Internal Audit

6. Compliance
Officer
7. Anti-Money
Laundering
Compliance Officer

1. Board of
Directors

2. RiskManagement
Committee

3. Managing
Director

10. Investment
Committee

4. General Manager(4-Eyes)

8. Risk Manager
9. GDPR Officer

11.
Brokerage
Dept.

15.
12. Dealing on 13. Admin / 14. Finance &Own Account Back Office Accounting Safekeeping
Dept.
Dept.
Dept.
Dept.

16. Credit
and Loans
Dept.

17. IT
Services
Dept.

19.
Germany
Branch18.
MarketingDept.

2.2. The Board of Directors
The Board has the overall responsibility for the establishment and oversight of the Company’s
Risk Management Framework. The Board satisfies itself that financial controls and systems ofrisk management are robust. The Board comprises of two executive directors and two
independent non-executive directors.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
The Company has in place the Internal Operations Manual which lays down the activities,
processes, duties and responsibilities of the Board, Committees, Senior Management and staff
constituting the Company.
The Company implements and maintains adequate risk management policies and procedures
which identify the risks relating to the Company’s activities, processes and systems, and whereappropriate, set the level of risk tolerated by the Company. The Company adopts effective
arrangements, processes and systems, in light of that level of risk tolerance, where applicable.
2.3. Number of Directorships held by members of the Board
All members of the Board commit sufficient time to perform their functions in the Company.
The number of directorships which may be held by a member of the Board at the same time shalltake into account individual circumstances and the nature, scale and complexity of theCompany’s activities. Unless representing the Republic, members of the Board of a CIF that issignificant in terms of its size, internal organisation and the nature, the scope and the complexityof its activities shall not hold more than one of the following combinations of directorships at thesame time:

one executive directorship with two non-executive directorships;
four non-executive directorships.

For the purposes of the above, Executive or non-executive directorships held within the samegroup shall count as a single directorship. Furthermore, directorships in organisations which do
not pursue predominantly commercial objectives such as non-profit or charitable organisations
shall not count for the purposes of the above guidelines.
The table below discloses the number of directorships held by members of the management
body.
Table 3 - Number of Directorships of the members of the Board of Directors
Number of
Number of
Director
Function
Executive
Non-Executive
Directorships Directorships
Mr. Rifat Sayim
Executive Director
10
Mr. Niklas Neubauer
Executive Director
10
Ms. Olga Kvasova
Independent, Non-Executive
0
2
Director
Mr. Andreas
Independent, Non-Executive
0
4
Psindros*
Director*Mr. Andreas Psindros was appointed on 17 August 2018 in replacement of Mr. Christos
Avgoustinos.
2.4. Policy on Recruitment
The Company follows a predetermined procedure for the appointment of the members of the
Senior Management and the Board of Directors. Recruitment into the Board combines anassessment of both technical capability and competency skills referenced against the Company’s
leadership framework.
Members of the Board shall possess sufficient knowledge, skills and experience to perform theirduties. The overall composition of the Board shall reflect an adequately broad range ofexperiences to be able to understand the CIF’s activities, including the principal risks faced by
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
the Company as well as sufficient knowledge, of the legal framework governing the operations a
CIF.
Specifically, when considering the appointment of the members of the Board and Senior
Management, special attention shall be given to the following: Essential qualifications, business administration skills, education and experience so as toensure the sound and prudent management of the Company, and diversity in order to
conduct effectively and efficiently all their duties and responsibilities;
 Very strong interpersonal skills as well as managerial skills including time management andleadership skills;
 Profound and solid corporate governance; Financial markets and financial advisory sector market knowledge, experience andknowledge in the financial services industry, risk management knowledge and experience
with local and international financial matters;
 Sufficient knowledge of the legal framework governing the operations of a Cyprus

investment firm, including the investment services and activities which are regulated by the
Cyprus Investment Firms Law;
 High sense of responsibility and work ethics portraying the professional traits of initiative;
 Criminal record certificate from the competent authorities of the country of residence of theperson for the last five years, attesting that the person has no criminal records;
 Good knowledge of the Greek or/and English languages. Particularly, when considering theappointment of a member of the Board, special attention shall be given to the potential
member’s skills review which aims to assess the specific experience and skills needed toensure the optimum blend of the potential individual and the aggregate capability having
regard to the Company’s long term strategic plan. Members of the Board and Senior
Management appointment are subject to the approval of the Chief Executive Officer and theBoard. Regulatory approval is co-ordinated through the Compliance Officer. The majority ofthe members of the Board shall be residents of Cyprus.
2.5. Policy on Diversity
The Company is committed to promoting a diverse and inclusive workplace at all levels,reflective of the communities in which it does business. It approaches diversity in the broadest
sense, recognizing that successful businesses flourish through embracing diversity into theirbusiness strategy, and developing talent at every level in the organization.
The Company recognises and embraces the benefits of having a diverse Board, and sees
increasing diversity at Board level as a necessary element in maintaining a competitive
advantage.
The Company believes that the diversity of the board enhances decision-making capability andthat a diverse board is more effective in dealing with organisational changes. A truly diverse
Board will include and make good use of differences in the skills, regional and industry
experience, background, gender, race and other distinctions between members of the Board.
These differences will be considered in determining the optimum composition of the Board andwhen possible should be balanced appropriately. The Company believes that the Board should becharacterized by a broad range of views arising from different experiences.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
For the purpose of this policy, the Company considers that the concept of diversity incorporates
a number of different aspects, therefore all Board appointments are made on merit, in the context
of the skills, experience, knowledge, business perspectives, industry or related experience,
independence, gender, age, cultural, educational background and more general experience which
the Board as a whole requires in order to be effective.
Skills and Experience
The Board should possess a balance of skills appropriate for the requirements of the business of
the Company, in order for the Company to benefit from its directors’ experience in a range ofactivities including varied industries, education, government, investment and the professions.
Further reference is made to Company’s Recruitment Policy in subsection 2.4, which aims toassess the specific experience and skills needed to ensure the optimum blend of the potential
individual and the aggregate capability having regard to the Company’s long term strategic plan.
Independence
The Board includes a composition of Executive and Non-executive Directors so that there is astrong element of independence in the Board. The Independent Non-executive Directors shall beof sufficient calibre and stature for their views to carry weight. Each member of the board mustact with independence of mind to properly assess and challenge the decisions of the senior
management where necessary and to effectively oversee and monitor management decisionmaking.
Gender
The Company is committed to maintaining an environment of respect for people regardless of
their gender in all business dealings and achieving a workplace environment free of harassment
and discrimination on the basis of gender, physical or mental state, race, nationality, religion, age
or family status. The same principle is applied to the selection of potential candidates forappointment to the Board
2.6. Governance Committees
Risk Management Committee
In order to support effective governance and management of the wide range of responsibilities
the Board has established the Risk Management Committee. The role of the Risk Management
Committee is to provide oversight, review and challenge of the material risks both current andfuture affecting the business whilst ensuring that there is effective management and control of all
key risks and issues facing the Company.
The Risk Management Committee, inter alia, scrutinizes, and decides on various risks inherent
with the operation of the Company with the view to formulate internal policies and measure theperformance of the said policies in dealing with the risks associated with the operation of theCompany. Moreover, the Risk Management Committee reviews the risk management proceduresin place (monitors and controls the Risk Manager in the performance of his duties and theeffectiveness of the Risk Management Department).
The Risk Management function operates independently and monitors the adequacy andeffectiveness of policies and procedures, the level of compliance to those policies andprocedures, in order to identify deficiencies and rectify. The Investment Committee is

