Important legal and regulatory information
LGT Vestra LLP is authorised and regulated by the Financial Conduct Authority ("FCA") and is a member of the London Stock Exchange. Our FCA registration details are set out in the FCA Register under Firm Reference number 471048 (www.fca.org.uk). LGT Vestra LLP is registered in England and Wales (registered number OC329392) and our registered office is 14 Cornhill, London EC3V 3NR.
The information contained in this website should not be regarded as advice or an offer, invitation or solicitation to enter into any financial obligation, activity or promotion of any kind as defined by the Financial Services and Markets Act 2000. The provision of any investment services and products, whether or not mentioned in this website, may not always be suitable for an investor, and we recommend that any potential investor consults a financial adviser before entering into any investment contract. Investors should be aware that past performance is not an indication of future performance, the value of investments and the income derived from them may fluctuate and you may not receive back the amount you originally invested.
Our Advisory and Discretionary Portfolio Management services are restricted to providing you with specialist expertise and advice on the management of investment portfolios. As a firm we are able to source our investment solutions from the whole of market, and we are not tied to any products or providers. However, we will not consider your wider financial planning and pension requirements, unless you wish us to do so, when we will refer you to one of our wealth planners.
We are committed to protecting your privacy. Information we collect about you will be used to send you details of our products or services that you have requested. By using this website you agree to the use of your information as set out in this statement. We are registered, and process your data, in accordance with the Data Protection Act 1998 ("DPA"). You have certain rights under the DPA in respect of the information we hold about you. You are entitled to a copy of the information held about you. Your right of access can be exercised in accordance with the DPA and any access request may be subject to a fee.
You may use information on this website for your own personal reference only. All information and material on this website is copyrighted to LGT Vestra LLP.
The information on this website is provided in good faith and no representation, guarantee or warranty is made by us as to its accuracy. We shall not be liable for any loss or damage arising out of the use of or reliance on the information contained in our website. This does not affect our duty or liability to you which we have under the Financial Services and Markets Act 2000 or under the regulatory system. LGT Vestra accepts no liability for information contained within websites provided by third parties that may have links to or from our website.
We take care to maintain high standards of service. If we are aware of client concerns or unease, we give priority to resolving the matter as quickly as possible. To assist with this process we have prepared procedures to ensure that complaints are handled fairly and within reasonable timescales. The below is a summary of our complaint handling procedure. A copy of our full procedure is available on request.
How to make a complaint.
If you have a complaint about us and/or our services, you should direct this in the first instance to your investment manager. If you are uncomfortable doing so, your complaint can be directed to the Compliance Officer or the Chief Executive Officer. You can complain in writing, by telephone, by fax or via e-mail. Details can be found on the Contact us page.
What happens after I have complained?
Upon receipt of a complaint, a senior person who, where possible is independent of the case, will investigate the complaint. You will be given the name and contact details of the person dealing with your complaint. We will aim to resolve the complaint as quickly as possible. The person investigating your complaint will;
The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary. Your complaint will be investigated using our files together with reports from other parties if relevant. We may also write to you if further information is required.
We will keep you informed of the progress of the complaint investigation. After eight weeks, if a final response letter has not already been sent to you, you will receive a final response letter detailing our conclusions and resolution to the complaint. If we are not in a position to make a final response, we will give the reasons for the delay and will indicate when we expect to be able to provide a full response.
What if I am still not satisfied?
Within our final response letter to you, we will include details of the Financial Ombudsman Service (the “FOS”) whom, provided you are an eligible complainant, you have the right to right to refer a complaint if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. Further information about the FOS and whether you are an eligible complainant can be found at http://www.financial-ombudsman.org.uk or by calling 0800 023 4567.
Our remuneration policy is designed to ensure that we comply with the Remuneration Code and our compensation package is in line with the Firm’s strategy and objectives. The policy is designed to create a direct link between reward and performance, encourage a team ethic throughout the business, and promote effective risk management. For our full disclosure statement, please click here.
Pillar III Disclosures as at 30.04.2015
Pillar III Disclosures
Given the industry that the LLP operates in it is subject to a number of risks including but not exclusively credit risk, market risk, operational risk, liquidity risk, interest rate risk and securitisation risk. Each risk category has a greater or lesser impact on the LLP but risk management in its entirety is considered a key component to the functioning of the LLP and will continue to be a focus of management. Each risk category has been identified and analysed to understand the impact it has on the LLP and then steps have been put in place to make sure all risks are mitigated as far as is reasonably possible.
This is divided into counterparty risk and concentration risk but it is essentially the risk that losses will arise from counterparties and clients failing to make good their obligations. The main material risks result from amounts due from market and client counterparties however to mitigate these risks the LLP does the vast majority of trades on delivery versus payments i.e. free deliveries are not made. Also, the LLP will only use recognised stock exchanges or retail service providers (RSP). The vast majority of transactions are executed by the LLP as Agent but the LLP does have permission to act as Principal but this is limited to being a matched principal broker only. The concentration risk is mitigated by only using highly credit rated banks and institutions, and also exposure is spread over a number of counterparties.
