Legal & Compliance

General Information

If you are a person who is resident in the United States of America (the "US") or you are otherwise regarded as a US person pursuant to the Securities Act, 1933 (e.g. you are incorporated in the US, you hold an account for the benefit or account of a US person or you are a US Trustee) and you are not an existing client of Credo Capital plc ("Credo"), then you may not access this website. Credo is not registered with the Securities Exchange Commission ("SEC") in the US and accordingly does not hold itself out generally to the public in the US as an investment adviser and does not solicit for business in the US. Credo is entitled to have a limited number of US clients based on it complying with the relevant exemptions from registration with the SEC. If you are an existing client or you are unsure whether you are a US person, please contact your Relationship Manager or send your query to

To the extent that this website contains information regarding collective investment schemes that are not authorized for distribution in Switzerland, such collective investment schemes may not be offered or publicly distributed in Switzerland.

The information on this website is only aimed at qualified investors according to Swiss law. This includes: (i) banks, securities dealers, fund managers and asset managers of collective investment schemes (including their clients with whom a written asset management agreement is in place), (ii) insurance companies, (iii) public corporations and pension funds with professional treasury operations as well as (iv) companies with professional treasury departments. An investor is deemed to operate a professional treasury service if it has at least one qualified expert experienced in the financial field to which it entrusts the continuous management of its financial assets.

Furthermore, the following are qualified investors: (v) high-net-worth individuals (i.e. private investors who have, prior to accessing this website, confirmed in writing to Credo Capital plc, 8-12 York Gate, 100 Marylebone Road, London NW1 5DX, that they possess net financial assets of at least CHF 2'000'000) and (vi) independent asset managers and investors who have entered into an asset management contract in writing with an independent asset manager to the extent that the asset manager is subject to the Money Laundering Act and to a code of conduct of a professional organization which is recognized as a minimum standard by the Swiss Financial Markets Supervisory Authority (FINMA) and that the asset management agreement is in accordance with the recognized guidelines of a professional organization.

Persons who are not qualified investors as described above may not access this website.

If you are accessing this site in the United Kingdom, please note that the information contained on this site has been approved by Credo, which is authorised and regulated by the Financial Conduct Authority (the "FCA"). The information on this site is not intended for distribution to, directed at nor for use by residents outside the United Kingdom, if such distribution, direction or use would be contrary to local law or regulatory requirements and no company in the Credo Group would accordingly be able to provide any services described in this site to any person in such circumstances. Investors are responsible for satisfying themselves that they may lawfully access this site, under the laws of their home jurisdiction.

The content on this site is provided for information purposes only and should not be construed as an offer or as solicitation of an offer to purchase investments or investment advisory services from the Credo Group of companies.

The relevant Credo Group companies undertake to comply with their obligations under the Financial Services and Markets Act 2000 (the "Act") and any disclaimers contained on this site will not operate to exclude or restrict liability for any duty to clients under the Act or any other applicable regulatory authority.

The investments or investment services provided by Credo may not be suitable for all investors. Investors with any doubts as to suitability of the investment products or services provided by Credo should consult their investment, tax or legal advisor.

Certain investments mentioned on this site may not be listed on any recognised stock exchange and so carry higher risks than investments in securities listed on a recognised stock exchange and may be difficult to sell or realise. Reliable information for determining their current value or the risks to which they may be exposed may not be available. No investment or investment service mentioned on this site amounts to a personal recommendation to any one investor.

Past performance is not a guide to future performance. The value of investments and the income from them can go down as well as up and an investor may not get back the amount invested. The value of shares may rise or fall due to changes in the rate of exchange in the currency in which the shares are denominated if it is different from the investor's own currency.

Certain Credo Group companies, or companies to which the Credo Group may introduce you, may not be authorised and regulated under the Act, but an introduction will only be made where it is deemed suitable. Accordingly, investors entering into investment agreements with such companies will not have the protections afforded by the Act or the rules and regulations made under it including the Financial Services Compensation Scheme.

Any of the Credo Group of companies and their associates may have positions in any investments that may be recommended to you and may be providing or have provided investment advice or services in relation to such investments.