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
responsible for monitoring and controlling the Risk Manager in the performance of his/herduties.
The Risk Management Committee meets at least annually, unless the circumstances require
extraordinary meetings. Extraordinary meetings can be called by any member of the Risk
Management Committee, as well as by the Risk Manager.
Investment Committee
An Investment Committee has been formed to ensure the implementation of a prudent
investment policy and the monitoring of the provision of adequate investment services to Clients.
The Investment Committee is responsible, inter alia:(a) to supervise the proper choice of investments (framework for investment decisions)(b) to analyse the investment potential and contribute to the elaboration of the investment
policy, as applicable(c) to determine the Company’s pricing policy(d) to decide upon the markets and types of Financial Instruments in which the Company shallbe active(e) to determine the mode, content and frequency of the Client’s briefing.
(f) to brief the Internal Auditor, as applicable(g) to establish, approve, adjust and monitor the Company Investment Policy in relation to thePortfolio Management Department by using the recommendations of the Heads of therelevant Departments through the Investment Reports, as applicable(h) to review the Company Investment Policy whenever a material change occurs(i) to establish risk profile categories for each Client (e.g. cautious, balance, growth,
aggressive)(j) to analyse the economic conditions and the investment alternatives based on a thoroughexamination of third party reports(k) to select appropriate benchmarks for different type of portfolios, where applicable(l) to examine the returns and the associated risks of the Client portfolios, as applicable(m) to annually review the established dealing on own account policy and to use therecommendations of the Head of the Dealing on Own Account Department. Such a review
shall also be carried out whenever a material change occurs(n) to monitor the collection of the Client information through the filling of the Investment
Questionnaire, or information obtained through interviews
2.7. Other Governance Functions
Internal Audit
The Company, taking into account the nature, scale and complexity of its business activities, aswell as the nature and the range of its investment services and activities, establishes andmaintains an internal audit function through the appointment of a qualified and experienced
Internal Auditor. The Internal Auditor is appointed and reports to the Senior Management andthe Board of the Company.
The Internal Auditor is separated and independent of the other functions and activities of theCompany. The Internal Auditor bears the responsibility to:(a) establish, implement and maintain an audit plan to examine and evaluate the adequacyand effectiveness of the Company’s systems, internal control mechanisms andarrangements(b) issue recommendations based on the result carried out in accordance with point (a)GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report(c) verify compliance with the recommendations of point (b)(d) provides timely, accurate and relevant reporting in relation to internal audit matters to theBoard of Directors and the Senior Management of the Company, at least annually.
The Internal Auditor is responsible for applying the Internal Control System (hereinafter, the“ICS”), which confirms the accuracy of the reported data and information. Furthermore, the roleof the Internal Auditor is the programming, on an at least annual basis (as applicable), of checks
on the degree of application of the required ICS.
The Internal Auditor has clear access to the Company’s personnel and books. Likewise, theCompany’s employees have access to the Internal Auditor for the reporting of any significant
deviations from the guidelines provided.
The Board ensures that internal audit issues are considered when presented to it by the Internal
Auditor and appropriate actions shall be taken. The Board ensures all issues are dealt with andprioritized according to the Board’s assessment.
Compliance Officer
Pursuant to the regulatory obligations of the Company and with the view to complement theInternal Governance framework of the Company, the Board has appointed a Compliance Officer,
to head the Compliance Function of the Company in order to establish, implement and maintainadequate policies and procedures designed to detect any risk of failure by the Company tocomply with its obligations, to put in place adequate measures and procedures designed tominimize such risks and to enable the competent authorities to exercise their powers effectively.
The Compliance Officer is independent and reports directly to the Senior Management of theCompany, having at the same time the necessary authority, resources, expertise and access to all
relevant information.
The Compliance Officer is responsible, inter alia, to:a) liaising with all relevant business and support areas within the Companyb) to monitor on a permanent basis and to assess, on a regular basis, the adequacy andeffectiveness of the measures, policies and procedures put in place, and the actions taken
to address any deficiencies in the firm's compliance with its obligations;c) monitoring and assessing the level of compliance risk that the Company faces, taking
into account the investment and ancillary services provided, as well as the scope offinancial instruments traded and distributedd) monitoring the adequacy and effectiveness of the measures and procedures of theCompanye) advising and assisting the relevant persons responsible for carrying out the investment
services to be in compliance with the Law
Anti-Money Laundering Compliance Officer
The Board retains a person to the position of the Company’s Anti-Money Laundering
Compliance Officer (hereinafter the “AMLCO”) to whom the Company's employees report theirknowledge or suspicion of transactions involving money laundering and terrorist financing. The
AMLCO belongs to the higher hierarchical levels/layers of the Company so as to command thenecessary authority. The AMLCO leads the Company’s Anti-Money Laundering Compliance
procedures and processes and report to the Senior Management and the Board of the Company.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
Scope and objectives of the AMLCO:a) The improvement of mechanisms used by the Company for counteraction of legalization(laundering) of criminally earned incomeb) To decrease the probability of appearance among the Customers of the Company of any
persons/organizations engaged in illegal activity and/or related with such persons/organizationsc) To minimize the risk of involvement of the Company in any unintended holding and realizationof operations with any funds received from any illegal activity or used for its financingd) To ensure compliance with anti-money laundering laws and directives issued by CySec

as well as the identification and proper reporting of any money laundering activity to therelevant authorities
2.8. Information flow on risk to the management body
Risk information flows up to the Board directly from the business departments and control
functions. The Board ensures that it receives on a frequent basis, at least annually written reports
regarding Internal Audit, Compliance, Money Laundering and Terrorist Financing and Risk
Management issues and approves the Company’s ICAAP report as shown in the table below:
Table 4- Information flow on risk to management body
Report Name
Owner of Report
Recipient
1 Risk Management
Risk Manager
Senior Management,
ReportBoard
2 Pillar I – CRDIV
Risk Manager
Senior Management,
CoRep Forms
Board
3 ICAAP (Pillar 2)
Risk Manager
Senior Management,
ReportBoard
4 Pillar 3 Disclosures
Risk Manager
Senior Management,
Board
5 Risk Register
Risk Manager
Senior Management,
Board
6 Compliance ReportCompliance Officer Senior Management,
Board
7 Internal Audit
Internal Auditor
Senior Management,
ReportBoard
8 Anti-money
Anti-money
Senior Management,
laundering
laundering
Board(AMLCO) ReportCompliance Officer

Frequency
Annually
Quarterly
Annually
Annually
Annually
Annually
Annually
Annually

Furthermore, the Company believes that the risk governance processes and policies are of utmost
importance for its effective and efficient operation. The processes are reviewed and updated on
an annual basis or when deemed necessary

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

3. OWN FUNDS
Own Funds (also referred to as capital resources) is the type and level of regulatory capital thatmust be held to enable the Company to absorb losses.
The Company is required to hold own funds in sufficient quantity and quality in accordance withCRD IV which sets out the characteristics and conditions for own funds.
The Company throughout the year under review managed its capital structure and madeadjustments to it in light of the changes in the economic and business conditions and the risk
characteristics of its activities.
During the 12 month accounting period to 31 December 2018 the Company complied fully withall capital and liquidity requirements and operated well within the regulatory requirements.
The Total Capital Ratio of the Company as at 31 December 2018 was 11.99% which is above theminimum regulatory capital of 9.875% (8% + buffers). The Company’s Combined Buffer
Requirement consists of the following:Regulatory capital requirement of the level of 8%,Capital Conservation Buffer (“CCB”),

Countercyclical Capital Buffer (“CCyB”) and

Specific risk buffer derived from the Company’s Exposures to Estonia (Circular C222).

