Kintbury Capital LLP (’Kintbury Capital’ or the ‘Firm’) is authorised and regulated by the Financial Conduct Authority (the ‘FCA’). The Firm is a full scope Alternative Investment Fund Manager (‘AIFM’) and is categorised by the FCA, for capital purposes, as a Collective Portfolio Management Investment (“CPMI”) firm. The Firm is not required to prepare consolidated reporting for prudential purposes.
Materiality & Confidentiality
The Firm regards information as material in disclosures, if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions. The Firm regards information as proprietary/confidential if sharing that information with the public would undermine its competitive position.
Risk Management Objectives and Policies
The Firm’s Executive Committee are ultimately responsible for ensuring compliance with all regulatory requirements and comprehensively reviewing all risk issues at the Firm. The Firm’s CEO is responsible for Portfolio Risk Management oversight and for reporting to the Executive Committee. The Firm’s COO is responsible for systems and controls and for reporting of various operational and business risk management matters. The CEO and COO are functionally separated from the investment management team.
Kintbury Capital has clearly documented policies and procedures (these are contained in the Firm’s Compliance Policies and Procedures Manual), which are designed to minimise risks to the Firm and all staff are required to confirm that they have read and understood them.
You may provide us with personal information, such as your name, address, telephone number, social security number, assets and/or income information (i) in the Subscription Agreement and related documents, and (ii) in correspondence and conversations with Kintbury’s representatives.
We do not disclose any of this personal information to anyone, other than to our affiliates and except as permitted by law, such as to our attorneys, auditors, brokers and regulators and certain service providers, such as our administrator and a third party that hosts our customer relationship management system, but, in all such cases, only as necessary to facilitate the acceptance and management of your investment. Thus it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so, if compelled to do so by law, in connection with any government or self-regulatory organization request or investigation or if information is required to facilitate the partnership’s investments.
We seek to carefully safeguard your private information and, to that end, restrict access to nonpublic personal information about you to those employees and other persons who need to know the information to enable Kintbury to provide services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
Please note that calls made to, or from, the firm are recorded in order to comply with the Firm’s regulatory obligations.
FCA Complaint Procedure
You should contact us immediately if you are dissatisfied with any aspect of the AIF management services provided to you by Kintbury Capital LLP. Please write to John Aves at 33 Cork Street, London, W1S 3NQ; or [email protected]. We take every complaint seriously and your complaint will be handled in accordance with the relevant FCA rules, which may differ depending upon your status, although please note that it is Kintbury Capital LLP’s policy to aim to resolve every complaint fairly and in a timely manner. Kintbury Capital LLP has a written internal complaints handling policy, as required by the FCA Rules. You can obtain a copy of this on request, and in the event you should have cause for complaint about the AIF management services which Kintbury Capital LLP provides to you, a copy of the policy will be sent to you.
In the event we fail to resolve a complaint to your satisfaction, or if we fail to do so within eight weeks of receiving your complaint, you may also be entitled to refer your complaint to the Financial Ombudsman Service at Exchange Tower, Harbour Exchange Square, London, E14 9SR. Telephone: 0800 023 4 567 or at www.financial-ombudsman.org.uk.
UK Stewardship Code & SRD II
On 10 June 2019 the requirements of the Shareholder Rights Directive II (“SRD II”) came in to force. These rules continue along a similar path as the UK Stewardship Code ( the “Code”) which was updated by the Financial Reporting Council in 2020, in promoting common stewardship objectives between institutional investors and asset managers. Stewardship is the process by which Kintbury Capital LLP (“Kintbury”) protects and manages our clients’ investments by actively monitoring investee companies inclusive of liaising with company management or brokers on strategy, performance, governance and risk management.
Kintbury would like to be a signatory of the UK Stewardship Code, however the technicalities of holding our positions through CFDs or swaps means that we cannot vote on those positions. As such we cannot show evidence of meeting the Code’s requirements. Kintbury is therefore not a signatory of the Code. We do engage with company management on conduct related to the Code. Our aim is to provide good performance whilst keeping clients’ interests paramount and to continue to maintain the good reputation that Kintbury has established within the Hedge Fund industry. The principles of the Code form the basis for our SRD II approach also. The attached is an outline of how Kintbury applies the Code and SRD II in its engagement with UK equity issuers.
Pillar III Disclosures