The directors present their strategic report on ODIM (UK) LTD ("ODIMUK" or the "Company") for the year ended 31 March 2026.
The Company is authorised and regulated by the Financial Conduct Authority ("FCA") as a MiFID investment firm and is classified as a small and non-interconnected investment firm (an "SNI firm") for the purposes of the FCA’s Prudential sourcebook for MiFID Investment Firms ("MIFIDPRU"). The Company provides discretionary investment management services to institutions and family offices based in the UK and Europe. The Company's investment philosophy is centred on fundamental, bottom-up research and a long-term approach to value creation through investing in listed equities.
Results and performance
The Company has made a small profit for the current Fiscal Year. Currently, the management fee is the Company’s sole source of income. The Company's primary expense in the current year have been operational costs, professional service fee and compliance support fees.
Regulatory capital and liquidity
As an SNI MIFIDPRU investment firm which has not issued additional tier 1 instruments, the Company remains subject to MIFIDPRU 8.6 and accordingly discloses its remuneration policy and practices to the extent applicable to an SNI firm. Details of the Company’s unaudited disclosures required under MIFIDPRU 8, comprising the remuneration disclosures applicable to a small and non-interconnected investment firm, are available on the Company website.
Strategy
The Company is committed to meeting its clients’ investment performance expectations, focusing exclusively on Chinese equities, following an active bottom-up stock selection approach. Its investment proposition is simple and focused. ODIMUK’s bottom-up research approach aims to identify the best long-term investment opportunities and to provide a concentrated, diversified portfolio to deliver attractive risk-adjusted returns.
The Company will continue to focus on products delivering long-term risk adjusted investment performance and on providing high quality customer service to its clients. The Company's investment solutions are specifically designed to meet our clients’ needs.
Our priorities for the coming year include continued growth in Assets under Management (“AUM”) through deepening relationships with existing clients and attracting new mandates. Risk-adjusted Investment performance remains a central focus, as does maintaining the highest standards of client service and regulatory compliance. The macroeconomic environment remains uncertain; however, the Company is well positioned with a strong balance sheet and a conservative business model.
Principal risks and uncertainties
The Board is responsible for identifying, assessing and managing the principal risks and uncertainties facing the Company, and for maintaining a system of internal control that is proportionate to the nature, scale and complexity of the business. These risks are assessed formally through the ICARA process and are kept under review by the Board throughout the year. The principal risks identified by the Directors are set out below.
Business/Strategic Risk: Risk of reliance on specific clients, investment products, or revenue streams, or key personnel departures. The Board seeks to mitigate this risk through client diversification over time, remuneration and retention arrangements, and succession planning.
Regulatory and Compliance Risk: The Company operates in a highly regulated environment. The Board maintains a compliance monitoring programme and receives regular reporting from the compliance function.
Operational and Outsource Risk: Arising from systems, people and operational processes, including outsourcing parties and cyber risks. The Board manages this risk through due diligence at appointment, written agreements, defined service levels and ongoing oversight of material outsourcing arrangements, information security controls and business continuity arrangements, and keeps the Company’s operational resilience under review.
Market Risk: Primarily related to exposure from FX movements on fee income.
Credit Risk: Limited exposure arising from counterparties and custodians.
Statement by the Directors regarding the performance of their statutory duties in accordance with Section 172 Companies Act 2006
In accordance with the Companies Act 2006 (the "Act"), the Directors of the Company are required to give an annual statement which describes how the Directors have taken into consideration the matters set out in section 172 (1) of the Act when discharging their duty under that section.
Section 172 of the Act requires a Director of a company to act in the way they consider, in good faith, would be most likely to promote the success of the company for the benefit of its members as a whole. In doing this, section 172 requires a Director to have regard, amongst other matters, to
the likely consequences of any decision in the long term.
the interests of the company's employees.
the need to foster the company's business relationships with suppliers, clients and others.
the impact of the company's operations on the community and the environment.
the desirability of the company maintaining a reputation for high standards of business conduct; and
the need to act fairly between different members of the company.
The Directors consider the matters set out above in their decision-making process, through the Company's business strategy, culture, governance framework, management information flows and stakeholder engagement processes. For each matter that comes before the Directors, stakeholders who may be affected are identified and the Directors consider the interest of all such stakeholders in coming to decisions.
Long-term decision making
The Company’s strategy is focused on delivering long-term, risk-adjusted returns to clients while maintaining a robust and sustainable business model. In setting this strategy, the Board considers potential impacts on clients, employees, and the wider market. During the year, the Board supported enhancements to client reporting, investment governance, and operational resilience, all with a view to long-term value creation.
Clients and business relationships
The Board recognises that the Company’s success is dependent on strong and trusted relationships with its clients. The Company is committed to delivering investment excellence with the highest standards of care and integrity. Directors place clients’ interests at the heart of key decision-making and ensure that business practices align with these priorities. The Company also maintains a strong focus on operational resilience, compliance, and information security to safeguard clients’ interests.