It is noted that the CCB for the year 2019 will be increased to 2.50% and as such the Combined
Buffer Requirement will be at least 10.50%.
3.1. Tier 1 & Tier 2 Regulatory Capital
Institutions shall disclose information relating to their own funds. Furthermore, institutions shalldisclose a description of the main features of the Common Equity Tier 1 and Additional Tier 1
instruments and Tier 2 instruments issued by the institution. In this respect, the Company’s Tier
1 capital is wholly comprised of Common Equity Tier 1 Capital.
The composition of the capital base and capital ratios of the company are shown in the following
table:

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
Table 5 - Composition of the capital base and capital ratios
Capital Instruments
Capital instruments and the related share premium accounts
Retained earnings
Common Equity Tier 1 (CET1) capital: instruments and reserves
Additional deductions of CET1 Capital due to Article 3 of the CRR (*)
Other intangible assets
Total regulatory adjustments
Common Equity Tier 1 (CET1) capital
Additional Tier 1 (AT1) capital
Tier 1 capital (T1 = CET1 + AT1)
Tier 2 (T2) capital
Total capital (TC = T1 + T2)

€000
1,016
664
1,680
(62)
(36)
(98)
1,582
1,582
1,582

Risk weighted assets
Credit risk
1,373
Market risk
5,671
Operational risk
6,023
CVA
131
Total risk weighted assets
13,198
Capital ratios and buffers
Common Equity Tier 1
11.99%
Tier 111.99%
Total Capital
11.99%
Institution specific buffer requirement (CET1 requirement in accordance
6.375%
with article 92 (1)(a) plus capital conservation and countercyclicalbuffer requirements, plus systemic risk buffer, plus the systemicallyimportant institution buffer (G-SII or )-SII buffer), expressed as apercentage of risk exposure amount)of which: capital conservation buffer requirement
1,875%of which: counter cyclical buffer requirement(**)
of which: systemic risk buffer requirement(***)
of which: Global Systemically Important Institution (G-SII) or
Other Systemically Important Institution (O-SII) buffer
CET1 available to meet buffers(****)
3.99%* Treatment pursuant to Circular C162 (Capital adequacy requirements - Change in thetreatment of the Investors Compensation Fund (“ICF”) Contribution) on 10 October 2016,
according to which the contribution to ICF will no longer be risk weighted as an “exposure to
public sector entities” pursuant to paragraph 13(3) of Directive DI144-2014-15. The said ICF
exposure will be deducted from CET1 Capital pursuant to Article 3 (Application of stricter
requirements by institutions) of the CRR. The aforementioned Article gives the member states thepower to request from the institutions to hold own funds in excess of those required by the CRR.
** The Company is exempted from the countercyclical buffer requirement for 2018.
***The Company has no exposures located in Estonia as at 31 December 2018.
**** Common Equity Tier 1 available to meet buffers (as a percentage of risk weighted assets).

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
The figures below illustrate the Capital Ratios and the breakdown of the exposures for the year ended
31 December 2018:

3.2. Main features of Common Equity Tier 1, Additional Tier 1 and Tier 2 instruments
In order to meet the requirements for disclosure of the main features of these instruments, thecompany discloses the capital instruments’ main features as outlined below:
Table 6 - Main features of capital instruments
Capital Instruments Main Feature
CET1
Issuer
GBE Brokers Ltd
Regulatory Treatment
Eligible at Solo/(sub-)consolidated/solo
Solo
Instrument type
Common Equity
Amount recognized in regulatory capital€1,016k
Nominal amount of instrument€1,016k
Issue Price
Various
Accounting classification
Shareholders’ Equity
Share Capital Increase€1k
Original date of issuance€1,000k€15k
Perpetual or dated
Perpetual
Original maturity dateNo maturity
Issuer call subject to prior supervisory No
approval
Coupons / Dividends
Fixed or floating dividend/coupon
Floating
Coupon rate and any related index
N/A

Effective Date
05/08/2013
04/08/2014
24/10/2014

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
The Company’s capital resources consist of CET1 Capital. No additional Tier 1 or Tier 2 Capital
available.
3.3. Balance Sheet Reconciliation
Institutions shall disclose a full reconciliation of Common Equity Tier 1 items, Additional Tier 1
items, Tier 2 items, filters, deductions and the balance sheet in the audited financial statements of
the institution as follows:
Table 7 - Balance Sheet Reconciliation€000
EquityShare capital
Share premium
Retained earnings
Total Equity as per the Audited Financial Statements

11
1,005
664
1,680

Regulatory Deductions
Additional deductions of CET1 Capital due to Article 3 of the CRR
Other Intangibles Assets
Total Regulatory Deductions

(62)
(36)
(98)

Total Own funds as per the CoRep Forms

1,582

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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4. COMPLIANCE WITH REGULATORY CAPITAL AND THE OVERALL PILLAR II
RULE
4.1. Internal Capital
The purpose of capital is to provide sufficient resources to absorb unexpected losses over andabove the ones that are expected in the normal course of business. The Company aims tomaintain a minimum risk asset ratio which will ensure there is sufficient capital to support theCompany during stressed conditions.
4.2. Approach to assessing adequacy of Internal Capital
The Company has established an ICAAP, documented it in a Manual and produced in this regard
the ICAAP Report, as per the Circular C026 and Circular C027. Upon CySEC’s request the
ICAAP Report shall be submitted to CySEC.
The Company has adopted the Pillar I plus approach whereby it determines the minimum capitalrequired under Pillar I methodology and subsequently incorporates in that methodology the risks
that are either not covered or are partially covered by Pillar I. Initially an assessment is made on
the general financial position of the Company both from its financial statements and its Capital
Adequacy Returns.
The Pillar I variable capital requirement is the sum of the credit risk and market risk
requirements and the operational risk. In order to validate the adequacy of the above
requirements under the Pillar I calculations, the ICAAP proceeds with the following individual
tests:









The adequacy of the credit and market risk requirements is assessed with reference to all
relevant balance sheet items in order to ascertain if there are additional risks that are notcovered by Pillar I
Other risks connected with the balance sheet, such as liquidity risk and concentration
risk, are reviewed in order to establish whether there should be an additional requirementthat might not be covered under Pillar I
The overall capital adequacy is tested by adding together the resulting requirement of theidentified risks.
The absolute impact of combinations of scenarios, including a severe market downturn,is considered in relation to the financial forecasts of the business to assess the potential
impact on the capital base over a three year period (forward-looking).
A comprehensive risk assessment is carried out for all risks, categorizing them under arisk profile by attributing the anticipated impact and likelihood of occurrence.
Finally, additional measures are set for the mitigation of the identified risks as well as
capital allocation

