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  • Terms of use and
    legal notice
  • Privacy notice for
    website visitors
  • Privacy notice for client
    and prospective clients
  • Special legal
    information

Last updated October 2018

Please read these terms carefully

Terms of use

Before using this website, you should read the following important information carefully. This information (together with the other documents referred to in it) (collectively these “terms”) governs your use of this website. By using this website, you indicate that you accept these terms of use and that you agree to be bound by them. If you do not agree, please do not use our website.

Changes to these terms

The content of this website, including these terms, may be changed by us without notice, and you should check this page from time to time for any updated terms. 

We may also need to make changes to the customer portal on our website to reflect changes in law or best practice or to deal with additional features which we introduce. We will aim to notify you of any changes and seek your consent when you attempt your first login to the customer portal after such changes have been made. If you do not agree to the changes to the customer portal, you will not be able to login or access the customer portal.

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. For more information about the regulatory framework within which LGT Vestra operates see the Special Legal Information.

Other terms

These terms of use refers to the following terms which also apply to your use of the site:

Our Privacy Notice for Website Visitors which applies to your use of our site, sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our site, you consent to such processing and you confirm that all data provided by you is accurate. It also sets out information about the cookies on our site.

Our LGT Vestra Online Service Terms which sets out the permitted uses and prohibited uses of our site’s customer portal. When using our site’s customer portal, you must comply with the terms of our LGT Vestra Online Service Terms. If you fail to do so, we may take such action against you as we deem appropriate which may include the immediate, temporary or permanent withdrawal of your right to use our site’s customer portal.

Suspension or withdrawal of our site

Access to our site is permitted on a temporary basis. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them..

Accessing our site

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at dpo@lgtvestra.com.

Information on our site

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.

The content on our site is provided without any representations, guarantees, conditions or warranties as to its accuracy or completeness or as to whether it is up to date.

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

The intellectual property rights in all elements of our customer portal, including software, databases, data and other information viewed, used or accessed through the customer portal, shall remain vested in us and/or our licensors, and you will not acquire or retain any proprietary right, interest or title in such elements.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of material on our site must always be acknowledged.

You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Our responsibility for loss or damage suffered by you

We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.

Our limitation of liability under these terms 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.

Please also see the LGT Vestra terms and conditions which set out our limitation of liability for any services we may provide to you.

If you are a business user of our site:  

We exclude all conditions, warranties, representations or other terms that may apply to our site or any content on it or to our customer portal (whether express or implied) including but not limited to, to the maximum extent permitted by law, any implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

  • use of, or inability to use, our site; or
  • use of or reliance on any content displayed on our site

In particular, we will not be liable for:

  • loss of profits, sales, business, or revenue;
  • business interruption;
  • loss of anticipated savings;
  • loss of business opportunity, goodwill or reputation; or
  • any indirect or consequential loss or damage.

If you are a consumer user:

Please note that we only provide our site to you for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

Viruses, hacking and other offences

We do not guarantee that our site will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer program and platform to access our site. You should use your own virus protection software.

You acknowledge that you are responsible for keeping any device on which you access our site secure, and that you must close access to our site when you are not using it.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site and you must not attack our site via a denial-of-service attack or a distributed denial-of service attack. You may commit a criminal offence under the Computer Misuse Act 1990 if you do so.

We will report any such offence to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such an offence, your right to use our site will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any site linked to it.

Linking to our site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it in any way whatsoever, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

Jurisdiction and applicable law

If you are a consumer, please note that these terms of use, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Entire agreement

These terms of use and any document expressly referred to in them constitute the whole agreement between us and supersede all previous discussions, correspondence, negotiations, previous arrangement, understanding or agreement between us relating to the use of our site.

 

Valid from September 2018

Data privacy notice regarding the use of LGT Vestra’s website and client portal

Our approach

This Privacy Notice describes what happens to the personal information which you supply to LGT Vestra LLP and LGT Vestra US Ltd (referred to as “LGT Vestra”, “our” or “we”) in connection with the use of LGT Vestra's website and client portal. LGT Vestra LLP and LGT Vestra US Ltd are registered with the Information Commissioner's Office (ICO) in the United Kingdom as a data controller.

