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Umbraila

Operate under our permissions, in your own name.

Your name on the door. Our permissions behind it.

 

What you get

Regulated activity under your own brand.

Registered with the FCA as our Appointed Representative.

Your promotions reviewed. Your activity supervised.

Fourteen firms have worked under our permissions. We hold it at four.

A route to your own authorisation, when you are ready.

Three ways to work under our permissions.

SEIS and EIS Funds
1 APPOINTED REPRESENTATIVE

An Appointed Representative is a firm that carries out regulated activity under the permissions of an authorised firm, known as its principal. Sapphire acts as principal. You trade under your own name and your own brand.

The appointment is registered with the FCA, so your firm appears on the Financial Services Register as our Appointed Representative. We assess you before appointment, supervise you afterwards, and answer to the regulator for the regulated activity you carry out.

It suits firms that want to move quickly, and firms that want to build a track record before applying for authorisation of their own. Zero Carbon Capital and Sustainable Ventures both work with us this way.

Measure Meter

“We feel confident that our regulatory and compliance needs are in good hands.”

Julia Groves, Sustainable Ventures

2 Investment Consultant

Not every arrangement needs an appointment. Some clients work alongside a Sapphire-managed fund as an investment consultant or company mentor, providing sourcing, research and analysis while the regulated decisions stay with us.

This is the lightest arrangement to put in place. There is no FCA notification and no appointment agreement, so it can be running in weeks rather than months.

It suits specialists who want to shape a fund's strategy without taking on regulatory obligations of their own. AI VentureFlows works this way, with Professor Andy Pardoe's team handling technical due diligence and deal sourcing, as well as mentoring the investee companies.

3 your own authorisation

Some clients use their time with us to build the track record, systems and governance that an FCA application requires.

We are not precious about it. Working under our permissions first gives you a live business and a documented history to point at when you apply, rather than a business plan and a promise.

Love Ventures obtained their own authorisation in 2024, as did EMV Capital. We count that as a success.

Measure Meter

“Sapphire has been the cornerstone of our investment operations." Mark Pearson, Fuel Ventures

property funds

Set up a property fund with Sapphire. Sapphire will collaborate with you in setting up the traditional "LP/GP" structure for a property fund. LPs are the limited partners who invest in the fund, and the GP is the General Partner.

In addition to this, Sapphire is authorised to manage & operate Exempt Property/ Exempt Property Unit Trust ("EPUT") structure. 

An indirect property investment means that the investor subscribes to shares in a company that, in turn, invests in properties. Through property funds, investors, therefore, have the opportunity to invest relatively small amounts in large-volume properties by way of professional fund companies. 

The responsibility sits with us.

Who Does What

The first question everyone asks is what we are actually responsible for. Here is the straight answer: you run your business, and the regulated activity sits under our permissions and our supervision.

1 Principal

We act as your principal, and your firm is registered with the FCA as our Appointed Representative on the Financial Services Register.

2 Supervision

We assess you before appointment, review your financial promotions before they go out, and monitor your regulated activity for as long as the appointment runs.

3 Liability

We answer to the FCA for the regulated activity you carry out under our permissions, which is the part most firms cannot carry on their own.

How it works

The second question everyone asks is how long an appointment takes.

 

A conversation. Fifteen minutes to understand your business, your people and what you want to do.

2 Due diligence. We assess your firm, your systems and the individuals who will carry out regulated activity.

3 Agreement. We put the appointed representative agreement in place and set the scope of what you can and cannot do.

4 FCA notification. We notify the regulator, which requires at least 30 days before the appointment can take effect.

5 Go live. Your firm appears on the Financial Services Register and you begin regulated activity under our permissions.

6 Ongoing. Annual reviews, promotion approvals and continuous monitoring for as long as the appointment runs.


Most appointments are in place within three months of the first conversation, when everything runs to plan.

Firms that have operated under our permissions.

Zero Carbon Capital became our Appointed Representative in 2019 and has completed 25 investments across an EIS fund and a GP/LP structure. Sustainable Ventures joined in 2025 and launched a SEIS and an EIS fund simultaneously. We have appointed fourteen firms over the years and deliberately hold that number at four today. We would rather supervise a small number of firms properly than a long list loosely.

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