The Company operates a fully integrated ICAAP process throughout the year that rolls into thefinal ICAAP assessment. The Company also performs monthly key risk assessments supported
by periodic stress testing. The ICAAP process considers all of the risks faced by the Company,
the likely impact of them if they were to occur, how these risks can be mitigated and the amountof capital that it is prudent to hold against them both currently and in the future.
The ICAAP Report describes how the Company implemented and embedded its ICAAP within
its business. The ICAAP also describes the Company’s Risk Management framework e.g. theGBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures ReportCompany’s risk profile and the extent of risk appetite, the risk management limits if any, as wellas the adequate capital to be held against all the risks (including risks other than the Pillar I risks)
faced by the Company.
According to the Policy Statement (PS-01-2019), €730k CFD CIFs must consider and address
the NBP requirement in the context of their ICAAP. In this respect, the Company's ICAAP shallbe prepared by taking into consideration the risks emanating from the NBP.
The graph below illustrates the process between ICAAP and SREP:The Supervisory Review and Evaluation Process (SREP) is the supervisory tool for establishing
the appropriate level of capital resources that a CIF should hold in order to meet its present andfuture capital requirements over a period of up to five years. Circular C027 outlines how CySEC
applies the supervisory review and evaluation process (SREP) when reviewing the CIFs’ internal
capital adequacy assessment processes (ICAAP) under the framework of the paragraph 33 of the
Directive DI144-2014-14.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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5. PILLAR I CAPITAL REQUIREMENTS
The following tables show the overall Pillar I minimum capital requirement and risk weighted
assets for the Company under the Standardised Approach to Credit Risk, Market Risk and the
Basic Indicator Approach for the Operational Risk.
5.1. Credit Risk
In the ordinary course of business, the Company is exposed to credit risk, which is monitored
through various control mechanisms. Credit risk arises when a failure by counterparties todischarge their obligations could reduce the amount of future cash inflows from financial assets
on hand at the balance sheet date.
The Company has policies to diversify risks and to limit the amount of credit exposure to any
particular counterparty in compliance with the requirements of the Directive. The Company
continuously monitors the fair value calculations, forecast and actual cash flows, and costbudgets so that to ensure that the carrying level of Company’s own funds and consequently the
Capital Adequacy ratio meet the regulatory requirements at all times.
Trade receivables are shown net of any provision made for impairment. The management
believes that no additional credit risk, beyond amounts provided for collection losses, is inherent
in the trade receivables. Cash balances are held with high credit quality financial institutions andthe Company has policies to limit the amount of credit exposure to any financial institution.
5.1.1. Credit risk adjustments
The Company assesses at the balance sheet date whether there is objective evidence that afinancial asset or group of financial assets is impaired. A financial asset or a group of financial
assets is impaired and impairment losses are incurred only if there is objective evidence ofimpairment as a result of one or more events that occurred after the initial recognition of theasset (a “loss event”) and that loss event (or events) has an impact on the estimated future cash
flows of the financial asset or group of financial assets that can be reliably estimated.
Trade receivables are recognized initially at fair value and are subsequently measured atamortized cost using the effective interest method, less provision for impairment. For thosetrading receivables that are 90 days or more past due, in non-accrual status, the Company
classifies them as “in default”, thus an impairment test will emerge. A financial asset is past due
if a counterparty has failed to make a payment when contractually due.
Other receivables are recognized initially at fair value and subsequently measured at amortized
cost, using the effective interest method, less provision for impairment. A provision for
impairment of other receivables is established when there is objective evidence that theCompany will not be able to collect all amounts due according to the original terms ofreceivables. Significant financial difficulties of the debtor, probability that the debtor will enter
bankruptcy or delinquency in payments are considered indicators that the trade receivable isimpaired. The amount of the provision is the difference between the asset's carrying amount andthe present value of estimated future cash flows, discounted at the original effective interest rate.
When a receivable is uncollectible, it is written off against the allowance account for otherreceivables. Subsequent recoveries of amounts previously written off are credited in thestatement of comprehensive income. None of the derivative financial instruments is either pastdue or impaired.
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
5.1.2. Credit Risk – Risk Weighted Assets
The Company’s Credit Risk Weighted Assets and Capital Requirements broken down by
exposure class were as follows:
Table 8 - Exposure classes as at 31 December 2018
Risk Weighted Assets€000
Exposure class463
Institutions
312
Corporates
499
Retail99
Other Items
1,373
Total

Capital Requirements
€000
37
25
40
8
110

The Regulation requires disclosure for additional asset classes. These have not been shown in thetable above as these are nil as at the reporting period.

Risk Weighted Assets by Exposure Class
Other Items
7%

Retail36%

Institution
34%

Corporate
23%

5.1.3. Credit Risk – Analysis of Average exposures and total amount of exposures after
accounting offsets
The Company shall disclose the total amount of exposures after accounting offsets and without
taking into account the effects of credit risk mitigation and the average amount of the exposuresover the period broken down by different types of exposures as follows:
Table 9 - Analysis of Average Exposures
Original exposure amount,net of specific provisions€000
Exposure class
1,928
Institutions
390
Corporates
1,301
Retail99
Other Items
3,718
Total

Average Exposure
€000
1,910
422
1,228
588
3,992

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
5.1.4. Credit Risk – Risk Weighted Assets by Geographical distribution of the exposure
classes
The Company shall disclose the geographical distribution of the exposures, broken down insignificant areas by material exposures classes. The geographical distribution of the exposure
classes of the Company are as follows:
Table 10 - Geographical distribution of the exposure classes
31 December 2018
New
Cyprus Germany Switzerland
Exposure class
Zealand
€000
€000
€000
€000
Institutions
870
359
26
170
Corporates
1
361
Retail37
676
248
Other Items
99
Total
1,006
1,036
636
170

Korea
€000

Other
€000

Total
€000

140
140

363
28
339
730

1,928
390
1,301
99
3,718

The Regulation requires disclosure for additional asset classes. These have not been shown in thetable above as these are nil as at the reporting period.

Geographical Distribution of the Exposures
Other
20%
CY
27%

DE
28%

KR NZ
4% 4%

CH
17%

5.1.5. Credit Risk – Distribution of exposures by industry
The Company shall disclose the distribution of the exposures by industry or counterparty type,broken down by exposure classes, including specifying exposure to SMEs, and further detailed if
appropriate as follows:
Table 11 - Exposures by industry
Banking/Financial
Exposure
services
class€000
Institutions
1,928
Corporates
390
RetailOther Items
38
Total
2,356

PrivateIndividuals
€000
1,301
1,301

Other

Total

€000
-

€000
1,928
390
1,301
99
3,718

61
61

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

Exposure by Industry
Other
2%

PrivateIndividuals
35%

Banking/Financial
services
63%

5.1.6 Residual maturity broken down by exposure classes
The Company shall disclose the residual maturity breakdown of all the exposures, broken down
by exposure classes, as follows:
Table 12 - Residual maturity broken down by exposure class
Residual Maturity
Residual Maturity≤ 3 months> 3 months
Exposure Class
€000
€000
Institutions
1,928
Corporates
390
Retail1,301
Other Items
38
61
Total
3,656
61

Total
€000
1,928
390
1,301
99
3,718

5.2. Use of ECAIs
The Company shall disclose the names of the nominated External Credit Assessment Institutions(“ECAIs”) and the exposure values along with the association of the external rating with thecredit quality steps.
The Company uses external credit ratings from Moody’s. These ratings are used for all relevant
exposure classes. The general ECAI association with each credit quality step is as follows:
Table 13 - ECAI Association with each credit quality stepInstitutions
CreditMoody’s
Credit Assessment method
Quality
Corporate Sovereign
RatingMaturity
Maturity 3
Stepmethod> 3 months
months or less1
Aaa to Aa3
20%
20%
20%
20%
2
A1 to A3
50%
50%
50%
20%
3
Baa1 to Baa3
100%
100%
50%
20%
4
Ba1 to Ba3
100%
100%
100%
50%
5
B1 to B3
150%
100%
100%
50%
6
Caa1 and
150%
150%
150%
150%
below
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