The registered address and phone number of LGT Vestra LLP and LGT Vestra US Ltd are: 14 Cornhill, London EC3V 3NR, +44 203 207 8000.

LGT Vestra reserves the right to change this Privacy Notice from time to time and revised terms will be posted on our website.

If you have any questions about this Privacy Notice or the information we collect and use about you, please contact the Data Protection Officer:

Paul Martin
LGT Vestra LLP
14 Cornhill
London
EC3V 3NR

Email: dpo@lgtvestra.com

Phone: +44 203 207 8000

What information do we hold about you and how do we collect it?

LGT Vestra collects, uses and stores personal information you have provided to us when using our website or client portal. Personal information we may process may include but is not limited to:

 

  • information on your electronic communication with LGT Vestra or other technical data (e.g. records of accessing our website);
  • your name, your email address and other contact details where you have provided this information to us; and
  • when using the client portal, your national insurance number, date of birth, and answers to security questions such as your mother's maiden name or first school attended.

If you establish contact with us by e-mail or by using the form provided on the website, the data provided is processed in order to handle the inquiry, to establish contact and for technical administration purposes.

We collect, process and use personal data collected on our website and client portal in order to help us improve our website, to align our business processes to our clients and to provide efficient access to portfolio information.

We do not use any personal information collected from the use of our website or client portal to engage in automated decision-making or profiling.

 

How do we use and upon what legal grounds do we process your personal information?

Your data is processed for the purposes of a legitimate interest:

 

  • pursued by us, in processing your request, achieving the highest degree of stability and functionality for our website, effectively designing our website, preparing statistical analyses of visitor behavior for optimisation and marketing purposes, or
  • pursued by a third-party provider (e.g. Google, Youtube) in incorporating personalised advertising based on visitors’ surfing behavior or on market research. The third-party providers have undertaken to observe the Privacy Shield Framework between the EU and the US regarding the collection, use and storage of personal data from EU member states.

Where necessary, your data can also be processed for the initiation of business contact or on the basis of your explicit consent.

How do we use cookies, web analysis and targeting?

Our website and client portal uses cookies. Cookies are small pieces of data sent by our web server and stored on your computer to enable us to recognise your computer and login and to provide a personalised experience each time you visit the site. Cookies remain stored on your computer until you delete them. Cookies themselves do not identify the individual, just the computer used. Our cookies are used to keep track of your online session; they are maintained throughout multiple sessions on the site. Our cookies do not collect any personally identifiable or confidential information such as passwords or account numbers. Most browsers are initially set to accept cookies, but you can alter this if you prefer. However, if you disable session cookies some parts of our website and client portal will not function as designed.

When you use the LGT Vestra website, access data (e.g. log files, IP address, date and time of access, name of the requested file, access status, page from which access is gained, top-level domain, web browser used, operating system used) is stored. We use this data for statistical purposes, technical analysis, to improve the server infrastructure, to ascertain the frequency of access, and to draw conclusions about improving the user-friendliness and functionality of the website.

We use cookies for website analysis, i.e. cookies that give us statistics about the total number of visitors, the pages that were visited, etc. As output we receive statistical analyses which we use to make sure that our website design meets visitors’ needs. This does not enable our service provider to identify you or to come to any conclusions regarding your identity.

For this purpose, we use the following third-party service providers on our website:

1. Google Analytics provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google")

The cookies used for analysis by Google Analytics do not contain any personal data. Your IP address is abbreviated directly on your computer. Your IP address is sent to Google Analytics in this anonymized form. Google Analytics will not link your IP address to other information held by Google Analytics and will only pass on data to third parties where this is provided for by law.