Market Risk is the risk that a firm may incur losses under normal market conditions on a trading book position or portfolio. The firm’s activities in relation to MiFID financial instruments are limited to fulfilling or executing a client order and gaining entrance to a clearing and settlement system or recognised exchange. The LLP is exposed to a small amount of foreign exchange risk through its foreign currency activity. Foreign exchange positions are monitored daily and are held for operational reasons.
This is the risk facing the LLP from a failure of or inappropriate internal processes, people and/or systems. The LLP does not consider it possible to eliminate operational risk in its entirety but it aims to reduce the risk with due regard to the cost of achieving this relative to the potential impact. The LLP’s approach for monitoring, recording and mitigating operational risk is appropriate to its size and complexities. Exception reports, such as transactional errors, large movements in prices etc, are produced daily for review by the heads of departments and management information is produced monthly. The LLP has ensured that appropriately qualified people are employed to manage operational risk and to ensure that any exposure is kept to a minimum. In addition the LLP has professional indemnity insurance in place.
This is the risk that the LLP may face when trying to liquidate assets at fair value should unexpected cash flows result in a liquidity problem. The LLP is predominately equity funded. Regulatory capital ratios are monitored and maintained and cash flow analysis is conducted monthly to ensure that the LLP is able to meet future demands. The LLP does not trade on its own account and therefore there is no exposure to illiquid securities. When acting as agent on behalf of a client wishing to deal in illiquid stocks prior approval must be granted and additional internal controls are applied to ensure receipt of funds prior to the passing of stock certificates.
Interest Rate Risk
This is the risk arising from the effect of interest rate changes. The LLP has no exposure to interest rate risk as the clients are paid a rate that is linked to the Bank of England Base Rate and all interest rate fluctuations are born by the client. The LLP may make a margin on the interest rate however it is minimal compared to other income streams. This policy is set out in the client’s terms and conditions when joining the LLP.
The firm is not involved in the securitisation of assets. Should this situation change, LGT Vestra will undertake a risk review and implement the appropriate policies and procedures.
Capital adequacy an ICAAP
The LLP calculates its capital resources in accordance with the FCA rules and guidelines. An Internal Capital Adequacy Assessment Process (ICAAP) has been documented and lists all material risks together with the mitigations and controls in place to reduce their impact. The ICAAP document is reviewed once a year.
The regulatory capital resources of the LLP, calculated in accordance with FCA regulation, were last reported before year end as follows:
Common Equity Tier 1 Capital: £8.6m
Total Capital Ratio: 14.48%
LGT Vestra and the UK Stewardship Code
LGT Vestra complies with the UK Stewardship Code (the "Code") which was issued by the Financial Reporting Council in July 2010 and amended in September 2012 in respect of our activities for professional clients. "Stewardship" means the way in which we look after our clients’ best interests and manage their investments by actively monitoring the companies in which we invest on their behalf.
Although LGT Vestra primarily manages the assets of natural persons who are classified as retail investors, this policy statement focuses instead on our professional clients and summarises how we apply the seven principles of the Code.
1. Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
LGT Vestra manages client assets on a bespoke basis, seeking to maximise investment returns for each client. It is central to our investment process to consider each company’s ability to create, sustain and protect value. Therefore, we continually assess the performance of the management of companies in which we have invested on behalf of our clients and whether or not our client’s interests are being best served. Effective monitoring of investee companies is fundamental to fulfilling our responsibility of our clients. An investment is unlikely to be made if we have significant concerns about either management or matters of corporate governance.
From time to time where deemed appropriate, discretionary proxy voting decisions may be taken internally. This is done with our client’s best interests in mind at all times.
2. Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.
LGT Vestra maintains a robust policy on managing conflicts of interest which is designed to ensure its decisions are taken wholly in the interest of its clients. LGT Vestra aims to ensure that all potential and actual conflicts are identified, recorded, evaluated, managed and monitored.
A summary of LGT Vestra’s conflicts of interest policy is available to clients upon request.
3. Institutional investors should monitor their investee companies.
Comprehensive and continuous research and monitoring of investee companies is fundamental to LGT Vestra’s investment process as our investment strategy typically looks to long term investment rather than continual turnover of clients’ portfolio holdings. Monitoring typically occurs though financial reporting, general meetings, in connection with news and announcements and research LGT Vestra may conduct when looking into investment ideas or reviewing our approved lists of securities.
4. Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.
Where we have concerns about the performance or strategy of an investee company or where we have reason to believe that our client’s rights as shareholders are being compromised in any way, we will escalate our engagement with the investee company’s management and take any trading decisions accordingly.
5. Institutional investors should be willing to act collectively with other investors where appropriate.
LGT Vestra’s long term investment strategy and research process mean that it will rarely be necessary for such collective action to taken. However, if such collective action is deemed to be in the best interests of our clients, it will be carefully considered and may be taken accordingly.
6. Institutional investors should have a clear policy on voting and disclosure of voting activity.
Where we take voting decisions on behalf of our clients, we will always act in a manner consistent with our client’s best interests. Where necessary or appropriate, we endeavour to engage with investee companies. Records of our votes on behalf of particular clients are available to those clients upon request.
We do not lend stock or use proxy voting services.
7. Institutional investors should report periodically on their stewardship and voting activities.
We regularly report investment activity to our clients, and where it is considered relevant to the client, we will report details of our stewardship and voting activities.