Any data and research material provided ahead of an investment decision is for information purposes only. We shall not be liable for any errors or delays in the provision of information, or any actions taken in reliance thereon.

We reserve the right to amend, alter, or withdraw any of the information contained in this website at any time and without notice. No liability is accepted for such changes, or for the pages of this website not being available at all times.

This site may include forward looking statements that are based upon current opinions, expectations and projections. We undertake no obligation to update or revise any forward looking statements. Actual results could differ materially from those anticipated in the forward looking statements.

The internet is not a completely reliable transmission medium and there may be arbitrary delays and omissions in the provision of service. No company in the Credo Group will be liable for any loss (insofar as is permitted by the rules of the FCA, where applicable) resulting from a cause over which it does not have direct control. No company in the Credo Group will be responsible for any damage to investors' computers, software, modems, telephones or other property resulting from investors' use of this site. Whilst endeavouring to ensure availability of this site 24 hours a day, no company in the Credo Group will be liable for any loss or damage suffered by any person as a result of this site not being available. Access to this site may be suspended temporarily or permanently and without notice.

We accept no responsibility for information or software provided by other sites which may be accessed by hypertext link from these pages and we are not responsible for the maintenance or availability of such pages or the information or software which they contain.

All relevant telephone calls are recorded in accordance with our regulatory obligations.

Customer Statement

At Credo we are committed to offering our customers the highest possible standard of service and have accordingly incorporated the FCA's concept of 'Treating Customers Fairly' into our mission statement.

We recognise that we have as much to gain as you, our customers, when we look after your best interests and treat you fairly in all aspects of our dealings with you and so we are stating our commitment to you on this site.

Our commitment to you

  • To provide you with clear information about the products and services we offer you, including fees and charges;
  • To ascertain your individual needs, preferences and circumstances before recommending a product to you or investing in a product for you;
  • To deal openly and in a timely manner with your queries;
  • To meet or speak with you on a regular basis;
  • To only recommend products and services that we believe are suitable or appropriate for you;
  • To manage conflicts of interest fairly, both between ourselves and our customers and between customers themselves;
  • To encourage you to ask if there is anything that you don't understand;
  • To encourage you to give us feedback (whether positive or negative) on our services; and
  • To give you access to a formal complaints procedure should you become unhappy with our service.

How you can help us

You can assist us to provide you with the products and services that are suitable for you by:

  • providing us with information relating to your financial position, knowledge, experience, understanding of risk and personal background to enable us to offer you tailored products that are suitable or appropriate for you;
  • informing us of any changes to your financial or personal information, in a secure manner, to ensure that we keep our records up to date;
  • letting us know if there is any aspect of our service, or of a product we have discussed or recommended that you don't understand or you are not happy with; and
  • telling us if you think there are ways we can improve our service.

Feedback

Should you have any comments (positive or negative) regarding the implementation of our commitment to you or any service that we provide to you (or you have any question) please tell us by contacting your relationship manager and/or send your comments to .

Introduction

Credo’s intention is always to provide all clients with the highest quality of service and to act in their best interests at all times. Occasionally, however, a client may feel they have a cause for complaint regarding the service, or part of the service, provided, or failure to be provided, by Credo. This summary outlines who is an ‘eligible complainant’ and the process and timeline that Credo will follow when dealing with any complaint brought by a client.

Financial Conduct Authority and Financial Ombudsman Service

Credo Capital plc (FRN: 192204) and Credo Corporate Finance Limited (FRN: 190699) (collectively Credo) are authorised and regulated by the Financial Conduct Authority (FCA).

As part of its statutory obligation, the FCA has established the Financial Ombudsman Service (FOS) which has the power to consider, arbitrate and settle complaints between FCA authorised firms and an ‘eligible complainant’ where the parties have been unable to resolve the matter themselves, or a client is not satisfied with the way in which a firm has dealt with the client’s complaint.