You can refuse permission for Google Analytics cookies to be used in future at any time by clicking on this opt-out link:

Please also read the information on the services and data privacy policy of Google Analytics at: https://support.google.com/analytics/answer/6004245?hl=en

2. Webtrends Analytics provided by Webtrends Inc., 851 SW 6th Ave. Suite 1600, Portland, OR 97204, USA (“Webtrends”)

The cookies used for analysis by Webtrends do not contain any personal data. Your IP address is abbreviated directly on your computer. Your IP address is sent to Webtrends in this anonymised form. Webtrends will not link your IP address to other information held by Webtrends and will only pass data on to third parties where this is provided for by law.

You can refuse permission for Webtrends cookies to be used in future at any time by clicking on the following opt-out link:

Please also read the information on the services and data privacy policy of Webtrends at: https://www.webtrends.com/terms-policies/privacy/privacy-statement/

When visiting some of our sites, providers of targeting services can store temporary cookies on your computer's hard disk or your mobile device, which will be automatically deleted after a specified period. These cookies contain computer-generated alphanumeric identifiers that do not permit any conclusions about your person or the IP address of your computer. You can prevent the use of targeting cookies by changing your browser settings so that no cookies are stored.

The above cookies are used to collect anonymised data that make it possible to analyse the use of our website.

To enable you to share the contents of our website via social media channels (Facebook, Twitter, etc.), a cookie has to be installed on your computer. Once this function has been activated, the relevant third-party provider is responsible for the further processing of the data.

Our website can also be used without cookies. However, the functionality of our website may be limited if you do not allow or disable cookies. If you do not wish any cookies, you can change your browser settings to notify you when a cookie should be set, which will allow you to approve cookies on an ad hoc basis only. You can also set your web browser to automatically disable cookies. Please note that most browsers offer different options for protecting your privacy. As a rule, instructions for managing cookies in your browser are available in the browser's Help function or in the instruction manual for your computer. Instructions for disabling cookies in the most common browsers can be found at the following links:

Incorporation of third-party services and contents and use of plugins

Third-party contents and services can be incorporated into our website (known as externally embedded components or plugins/widgets). These always require that the third-party providers of these contents use the visitor’s IP address, as no contents can be sent to the visitor's browser without the IP address.

If you click on the icon or logo of the third-party, such as Twitter or LinkedIn, you consent to communication with the relevant platform and the transmission of information to the third-party provider in question.

This does not apply to the following services, where data is transmitted to the relevant third-party provider without you having to click on the relevant symbol:

1. Youtube videos provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”)

If you click on pages incorporating YouTube videos, a connection is established to Google's “DoubleClick” network.

As soon as you go to a site incorporating a Youtube video, cookies are activated to collect information on user behavior. Google uses these data to create and analyze user profiles. If you have a Google account and are logged in to this account, your data are also linked to your Google account. You have the right to object against the creation of user profiles, which you can exercise towards Google.

Please also read the information on the services and data privacy policy of Google at: https://policies.google.com/privacy?hl=en-GB&gl=de

2. Google Maps provided by Google Maps (API) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) to show our locations and to make it easier to find your way to us

If you click on pages incorporating maps provided by Google Maps, data (e.g. IP address) are transmitted to and stored on Google's systems in the US. Google uses these data to create and analyse user profiles. If you have a Google account and are logged in to this account, your data are also linked to your Google account. You have the right to object against the creation of user profiles, which you can exercise towards Google.

You can prevent the future transmission of your data when you use Google Maps by disabling the web service of Google Maps in your browser.

Please also read the information on the services and data privacy policy of Google and Google Maps at:

We have no control over the scope of the data that are collected by the relevant third-party providers with the help of their plugins or your use of websites that incorporate certain services offered by third-party providers. If you use the services of third-party providers, the relevant third-party provider is responsible for the further processing of the data.

How do we keep your personal information secure?

LGT Vestra takes all reasonable steps to ensure that any personal data that you provide to us is kept secure, and we have put in place measures to guard against unauthorised use of your personal information or accidental loss, destruction or damage. Because of the nature of the Internet, we cannot guarantee the security of your data transmitted to the website or via email, and any inward transmission of data is carried out at your own risk.