Environment and community
As an office-based investment management firm, the Company’s direct environmental impact is limited. Nevertheless, the Board seeks to minimise the Company’s environmental footprint and supports responsible practices in its operations. Furthermore, the Company encourages the integration of ESG considerations within its investment process, where appropriate.
High standards of business conduct
The Company’s reputation for integrity and high standards of conduct is fundamental to its success. The Board promotes a strong compliance culture and oversees robust governance practices. The Company maintains open and constructive relationships with the Financial Conduct Authority and adheres to relevant regulations, including the Consumer Duty and other applicable regulatory standards.
Fairness between members
The Board is committed to treating all members of the Company fairly and with due regard to their interests, both in day-to-day decisions and in the execution of the Company’s broader strategic objectives.
The Directors recognise that the long-term success of the business is dependent on aligning our activities with the interests of its key stakeholders. The Directors believe that corporate citizenship is a critical link between integrity and performance, how the Company does the right things, the right way to deliver value to its clients, employees, and its communities. As an organisation, citizenship is embedded in the Company's corporate values and is an important element of how it achieves success in working with all its key stakeholders. Our core values reflect what is most important to us as a company. They are the ideas that guide us in how we do business, how we treat our clients, and how we work with each other.
Forward-looking statements
This Strategic Report contains certain forward-looking statements regarding the Company’s markets, strategy and intentions, including statements as to the Investment Manager’s outlook for Chinese equity markets and its expected areas of portfolio focus. Such statements reflect the Directors’ views and expectations as at the date of approval of this report and are subject to risks, uncertainties and assumptions, including those described under Principal risks and uncertainties above. Actual outcomes may differ materially from those expressed or implied. Nothing in this report constitutes a forecast or a guarantee of future performance, and past performance is not a reliable indicator of future results. The Directors undertake no obligation to update any forward-looking statement, save as required by law or regulation.
On behalf of the board
The directors present their annual report and financial statements for the year ended 31 March 2026.
The results for the year are set out on page 10.
No ordinary dividends were paid. The directors do not recommend payment of a final dividend.
The directors who held office during the year and up to the date of signature of the financial statements were as follows:
As the company has not consumed more than 40,000 kWh of energy in this reporting period, it qualifies as a low energy user under these regulations and is not required to report on its emissions, energy consumption or energy efficiency activities.
Company law requires the directors to prepare financial statements for each financial year. Under that law the directors have elected to prepare the financial statements in accordance with United Kingdom Generally Accepted Accounting Practice (United Kingdom Accounting Standards and applicable law). Under company law, the directors must not approve the financial statements unless they are satisfied that they give a true and fair view of the state of affairs of the company and of the profit or loss of the company for that period.
In preparing these financial statements, the directors are required to:
select suitable accounting policies and then apply them consistently;
make judgements and accounting estimates that are reasonable and prudent;
state whether applicable UK Accounting Standards have been followed, subject to any material departures disclosed and explained in the financial statements; and
prepare the financial statements on the going concern basis unless it is inappropriate to presume that the company will continue in business.
The directors are responsible for keeping adequate accounting records that are sufficient to show and explain the company’s transactions and disclose with reasonable accuracy at any time the financial position of the company and enable them to ensure that the financial statements comply with the Companies Act 2006. They are also responsible for safeguarding the assets of the company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.
We have audited the financial statements of ODIM (UK) LTD (the 'company') for the year ended 31 March 2026 which comprise the Profit and Loss Account, the Balance Sheet, the Statement of Changes in Equity, the Statement of Cash Flows and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).
Basis for opinion
Conclusions relating to going concern
In auditing the financial statements, we have concluded that the directors' use of the going concern basis of accounting in the preparation of the financial statements is appropriate.
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the company's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this report.
Other information
Opinions on other matters prescribed by the Companies Act 2006
In our opinion, based on the work undertaken in the course of our audit:
the information given in the Strategic Report and the Directors' Report for the financial year for which the financial statements are prepared is consistent with the financial statements; and
the Strategic Report and the Directors' Report have been prepared in accordance with applicable legal requirements.
Explanation as to what extent the audit was considered capable of detecting irregularities, including fraud
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our procedures are capable of detecting irregularities, including fraud is detailed below.
The objectives of our audit in respect of fraud, are; to identify and assess the risks of material misstatement of the financial statements due to fraud; to obtain sufficient appropriate audit evidence regarding the assessed risks of material misstatement due to fraud, through designing and implementing appropriate responses to those assessed risks; and to respond appropriately to instances of fraud or suspected fraud identified during the audit. However, the primary responsibility for the prevention and detection of fraud rests with both management and those charged with governance of the company.
Our approach was as follows:
We obtained an understanding of the legal and regulatory requirements applicable to the company and considered that the most significant are the Companies Act 2006, UK financial reporting standards as issued by the Financial Reporting Council, and UK taxation legislation.
We obtained an understanding of how the company complies with these requirements by discussions with management and those charged with governance.
We assessed the risk of material misstatement of the financial statements, including the risk of material misstatement due to fraud and how it might occur, by holding discussions with management and those charged with governance.