Sovereign
0%
20%
50%
100%
100%
150%
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2018 Pillar III Disclosures Report
Exposures to unrated institutions are assigned a risk weight according to the credit quality step towhich exposures to the central government of the jurisdiction in which the institution isincorporated, as specified in Article 121 of CRR.
Notwithstanding the general treatment mentioned above, short term exposures to institutions
could receive a favourable risk weight of 20% if specific conditions are met.
The Other Items category includes tangible assets, debtors and prepayments risk weighted at
100%, cash items in the process of collection risk weighted at 20% and cash in hand risk
weighted at 0%.
Exposures to corporate clients were risk weighted by 100% risk factor since they were all
unrated and were incorporated in countries with no credit rating or with credit assessment up tocredit quality step 5.
The exposure values pre- and post-credit mitigation, by credit quality step are indicated below:
Table 14- Exposures before and after credit risk mitigation as at 31 December 2018
Exposure values before
Exposure values after credit
Credit Quality Step
credit risk mitigation
risk mitigation
€000
€000
CQS 5
861
861
Unrated
2,857
1,540
Total
3,718
2,401
5.3. Securitisations
The Company is not an active participant in the origination of securitisations (meaning pooled
assets with trenched risk), and accordingly detailed Pillar III disclosures are not made.
5.4. Counterparty Credit Risk
Counterparty Credit Risk (“CCR”) may be defined as the risk that the counterparty to atransaction could default before the final settlement of the transaction's cash flows. Suchtransactions relate to contracts for financial derivative instruments, repurchase agreements andlong settlement transactions.
The company takes margin cash deposits as funded credit protection (collateral) for derivatives
and uses the Financial Collateral Comprehensive Method for calculation of the funded credit
protection.
The Company in its ordinary course of business uses over the counter (OTC) derivatives tohedge exposures, i.e. interest rate and foreign exchange risk.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
Table 15- Counterparty Credit Risk broken down by contract type as at 31 December 2018
Type ofcontract

Interest rate
FX rates &Gold
Equities
Precious
metals except
gold
Commodities
other than
precious
metals
Total

€000
0

ExposureAmountbefore
CRM€000-

ExposureAmount
after
CRM
€000
-

764

104,783

1,811

162

2,934

1

Positive
Fair
Value

NominalValue

Risk
Weighted
AssetsCapitalRequirements

€000
-

€000
-

€000
-

1,136

705

56

338

186

135

11

290

21

21

12

1

21

337

55

24

17

1

948

108,344

2,225

1,368

869

69

5.5. Market Risk
Market risk can be defined as the risk of losses in on and off-balance sheet positions arising fromadverse movements in market prices. From a regulatory perspective, market risk stems from all
the positions included in banks' trading book as well as from commodity and foreign exchange
risk positions in the whole balance sheet. As per the requirements of the Regulation, theCompany shall disclose the own funds requirements for Market Risk exposures.
The Company implements a hedging strategy to minimize its exposure to the market risk. This
strategy consists of identifying and monitoring customers that are associated with higher degrees
of risk for the Company, and hedging positions with clients by opening own account hedging
trades with a cooperating broker. The Company also has a maximum limit of tolerated loss,
which is also used as a trigger for hedging.
The Company benefits from a number of factors that reduce the volatility of its revenue andprotect it from significant changes in market conditions such as its product range. This
diversification leads to a significant reduction in the Company’s exposure to price risk. The
Company’s exposure to risk price at any point in time depends primarily on short-term market
conditions and client activities during the trading day, hence the exposure at each reporting date
may not be representative of the price risk exposure faced by the Company over the year. The
following table discloses the Company’s market risk as 31 December 2018:
Table 16- Market Risk Exposure
Market Risk

2018

Risk Weighted Assets€000

Traded Debt Instruments-

Equity387

Foreign Exchange

4,497

Commodities

787

Total Market Risk Exposure

5,671

Total Market Risk Requirements454

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
5.5.1. Equity Risk
The sum of the absolute values of all the Company’s net long positions and all its net shortpositions is its overall gross position. The Company calculates, separately for each market, thedifference between the sum of the net long and the net short positions. The sum of the absolutevalues of those differences is its overall net position.
The specific risk on this individual equity can be ignored if the stock-index future in question is
exchange traded and represents a relevant appropriately diversified index.
The Company multiplies its overall gross position by 8% in order to calculate its own funds
requirement against specific risk. The own funds requirement against general risk are theCompany's overall net position multiplied by 8%.
Table 17 - Capital requirements for position risks in equities
Total Exposure€000
General Risk
315
Specific Risk
72
Total
387

Capital requirements
€000
25
6
31

5.5.2. Foreign Exchange Risk
Foreign exchange risk is the effect that unanticipated exchange rate changes have, on the
Company.
In the ordinary course of business, the Company is exposed to foreign exchange risk, which ismonitored through various control mechanisms.
The foreign exchange risk in the Company is effectively managed by setting and controlling
foreign exchange risk limits, such as through the establishment of maximum value of exposure toa particular currency pair as well as through the utilization of sensitivity analysis.
The Company’s foreign exchange risk capital requirement is EUR 360k emanating from a net
foreign exchange exposure of EUR 4,497k based on the latest relevant calculations of theCompany’s capital requirements, as at 31st of December 2018.
The Company continues to regularly monitor the impact of exchange rate risks and if deemednecessary corrective actions will be taken to minimize the effect.
Closely Correlated Currencies
Following the EBA’s Final draft Implementing Technical Standards on Closely Correlated
Currencies under Article 354 (3) of CRR, the Company may apply lower own funds
requirements against positions in relevant closely correlated currencies as those are disclosed by
EBA. In this respect, for the calculation of the foreign exchange risk for matched positions on
closely correlated currencies, a capital requirement of 4% instead of 8% is used.
As at 31 December 2018 the Company’s matched positions in closely correlated currencies werezero.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
5.5.3. Commodities Risk
The risk of the unexpected changes in commodities prices. These commodities are split into
precious metals (except gold), base metals, agricultural products and other energy products (oilgas). The Company calculates its capital requirement with respect to commodities risk using the
Simplified Approach.
Each position in commodities or commodity derivatives is expressed in terms of the standard
unit of measurement. The spot price in each commodity is expressed in the reporting currency.
The capital requirements for each commodity are calculated as the summation of the following:

15% x net position (long or short) x spot price for the commodity
3% x gross position (long plus short) x spot price for the commodity

The overall capital requirements for commodities risk is the sum of capital requirements for eachcommodity.
Table 18 - Capital requirements for Commodities risk
Total Exposure€000
Positions in commodities
787

Capital requirements€000
63

5.5.4. Interest Rate Risk
Interest rate risk is the risk that the value of financial instruments will fluctuate due to changes inmarket interest rates. The Company is exposed to interest rate risk in relation to its bank deposits
and from the interest charged on the derivative financial instruments that remain open overnight.
The Company's management monitors the interest rate fluctuations on a continuous basis andacts accordingly.
5.6. Operational Risk
Operational risk is defined as the risk of loss resulting from inadequate or failed internal
processes, people and systems or from external events, including legal risk. It is inherent in every
business organization and covers a wide range of issues. The Company manages operational risk
through a control-based environment in which processes are documented and transactions arereconciled and monitored. This is supported by continuous monitoring of operational risk
incidents to ensure that past failures are not repeated.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

