- The Information We Collect
- How We Use Information
- Our Commitment To Data Security
- How To Access Or Correct Your Information
- How To Contact Us
This notice explains our online information practices and how any information is collected and used.
The Information We Collect
We collect information about you for two reasons: firstly, to provide you with secure access and secondly, to provide you with the best possible service.
This notice applies to all information collected or submitted on the Investment Manager’s website. The types of personal information collected are:
- First Name
- Business Type
- Email Address
- Telephone Number
- Fax Number
We may use technology to track the patterns of behaviour of visitors to our site. This can include the use of “cookies”, a text-only string of information that gets entered into the memory of your browser. This data is collected primarily for monitoring the usage and performance of this website.
The Way We Use Information
We use the information you provide about yourself when registering only to provide you with access to member information. We do not share any information with outside parties except to the extent necessary to provide you with member services.
We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.
We use non-identifying and aggregate information to build a profile of our users, so we can determine what additional information users may find useful, and any further design requirements that maybe needed.
Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.
If we intend to transfer your information outside the EEA (European Economic Area) we will always obtain your consent first.
Our Commitment To Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
The personal information which we hold will be held securely in accordance with our internal security policy.
We will never collect sensitive information about you without your explicit consent.
How You Can Access Or Correct Your Information
You can access all your personally identifiable information that we collect online and maintain by sending us an email. We use this procedure to safeguard your information.
The information that we hold will be accurate and up to date. You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.
To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.
How To Contact Us
Should you have other questions or concerns about these privacy policies, please email [email protected]
UK Stewardship Code
Conduct of Business Sourcebook rule 2.2.3R, requires the Investment Manager (“firm”) to include a disclosure on its website stating the nature of its commitment to the UK Stewardship Code (“the Code”) issued by the Financial Reporting Council. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy. The code sets out various principles relating to the level of engagement by investors with UK equity investors. Investors may either comply with the Code or choose not to comply with certain aspects of the Code in such case an explanation of non-compliance is required.
The Firm’s alternative investment strategy is Multi-Strategy. This means that the firm may invest in Global equities, including UK equities. Therefore the Code is applicable to some aspects of the firm‘s trading. Although the firm supports the Code’s objectives, Firm has decided not to commit to the principles of the code. The firm invests in various asset classes and jurisdictions on a global basis. The current policy of the firm in engaging with issuers and their management is determined on a global basis. Thereby the firm takes a consistent approach to engaging with the issuers and their management in all the jurisdictions the firm invests in. Hence, it is not deemed appropriate to comply with any voluntary codes of practice in any individual jurisdiction.
Remuneration Code Disclosure
The Investment Manager’s Board is responsible for setting The Investment Manager’s policy on remuneration. The Investment Manager’s Remuneration Policy will be reviewed, at least annually, by the Board to ensure that it remains consistent with the Remuneration Code Principles and the Manager’s objectives. The Board will use all information available to it in order to carry out its responsibilities under the Remuneration Code including information on risk and financial performance. In addition as part of The Investment Manager’s regulatory monitoring, this will include a review of the implementation of the policy by the Investment Manager.
This remuneration disclosure is made under the Basel Pillar 3 framework. Our non-remuneration Pillar 3 disclosures can be found in our annual report and accounts.
The purpose of the Remuneration Code is to ensure that firms establish, implement, and maintain remuneration policies, procedures and practices that are consistent with, and promote, sound and effective risk management.
The Remuneration Code applies to ’Remuneration Code Staff’ (’Code Staff’). This includes senior management, risk takers, staff engaged in control functions and any employee receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the firm’s risk profile.
Link between pay and performance
The LLP considers the Remuneration Code as set out by the FCA in policy statement (PS10/21), consultation paper (CP10/27) and within the FCA Handbook (BIPRU11.5). The LLP has adopted its own remuneration code policy consistent with its Tier 4 level and Code Staff have been informed of this policy. Remuneration is linked to both financial and non-financial performance and bonuses over a certain threshold are subject to a linked deferral scheme. Where remuneration is performance-related then in addition to the performance of the Investment Manager will also take into account the performance of the business unit concerned and the overall results of the firm. Performance assessment will not relate solely to financial criteria but will also include compliance with regulatory obligations and adherence to effective risk management. In keeping with the Investment Managers long-term objectives, the assessment of performance will take into account longer-term performance and payment of any such performance related bonuses may need to be spread over more than one year to take account of the firms business cycle.
Quantitative remuneration information
The Investment Manager is of the opinion that, in accordance with BIPRU 11.5.20R, it is not appropriate to disclose aggregate information on remuneration in respect of its Code Staff.