We inquired of management and those charged with governance as to any known instances of non-compliance or suspected non-compliance with laws and regulations.
Based on this understanding, we designed specific appropriate audit procedures to identify instances of non-compliance with laws and regulations. This included making enquiries of management and those charged with governance and obtaining additional corroborative evidence as required.
There are inherent limitations in the audit procedures described above. We are less likely to become aware of instances of non-compliance with laws and regulations that are not closely related to events and transactions reflected in the financial statements. Also, the risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment by, for example, forgery or intentional misrepresentations, or through collusion.
Use of our report
This report is made solely to the company's members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken so that we might state to the company's members those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the company and the company's members as a body, for our audit work, for this report, or for the opinions we have formed.
ODIM (UK) LTD is a private company limited by shares incorporated in Scotland. The registered office is 272 Bath Street, Glasgow, Scotland, G2 4JR.
The financial statements are prepared in sterling, which is the functional currency of the company. Monetary amounts in these financial statements are rounded to the nearest £.
Basic financial assets, which include debtors and cash and bank balances, are initially measured at transaction price including transaction costs and are subsequently carried at amortised cost using the effective interest method unless the arrangement constitutes a financing transaction, where the transaction is measured at the present value of the future receipts discounted at a market rate of interest. Financial assets classified as receivable within one year are not amortised.
Financial assets are derecognised only when the contractual rights to the cash flows from the asset expire or are settled, or when the company transfers the financial asset and substantially all the risks and rewards of ownership to another entity, or if some significant risks and rewards of ownership are retained but control of the asset has transferred to another party that is able to sell the asset in its entirety to an unrelated third party.
Financial liabilities and equity instruments are classified according to the substance of the contractual arrangements entered into. An equity instrument is any contract that evidences a residual interest in the assets of the company after deducting all of its liabilities.
Basic financial liabilities, including creditors, bank loans, loans from fellow group companies and preference shares that are classified as debt, are initially recognised at transaction price unless the arrangement constitutes a financing transaction, where the debt instrument is measured at the present value of the future payments discounted at a market rate of interest. Financial liabilities classified as payable within one year are not amortised.
Debt instruments are subsequently carried at amortised cost, using the effective interest rate method.
Trade creditors are obligations to pay for goods or services that have been acquired in the ordinary course of business from suppliers. Amounts payable are classified as current liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities. Trade creditors are recognised initially at transaction price and subsequently measured at amortised cost using the effective interest method.
Financial liabilities are derecognised when the company’s contractual obligations expire or are discharged or cancelled.
Equity instruments issued by the company are recorded at the proceeds received, net of transaction costs. Dividends payable on equity instruments are recognised as liabilities once they are no longer at the discretion of the company.
The carrying amount of deferred tax assets is reviewed at each reporting end date and reduced to the extent that it is no longer probable that sufficient taxable profits will be available to allow all or part of the asset to be recovered. Deferred tax is calculated at the tax rates that are expected to apply in the period when the liability is settled or the asset is realised. Deferred tax is charged or credited in the profit and loss account, except when it relates to items charged or credited directly to equity, in which case the deferred tax is also dealt with in equity. Deferred tax assets and liabilities are offset when the company has a legally enforceable right to offset current tax assets and liabilities and the deferred tax assets and liabilities relate to taxes levied by the same tax authority.
In the application of the company’s accounting policies, the directors are required to make judgements, estimates and assumptions about the carrying amount of assets and liabilities that are not readily apparent from other sources. The estimates and associated assumptions are based on historical experience and other factors that are considered to be relevant. Actual results may differ from these estimates.
The estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the period in which the estimate is revised where the revision affects only that period, or in the period of the revision and future periods where the revision affects both current and future periods.
The directors consider there to be no significant judgements or key sources of estimation uncertainty in the financial statements.
The average monthly number of persons (including directors) employed by the company during the year was:
Their aggregate remuneration comprised:
The actual charge for the year can be reconciled to the expected charge/(credit) for the year based on the profit or loss and the standard rate of tax as follows:
The company has losses of £52,723 (2025: £77,037) to set against future taxable profits. A deferred tax asset has not been recognised in the Statement of Financial Position due to uncertainty of the timing of future taxable profits.
Included within other creditors there is a balance of £31,800 (2025: other creditors amounts falling due after more than one year £30,900) relating to an unsecured loan payable to Shifeng Ke, the 100% director and shareholder of ODIM (UK) Ltd.
Interest on the loan is payable at 3% per annum; full repayment of the principal and interest is due on 30 June 2026. £900 (2025: £900) relating to the interest expense on this loan has been included within interest payable.
Included within other creditors is £9,276 (2025: £1,341) due to key management personnel in respect of business expenses incurred on behalf of the company. The balance is unsecured and interest free.
During the year, the company made purchases of £134,000 (2025: £8,000) from Open Door Investment Management Limited (a company with a common director) who provide consultancy services. At the year end the amount owed was £142,000 (2025: £8,000)