In addition, the Company has developed, implemented and maintains an Operational Risk
Management Framework, congruent with the Policy and the principles of the Capitalrequirements (CRR/CRDIV) framework. The Operational Risk Management Frameworkprovides the strategic direction and guidelines on operational risk in order to ensure that aneffective operational risk management and measurement process is adopted throughout theCompany. The Framework also provides for the consistent and comprehensive capture of data
elements needed to measure and verify the operational risk exposure, as well as to implement
appropriate reporting systems and mitigation strategies.
Further to the above, the company has in place controls and procedures in order to reduce theoperational risk arising, as follows: Monitoring of the effectiveness of policies, procedures and controls; Use of systems to automate processes and controls to eliminate risk due to human error; Ongoing maintenance of procedures to prevent unauthorised actions and errors; Use of training to reduce the likelihood of human error arising from lack of expertise Maintaining risk registers in the context of ICAAP; and Maintaining a four-eye structure and implementing board oversight over strategic
decisions made by the heads of departments;
Furthermore, the Company has in place additional policies and processes whose implementation
assists with the evaluation and management of any exposures to operational risk. Such policy
and process is the Business Continuity and Recovery Plan. The Company acknowledges that asignificant hazard exists to its ability to continue normal business procedures following
unexpected incident. Moreover, the Company has an important dependency with its automatic
systems and processes. As a result, a recovery plan is needed in order to deal with the risk ofpotential disaster.
The objectives of this plan are to provide:a) continuing operations so that the Company can offer its services to the clients,b) business and records protection,c) a framework for risk and exposure controlling,d) measures against risks.
For the calculation of operational risk in relation to the capital adequacy reports, the Company
uses the Basic Indicator Approach (BIA). Under the BIA, the own funds requirement for
operational risk is equal to 15% of the average over three years of the relevant indicator. Basedon the relevant calculations the Company’s exposure to Operational Risk, as at 31 December
2018, was €6,023k as provided by the table below:
GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
The tables below show the Company’s exposure to Operational Risk:
Table 19 - Operational Risk capital requirements
2018Year -3

Year -2Last Year

Total Exposure

Total

€000
2,180

€000
3,682

€000
3,775

€000
6,023

CapitalRequirements
€000
482

Under the Basic Indicator Approach, the capital requirement for operational risk is equal to 15%of the average of three years of the above relevant indicator, resulting to €482k capitalrequirements.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

6. LEVERAGE RATIOThe Company shall disclose the Leverage Ratio and how it applies the definition of Tier 1
Capital.
The leverage ratio is a supervisory tool for the European Union, which it is in line withinternational agreements. Moreover, it is a supplementary non-risk based ratio that aims inmonitoring the excessive built-up of leverage on the balance sheet of institutions. The leverage
ratio is expressed as a percentage of Tier 1 Capital over the total leverage exposure measure.
The total leverage exposure measure is defined as the sum of exposure values of all assets and all
off-balance sheet items not deducted when calculating Tier 1 Capital.
The Leverage Exposure measure includes:All On-balance sheet assets;
Derivative exposures;
Securities Financing Transaction exposures;
Other non-trading book exposures.

The Basel Committee has set a benchmark of 3% for a minimum Leverage ratio.
The Company’s Leverage Ratio for the period up to 31 December 2018 was 42.56%:
Table 20 - Leverage Ratio
2018

Leverage Ratio
Exposure€000

Exposure Values
Derivatives: Current Replacement Cost
Derivatives: Add-on under the mark-to-market Method
Other assets
Total exposures

948
1,278
1,492
3,718

Capital and regulatory adjustments
Tier 1 capital – fully phased-in definition

1,582

LEVERAGE RATIO

42.56%The Company monitors leverage closely in order to ensure that any possible excess of the
Leverage Limit will be identified and managed promptly. The Company’s leverage ratio of
42.56% is well above the minimum ratio of 3%.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

7. OTHER RISKS
7.1. Concentration Risk
Concentration Risk includes large individual exposures and significant exposures to companies
whose likelihood of default is driven by common underlying factors such as the economy,geographical location, instrument type etc.
Concentration risk was partly addressed through diversification of counterparties, namely
banking institutions.
The Company’s experience in the collection of trade receivables has never caused debts which
are past due and have to be impaired. The company has a policy in place to monitor debts
overdue by preparing debtors ageing reports.
Large Exposures
The Company shall disclose any additional capital requirements derived from large exposures in
the Company’s trading book.
A large exposure is defined as the total exposure of a firm to a client or group of connectedclients, whether in the banking book or trading book or both and its value is equal to or exceeds
10% of its eligible capital.
Where the amount of €150 million is higher than 25% of the institution's eligible capital thevalue of the exposure, after taking into account the effect of credit risk mitigation in accordancewith Articles 399 to 403 shall not exceed a reasonable limit in terms of the institution's eligible
capital. That limit shall be determined by the institution in accordance with the policies andprocedures referred to in Article 81 of Directive 2013/36/EU, to address and control
concentration risk. This limit shall not exceed 100% of the institution's eligible capital.
Large exposures related to the trading book are subject to additional capital requirements as per
the Article 397 of the CRR. Moreover, the capital charge is associated with the trading book
exposure for each client or group of connected clients exceeding the large exposure limit times a
multiplier which is defined on table 1 of the aforementioned article.
The Company’s exposures are within the limits and as such no further actions are required.
Counterparty Policies with respect to wrong-way risk exposures
Wrong-way risk occurs when the exposure to a particular counterparty is positively correlatedwith the PD of the counterparty itself or where there is an adverse correlation between
counterparty’s PD and the mark-to-market value of the underlying transaction. A wrong-way
trading situation can be defined as the condition where the exposure to the counterparty
increases, while the counterparty’s financial situation and its ability to pay on the transaction
diminishes.
As part of the credit review process, basic assumptions are established regarding correlations fora given trading product.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report
The management of wrong-way risk is integrated within the Company’s overall credit risk
assessment approach and is subject to a framework for identification and treatment of wrongway risk, which includes governance, processes, roles and responsibilities, methodology,
scenarios, reporting, review and escalation.
A conservative treatment for the purpose of calculating exposure profiles is applied to material
trades with wrong-way risk features. The wrong-way risk framework applies to OTC, securities
financing transactions and centrally cleared trades. If material correlation is identified, thecollateral is deemed ineligible for regulatory risk calculations and risk is measured on an
uncollateralised basis. The Company does not have any Wrong-Way Risk Exposures.
7.2. Reputation Risk
Reputation risk is the current or prospective risk to earnings and capital arising from an adverse
perception of the image of the Company on the part of customers, counterparties, shareholders,investors or regulators. Reputation risk could be triggered by poor performance, the loss of one
or more of the Company’s key directors, the loss of large customers, poor customer service,fraud or theft, customer claims, legal action and regulatory fines.
The Company has transparent policies and procedures in place when dealing with possible
customer complaints in order to provide the best possible assistance and service under suchcircumstances. The possibility of having to deal with customer claims is very low as theCompany provides high quality services to customers.
7.3. Strategic Risk
Strategic Risk could occur as a result of adverse business decisions, improper implementation ofdecisions or lack of responsiveness to changes in the business environment. The Company’s
exposure to strategic risk is moderate as policies and procedures to minimize this type of risk are
implemented in the overall strategy of the Company.
7.4. Business Risk
Business Risk includes the current or prospective risk to earnings and capital arising fromchanges in the business environment including the effects of deterioration in economic
conditions. Research on economic and market forecasts are conducted with a view to minimize
the Company’s exposure to business risk. These are analyzed and taken into consideration when
implementing the Company’s strategy.
7.5. Capital Risk Management
Capital Risk is the risk that the Company will not comply with capital adequacy requirements.
The Company's objectives when managing capital are to safeguard the Company's ability tocontinue as a going concern in order to provide returns for shareholders and benefits for otherstakeholders. The Company has a regulatory obligation to monitor and implement policies andprocedures for capital risk management. Specifically, the Company is required to test its capitalagainst regulatory requirements and has to maintain a minimum level of capital. This ultimately
ensures the going concern of the Company. Such procedures are explained in the Procedures
Manual of the Company.
The Company is further required to report on its capital adequacy quarterly and has to maintainat all times a minimum total capital adequacy ratio which is set at 8%. The capital adequacy ratio
expresses the capital base of the Company as a proportion of the total risk weighted assets.
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2018 Pillar III Disclosures ReportManagement monitors such reporting and has policies and procedures in place to help meet the
specific regulatory requirements. This is achieved through the preparation on a monthly basis ofmanagement accounts to monitor the financial and capital position of the Company.
7.6. Regulatory Risk
Regulatory risk is the risk the Company faces by not complying with relevant Laws andDirectives issued by its supervisory body. If materialized, regulatory risk could trigger the effects
of reputation and strategic risk. The Company has documented procedures and policies based on
the requirements of relevant Laws and Directives issued by the Commission; these can be foundin the Procedures Manual. Compliance with these procedures and policies are further assessed
and reviewed by the Company’s Internal Auditors and suggestions for improvement are
implemented by management. The Internal Auditors evaluate and test the effectiveness of theCompany’s control framework at least annually. Therefore the risk of non-compliance is verylow.
7.7. Legal and Compliance Risk
Legal and Compliance Risk could arise as a result of breaches or non-compliance withlegislation, regulations, agreements or ethical standards and have an effect on earnings andcapital. Following the replacement of the Law 144(I)/2007 by Law 87(I)/2017 for the purpose of
harmonization with MIFID II, several regulatory changes were applied that may cause theCompany’s exposure to compliance risk. The Company among others, is also exposed to legal
and compliance risk arising from inability or inadequate arrangements to comply with therequirements related to the:











Product Governance (Circular C236, Directive DI87-01),
New rules governing derivatives on virtual currencies (Circular C268),
Commission Delegated Regulation of 8 June 2016 of the European Parliament and of theCouncil with regard to regulatory technical standards for the annual publication by
investment firms of information on the identity of execution venues and on the quality of
execution,
Additional specific risk buffer with respect to exposures in Estonia (Circular C222),
Policy Statement on the Risk Management Arrangements of Cyprus Investment Firms
Providing Investment Services in CFDs,
European Securities and Markets Authority Decision (EU) 2019/155 of 23 January 2019
renewing the product intervention measures relating to the marketing, distribution or saleof contracts for differences to retail clients,
Provisions of the General Data Protection Regulation (GDPR) 2016/679 and
4th AML Directive (Directive (EU) 2015/849)

The probability of such risks occurring is relatively low due to the detailed internal proceduresand policies implemented by the Company and regular reviews by the Internal Auditors. The
structure of the Company is such to promote clear coordination of duties and the management
consists of individuals of suitable professional experience, ethos and integrity, who haveaccepted responsibility for setting and achieving the Company’s strategic targets and goals. In
addition, the Board meets at least annually to discuss such issues and any suggestions to enhancecompliance are implemented by management. Finally and with respect the Implications of NBP,
the Company has contractual agreements with solely with European Economic Area regulated
entities and as such is not required to maintain a minimum additional capital buffer.

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2018 Pillar III Disclosures Report
7.8. IT Risk
IT risk could occur as a result of inadequate information technology and processing, or arise
from an inadequate IT strategy and policy or inadequate use of the Company’s information
technology. Specifically, policies have been implemented regarding back-up procedures,software maintenance, hardware maintenance, use of the internet and anti-virus procedures.
Materialization of this risk has been minimized to the lowest possible level.
7.9. Risk Reporting
The Company maintains a system in place to record any risk event incurred on a special form
duly completed by personnel of each department and is submitted to the Compliance officer andRisk manager when such event occur.

7.10. Liquidity Risk
Liquidity risk is defined as the risk when the maturity of assets and liabilities does not match. An
unmatched position potentially enhances profitability, but can also increase the risk of losses.
The Company has policies and procedures with the object of minimizing such losses.
7.11. Conduct Risk
Conduct risk is defined as the risk of an action, by an individual, financial institution or theindustry as a whole, which leads to customer detriment or, undermines market integrity. This canbring sanctions and negative publicity. Moreover, EBA has defined conduct risk as the current orprospective risk of losses to an institution arising from inappropriate supply of financial services
including cases of wilful or negligent misconduct. Consequently, conduct risk arises fromfailures of designated liquidity providers located in third countries associated with the Company.
Additionally, the Company is exposed to negative balances with its Liquidity Providers, in caseof fast-pacing volatile market, where the LP cannot close a position at the Company’s stop out
limit. Therefore, the Company may be exposed to conduct risk arising from inadequate
agreements with the Liquidity Providers and/or with the third parties that hold client’s funds.
As part of risk management policy and tools, the Company has procedures in place to diversify
its liquidity providers and monitor their financial position on an on-going basis. The financial
soundness of the liquidity providers is closely monitored and the company is ready to switch toalternative LPs, if necessary. Furthermore, the receivable/payable amounts with the LPs aremonitored on a daily basis. In particular, the Company examines its existing procedures andarrangements with respect to the products offered and services provided.
Further to the above, the agreement of MoUs between CySEC and FCA is expected to maintaininvestors’ protection via the appropriate communications channels between the two competentauthorities and as such may negative impact on the Company’s risk profile due to hard Brexit
Scenario is mitigated.
ESMA’s Final Product Intervention Measures on CFDs and Binary Options
The European Securities and Markets Authority (ESMA) on 23 January 2019 adopted Decision
2019/155, under Article 40 of Regulation (EU) No 600/20141 to restrict the marketing,
distribution or sale of contracts for differences (CFDs) to retail clients. The Decision renews andGBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

40

2018 Pillar III Disclosures Reportamends ESMA Decision (EU) 2018/7962 on the same terms as the previous renewal decision,
ESMA Decision (EU) 2018/16363.
Pursuant to article 40 of MiFIR for CFDs, product intervention measure include:
1. Leverage limits on the opening of a CFD by a retail client from 30:1 to 2:1, which vary
according to the volatility of the underlying: 30:1 for major currency pairs;
 20:1 for non-major currency pairs, gold and major indices; 10:1 for commodities other than gold and non - major equity indices; 5:1 for individual equities and other reference values; 2:1 for cryptocurrencies;
2. Margin close out rule on a per account basis,
3. Negative balance protection on a per account basis,
4. A restriction on the incentives offered to trade CFDs,
5. A firm specific risk warning.
The company has complied with all the above measures adopted by ESMA within the specified
deadline.
Safeguarding of clients assets
In accordance with paragraph 6(1) of the Directive DI087-01, a CIF must upon receiving any
client funds, promptly place those funds into one or more accounts with any of the following:
1. Central bank;
2. Credit institution as defined in article 2(1) of the Business of Credit Institutions Law;
3. Bank authorized in a third country;
4. Qualifying money market fund.
The Company has complied with the above required as per CySEC’s instructions.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Report