How long do we retain your personal information?

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Notice (unless longer retention is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

What are your legal rights under data protection laws?

Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information.  Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

  • Right to be informed. You have the right to be informed about how we collect and use your personal information;
  • Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you. If you like would to obtain a copy of this information please email us at info@lgtvestra.com. You may be required to submit a proof of your identity and a fee.
  • Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. 
  • Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time if that is the legal basis upon which we are processing your information. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
  • Right to restrict processing. You may, as permitted by law, request that we restrict or limit processing your personal information.
  • Right to erasure. You may request that we erase your personal information, unless there is a lawful reason for us not doing so.
  • Right to data portability. You have the right to request a copy of your information in a structured, commonly used and machine-readable format; and
  • Right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the ICO directly using the contact details below.

You also have a right to object to the processing of your data for the purposes for direct marketing, and we must comply with your request. You may also object to the processing of your information where we are processing your data for our legitimate business interest or for statistical or research purposes, although we may have compelling legitimate grounds to continue processing your data.

To contact the Information Commissioner’s Office for more information on your rights or other question you may have, please visit the ICO website or contact them via the following:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 0303 123 1113

Linked websites

Please note that any websites that may be linked to our website are subject to their own privacy policy. LGT Group's data protection notice can be found on their website (www.lgt.com), and we encourage you to read that notice as well to understand how LGT may process your data.

 

Privacy notice

Our approach

This Privacy Notice describes what happens to the personal information which you supply to LGT Vestra LLP and LGT Vestra US Ltd (referred to as “LGT Vestra”, “our” or “we”) in connection with the services LGT Vestra provides to you. LGT Vestra LLP and LGT Vestra US Ltd are registered with the Information Commissioner's Office (ICO) in the United Kingdom as a data controller.

The registered address and phone number of LGT Vestra LLP and LGT Vestra US Ltd are: 14 Cornhill, London EC3V 3NR, +44 203 207 8000.

LGT Vestra reserves the right to change this Privacy Notice from time to time and revised terms will be posted on our website.

If you have any questions about this Privacy Notice or the information we collect and use about you, please contact the Data Protection Officer.

Paul Martin 

14 Cornhill

London, EC3V 3NR

dpo@lgtvestra.com

+44 203 207 8000

What information do we hold about you and how do we collect it?

LGT Vestra collects, uses and stores personal information you have provided to us or personal information which is necessary for us to provide the services you have requested.

Personal information may include but is not limited to:

 

  • personal details (e.g. name, date of birth, nationality, marital or civil partnership status, country of residence, dependents);
  • address and contact details (e.g. physical address, telephone number, e-mail address);
  • identification data (e.g. passport, National Insurance Number or other identity card numbers) and authentication data (e.g. specimen signature);
  • information on spouses, partners and other family details, or on authorised signatories and representatives;
  • information about financial matters (e.g. the assets in your portfolio, account numbers, origin of assets, your bank details);
  • professional and personal background information (e.g. employment, professional activity, preferences);
  • information on electronic communication with LGT Vestra or other technical data (e.g. records of accessing our website);
  • image and audio data (e.g. CCTV or voice recordings); and
  • where necessary to provide certain services to you and with your consent, we may collect and process sensitive personal information which may include information about your physical or mental health.

We collect information through a variety of sources, including:

 

  • the account agreements you complete for our services;
  • conversations and correspondence with us, including recorded telephone lines;
  • anti-money laundering verification services;
  • public registers and agencies;
  • our online services and website; and
  • agents, brokers, dealers, introducers and other intermediaries.

How do we use and upon what legal grounds do we process your personal information?

We use your personal information, and may share your personal information with other third parties acting on our behalf, for several purposes. These purposes and the legal basis upon which we process your personal information are set out below.