8. REMUNERATION POLICYThe Company has established a remuneration policy, which its purpose is to set out the
remuneration practices of the Company taking into consideration the salaries and benefits of thestaff, in accordance with the provisions of the Directive as well as the Circular 031 on
remuneration policies and practices, where these comply with specific principles in a way and to
the extent that is appropriate to the Company’s size, internal organization and the nature, scopeand complexity of its activities. Furthermore, the Company’s remuneration strategy is designed
to reward and motivate the people who are committed to maintaining a long term career with theCompany and performing their role in the interests of the Company.
The design of the Policy is approved by the people who effectively direct the business of theCompany, after taking advice from the compliance function, and implemented by appropriate
functions to promote effective corporate governance. The people who effectively direct thebusiness are responsible for the implementation of remuneration policies and practices and forpreventing and dealing with any relevant risks, that remuneration policies and practices cancreate. The Board discusses remuneration policy matters at least annually.
Furthermore, the Policy also benefits from the full support of senior management or, whereappropriate, the supervisory function, so that necessary steps can be taken to ensure that relevant
persons effectively comply with the conflicts of interest and conduct of business policies andprocedures.
Finally, the Policy adopts and maintains measures enabling them to effectively identify where
the relevant person fails to act in the best interest of the client and to take remedial action.
8.1. Remuneration System
The Company's remuneration system and policy is concerned with practices of the Company for
those categories of staff whose professional activities have a material impact on its risk profile,i.e. the Senior Management and members of the Board; the said practices are established toensure that the rewards are linked to the Company’s performance, to provide an incentive toachieve the key business aims and deliver an appropriate link between reward and performance
whilst ensuring base salary levels are not set at artificially low levels. The Company uses
remuneration as a significant method of attracting and retaining key employees whose talent cancontribute to the Company’s short and long term success.
The remuneration mechanisms employed are well known management and human resources
tools that take into account the following factors in order to determine the remuneration of eachstaff member:a) knowledge and skills,b) the adding value to the business,c) the demands (physical and mental) of the job,d) amount of training and/or experience needed,e) working conditions,f) the importance and the amount of responsibility,g) market dynamics such as the supply and demand for labour,h) financial viability of the Company,i) economic performance of the country in which the Company operates,

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2018 Pillar III Disclosures Reportj) employee’s personal goals and performance evaluation in relation to the objectives set up
at the beginning of the period,k) employee’s professional conduct with clients.
l) Staff’s skills, experience and performance, whilst supporting at the same time the longterm business objectives.
The Company’s remuneration system takes into account the highly competitive sector in which
the Company operates, and the considerable amount of resources the Company invests in eachmember of the staff. The remuneration includes all forms of benefits provided by the Company
to its staff and can be Financial or non-Financial remuneration.
It is noted that the Company has taken into account its size, internal organisation and the nature,
the scope and the complexity of its activities and it does not deem necessary the establishment ofa specific remuneration committee. Decisions on these matters are taken on a Board level while
the remuneration policy is periodically reviewed.
The remuneration varies for different positions/roles depending on each position’s actual
functional requirements, and it is set at levels which reflect the educational level, experience,accountability, and responsibility needed for a staff member to perform each position/role. The
remuneration is also set in comparison with standard market practices employed by the othermarket participants/ competitors. Furthermore, the employee’s personal goals and performance
evaluation in relation to the objectives set up at the beginning of the period and the employee’s
professional conduct with clients are taken into account in order to determine the remuneration.
The total remuneration of staff currently consists of a fixed and a variable component. On the
one hand, the Fixed Remuneration (FR) has purpose to attract and retain Company’s employees.
This fixed amount of remuneration includes salary, fixed pay allowance and other cash
allowances and all are determined based on the role and position of each employee, taking into
account the experience, seniority, education, responsibility, and market conditions. On the other
hand, the variable remuneration is a performance-based remuneration which motivated andrewards staff members based on their results in relation with the targets set in the beginning of
the year. This kind of remuneration is not guaranteed and the BoD has determined a maximum
percentage of variable remuneration relative to the fixed remuneration in order to ensure acompliant ratio between these two kinds of remuneration. Although, the maximum limit on
variable remuneration set at 100% of fixed salary, the limit could be set at 200% uponshareholders’ approval according to the Article 94 of Directive 2013/36/EU.
Furthermore there no remuneration is payable under deferral arrangements (with vested orunvested portions). Finally the Company did not pay any non-cash remuneration for the year
under review, since the Company does not have non-cash instrument, such as shares or otherequivalent non-cash instrument, in place.
The Company recognizes that its remuneration system have some features that increases the misselling risk. Therefore, the Company applies effective mitigation controls for each part of the
remuneration system.
8.2. Link between the pay and performance
The Company recognises the responsibility that the Staff has in driving its future success anddelivering value for the Company and that remuneration is a key component in motivating andcompensating its employees. Furthermore, the overall remuneration policy incorporates an

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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2018 Pillar III Disclosures Reportannual variable incentive compensation reflecting individual performance and overall
performance.
The individual performance is assessed during the annual appraisal process, which establishes
objectives for all staff covering both financial and non-financial factors, specific behavioral
competencies including compliance and risk management behaviors with regards to theCompany’s procedures.
Further to the above, the Company implements a performance appraisal method, which is basedon a set of Key Performance Indicators, developed for each business unit and its target is topromote the healthy competition amongst personnel, analysis of weak and strong sides of each
employee performance-based and give feedback to the staff member in order to motive them tobe improved. At the most of the times, the performance appraisal takes place in a multiyear
framework in order to ensure that the appraisal process assess employee’s long-term
performance. However, sometimes the performance appraisal is performed on medium andshort-term basis, and the performance indicators of this type of performance appraisal include
quantitative as well as qualitative criteria. The appraisal is being performed as follows:• The Company
implements a
performance appraisal
program based on key
performance indicatorsand targets.
• Each department setstargets for which theCompany functions,departments andindividuals are expectedto achieve over a
specific timeframe.

Performance Checks &Feedbacks• The Company's managers
provide support andfeedback to the staff during
the daily activities, time
periods decided and/or
during formal or informal
performance reviews.
• The aim is to assist the staff
to develop their skills andcompetencies.

SettingTargets• The Company at theend of each year
evaluates the overall
performance of the year
using quantitative andqualitative criteria.
• The performance
review determines thelevel of variable
remuneration to beawarded.

Annual Performance
Evaluation

8.3. Remuneration of Senior Management Personnel and Directors
The remuneration policy of the Company is intended to ensure that the Company will attract andretain the most qualified Senior Management Personnel and Directors. As stated in Section 8.2
the criteria used for determining the remuneration of the Company’s directors are segregated intoquantitative and the qualitative criteria.
The quantitative remuneration criteria mostly rely on numeric and financial data such as theCompany’s performance and the individual performance evaluation and ratings of each memberof the staff whose professional activities affect the risk profile of the firm. In addition to thequantitative criteria, the Company has put in place qualitative criteria which include compliance

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

44

2018 Pillar III Disclosures Reportwith regulatory requirements and internal procedures, fair treatment of clients and client
satisfaction.
Moreover, the remuneration of the Company’s non-executive directors is fixed and it is set at alevel that is market aligned and reflects the qualification and competencies required based on the
Company’s size and complexity, the responsibilities and the time that the non-executive directors
are expected to consume in order to serve the Company.
The remuneration of the senior management personnel of the Company, including Board areshown in the following tables:
Table 21 - Remuneration analysis split by Senior Management and key management
personnel
Senior Management
Key Management
Non-Executive
2018(Executive Directors)
personnel
Directors
260,453
184,235
12,000
Fixed reward
Variable reward
148,715
5,441
0
Total
409,168
189,676
12,000
Fixed and Variable
64%
97%
100%
Remuneration Ratio
Number of2
72
beneficiaries
Companies are required to disclose the number of natural persons that are remunerated €1mln or
more per financial year, in pay brackets of €1mln, including their job responsibilities, thebusiness area involved and the main elements of salary, bonus, long-term award and pension
contribution. Nevertheless, currently there are no natural persons at the Company that are
remunerated €1mln or more per financial year and as such the above disclosure is not applicableto the Company. No sign-on payments have been awarded during 2018, while no severance
payments were paid during the year. Furthermore, aggregate remuneration analyzed by businessarea is presented below:
Table 22 - Aggregate remuneration analysis by business area
Aggregate Remuneration€
Control Functions
478,626
Brokerage Department
50,409Dealing on Own Accounts Department
28,078Marketing Department
41,732
Total
598,846*Control functions include Compliance Department and the Deputy General Manager.

GBE brokers Ltd is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF license number 240/14.

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