 

  • We may process your personal information because it is necessary in connection with the provision of our services. This includes personal information we require to fulfil a request for our products or services prior to entering into a contract with you and for the performance of that contract.
  • We may process your personal information for our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your personal information:

to send you market commentary and information about your investments, products and services we believe are relevant and of interest to you;

to respond to any enquiry or complaint you may make to us;

for market research purposes, where we may contact you to ask for your feedback;

to prevent abuses of our website, for example, by requesting verification information in order to reset your account password (if required);

to ensure the security of our premises;

to maintain compliance with our internal policies and procedures; or

for our own administrative purposes, including training our staff and conducting internal audits.

 

  • We may process your personal information in order to comply with our regulatory and legal obligations such as to prevent money laundering, fraud, market abuse or other criminal activity, to comply with tax laws or to meet our regulatory reporting obligations.
  • We may process your information because you have given us your consent to do so. For example:

where you have provided us with sensitive personal information necessary for us to provide you with the services you have requested, such as information about your health;

where you have agreed we can contact you with information about the products and services we can offer to you; or 

where you have provided information to us via our website.

If at any time after you have consented to us using your personal information for marketing purposes and you wish us to stop using your information for these purposes, please email us at info@lgtvestra.com.

Is automated decision-making, including profiling, carried out?

As a basic principle, our decisions are not based on automated processing of personal data. There are areas of the business where personal data are processed at least partly by automated means. The objective of this is to evaluate certain aspects of the relationship where we are obligated to do so by legal and regulatory requirements (e.g. prevention of money laundering) and for the purposes of risk management.

Do we share your personal information with other third parties?

There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third parties. For example, we may pass on your data to:

 

  • our subsidiaries, branches or associated offices within the LGT Group;
  • government institutions, regulators, authorities and courts (when legally obliged to do so) such as the Financial Conduct Authority (FCA), the ICO or the HM Revenue & Customs (HMRC);
  • providers of investments we recommend; and
  • service providers who are processing the data on behalf of LGT Vestra under contractual obligations of confidentiality, such as IT service providers, auditors, printing services, professional advisers and fraud prevention organisations.

We will only transfer your personal information to countries outside the European Union (EU) or European Economic Area (EEA) (so-called third countries):

 

  • where it is necessary for the implementation of pre-contractual measures or the performance of a contract;
  • where it is necessary for the provision of services or processing of orders (e.g. execution of payment instructions or securities transactions);
  • where you have given us your consent (e.g. for referral to another LGT Group company for a product or service you have requested); and
  • where it is required by law or regulation (e.g. to comply with anti-money laundering regulations or reporting obligations under tax law).

These disclosures of personal information to third parties will only take place in accordance with the law and for the purposes listed above.

How do we keep your personal information secure?

LGT Vestra takes all reasonable steps to ensure that any personal data that you provide to us is kept secure, and we have put in place measures to guard against unauthorised use of your personal information or accidental loss, destruction or damage. Because of the nature of the Internet, we cannot guarantee the security of your data transmitted to the website or via email, and any inward transmission of data is carried out at your own risk.

How long do we retain your personal information?

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Notice (unless longer retention is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

What are your legal rights under data protection laws?

Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information.  Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

 

  • Right to be informed. You have the right to be informed about how we collect and use your personal information.
  • Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you. If you like would to obtain a copy of this information please email us at info@lgtvestra.com. You may be required to submit a proof of your identity and a fee.
  • Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information.
  • Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time if that is the legal basis upon which we are processing your information. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
  • Right to restrict processing. You may, as permitted by law, request that we restrict or limit processing your personal information.
  • Right to erasure. You may request that we erase your personal information, unless there is a lawful reason for us not doing so.
  • Right to data portability. You have the right to request a copy of your information in a structured, commonly used and machine-readable format; and
  • Right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the ICO directly using the contact details below.

You also have a right to object to the processing of your data for the purposes for direct marketing, and we must comply with your request. You may also object to the processing of your information where we are processing your data for our legitimate business interest or for statistical or research purposes, although we may have compelling legitimate grounds to continue processing your data.

To contact the Information Commissioner’s Office for more information on your rights or other question you may have, please visit the ICO website or contact them via the following:

Information Commissioner's Office

Wycliffe House Water Lane

Wilmslow Cheshire SK9 5AF

Phone: 0303 123 1113

Linked websites

Please note that any websites that may be linked to our website are subject to their own privacy policy. LGT Group's data protection notice can be found on their website (www.lgt.com), and we encourage you to read that notice as well to understand how LGT may process your data.

Cookies

For more information please visit our Cookies Policy.

carefully

Last updated: November 2017

Please read these terms carefully

This Special Regulatory Information document (together with the documents referred to in it) provides you with important information about the regulatory framework within which LGT Vestra operates.

The information contained herein may be changed by us without notice and so you should check this page from time to time for any updates.

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.

Services

LGT Vestra LLP’s advisory and discretionary portfolio management services are restricted to providing clients with specialist expertise and advice on the management of investment portfolios. As a firm LGT Vestra LLP is able to source investment solutions from the whole of market and we are not tied to any products or providers. However, we will not consider clients’ wider financial planning and pension requirements, unless a client expressly wishes us to do so, when the client will be referred to one of our wealth planners.

Complaint procedure

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;

  • Initiate a record and file of your complaint; and
  • Acknowledge your complaint as soon as is reasonably practicable after the receipt of your complaint. This will generally be within 3 working days of receipt.

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.

Execution policy

For our execution policy, please click here.

Execution venues 

For more information about execution venues please click here.

For analysis of our use of execution venues please click here.

For the data relating to execution venues please click here.

Pillar III Disclosures as at 31.12.2016

Pillar III Disclosures

Given the industry that LGT Vestra operates in it is subject to a number of risks including but not exclusively credit risk, market risk, operational risk, liquidity risk and interest rate risk. Please click here for our Pillar 3 disclosure. Please click here for our Pillar III Disclosure.

Remuneration

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, contained within our Pillar 3 disclosure.

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 discretionary 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 clients' 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. This is done with our clients' best interests in mind at all times.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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 clients' 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.

  1. 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.

Important risk information 

 

YOU SHOULD BE AWARE THAT A POSITIVE PERFORMANCE IN THE PAST IS NO GUARANTEE OF A POSITIVE PERFORMANCE IN THE FUTURE. THE RISK OF FALLING PRICES, FOREIGN CURRENCY LOSSES AND FLUCTUATING RETURNS DUE TO EXCHANGE RATES WHICH ARE UNFAVOURABLE FOR INVESTORS CANNOT BE EXCLUDED. IT IS POSSIBLE THAT INVESTORS WILL NOT GET BACK THE FULL AMOUNT THEY INVESTED. COMMISSIONS AND CHARGES LEVIED ON THE ISSUANCE AND REDEMPTION OF UNITS ARE DEBITED SEPARATELY TO EACH INVESTOR.

INVESTORS ARE SPECIFICALLY ADVISED THAT CERTAIN INVESTMENTS ARE HIGHLY VOLATILE. SUCH INVESTMENTS, SUCH AS DERIVATIVES, MAY BE SUBJECT TO SIGNIFICANT PRICE FLUCTUATION, WHICH MAY BE EQUAL TO OR GREATER THAN THE AMOUNT OF CAPITAL INVESTED.

CERTAIN SPECIFIC INVESTMENTS MAY NOT BE IMMEDIATELY REALIZABLE. IT MAY THEREFORE BE DIFFICULT FOR INVESTORS TO SELL AN INVESTMENT, REALIZE A PROFIT, OR OBTAIN RELIABLE INFORMATION AS TO ITS VALUE OR THE DEGREE OF RISK TO WHICH THE INVESTMENT IS EXPOSED.

WHEN BUYING OR SELLING INVESTMENTS INVOLVING A CONTINGENT LIABILITY, NOT ONLY MAY YOU LOSE THE AMOUNT INVESTED, BUT IN CERTAIN CIRCUMSTANCES YOU MAY ALSO BE REQUIRED TO PAY AN ADDITIONAL AMOUNT.