Only complaints by persons (or on behalf of persons) who are ‘eligible complainants’ (as defined by the FCA) may be made to the FOS. Not all clients would accordingly be able to make a complaint to the FOS, i.e. clients who are categorised as professional or eligible counterparties are generally not regarded as being ‘eligible complainants’, which for the purposes of the type of businesses that Credo carries on, are the following persons:

  • a consumer (being a natural person acting for purposes outside his trade, business or profession);
  • a micro enterprise (being an enterprise that employs fewer than 10 persons and has a turnover or annual balance sheet that does not exceed €2m);
  • a charity with an annual income of less than £1 million; or
  • a trustee of a trust which has a net asset value of less than £1 million.

If you have a complaint, please advise us at the following address:

Compliance Officer
Credo Wealth
8-12 York Gate
100 Marylebone Road
London NW1 5DX
Tel: 020 7968 8300
Email:

To enable us to resolve your complaint as quickly as possible, please provide us with the following information:

  • the name, address, contact phone number and email address of the complainant; or
  • the name and address of the organisation you represent, if you are making a complaint on behalf of an eligible complainant as well as the name and contact details of the person at the organisation who is making the complaint on behalf of an eligible complainant; and
  • the account number or other reference for the account that the complaint relates to; and
  • details of the complaint, including relevant references and dates.

Time Limits for Handling Complaints

Once we receive a complaint we will endeavour to resolve it as fairly and as quickly as possible, either informally or formally.

Informally Resolved Complaints

If a client makes a complaint to us that we are able to resolve informally within three business days of the complaint being received, we will do so. In that event, we will issue a Summary Resolution Communication (SRC) to the complainant which will include the following content which has been prescribed by the FCA:

  • A statement that Credo considers the complaint to be resolved;
  • A statement that the complainant may refer the complaint to the FOS if they subsequently decide that they are dissatisfied;
  • The website address for the FOS and comment that further information is available there; and
  • Whether Credo consents to waive the six-month time limit for referring the complaint to the FOS.

Formally Resolved Complaints

Where we are unable to resolve the complaint informally we will follow the formal ‘eight-week process’, as follows:

  • We will promptly issue a written acknowledgement of the complaint after receipt or failure to resolve it informally (the Date of Receipt), stating that the complaint has been received and is being dealt with or that we have been unable to deal with it informally and it will be dealt with formally;
  • Thereafter, we will keep the complainant informed of the progress of the complaint including the steps taken to resolve the complaint;
  • Within eight weeks of the date of Receipt, Credo will issue a written ‘final response’ to the complainant which;
    • accepts the complaint and, where appropriate, offers redress or remedial action; or
    • offers redress or remedial action without accepting the complaint; or
    • rejects the complaint and gives reasons for doing so;
    • encloses a copy of the FOS's standard explanatory leaflet;
    • provides the website address of the FOS;
    • informs the complainant that if they remain dissatisfied with the Company's response, they may now refer the complaint to the FOS and must do so within six months; and
    • indicates whether, or not, Credo consents to waive the relevant time limits.
  • If at the end of the eight-week period, Credo is not yet in a position issue a ‘final response’, it will send a written response to the complainant which;
    • explains why Credo is not in a position to make a final response and indicates when it expects to be able to provide one;
    • informs the complainant that they may now refer the complaint to the FOS;
    • indicates whether, or not, Credo consents to waive the relevant time limits;
    • encloses a copy of the FOS standard explanatory leaflet; and
    • provides the website address of the FOS.
  • If Credo is unable to issue a final response or it does so, but the complainant is not satisfied with the final response, the complainant has six months to refer the matter to the FOS.

Further information about the FOS may be obtained from;

The Financial Ombudsman Service
Exchange Tower
London E14 9SR

Telephone: 020 7964 1000 (Open 9am-5pm Monday-Friday)
Email:
Website: http://www.financial-ombudsman.org.uk

Credo Capital plc Pillar 3 Disclosure and Policy

Introduction

Regulatory Context

The Capital Requirements Directive (“CRD”) and the Capital Requirements Regulation (“CRR”) (approved by the European Parliament on 26 June 2013), together comprise CRD IV and took effect from 1 January 2014. CRR is binding directly on EU Members, while CRD was incorporated in the United Kingdom by way of rules introduced by the Financial Conduct Authority (the “FCA”) through the General Prudential Sourcebook (“GENPRU”), the Prudential Sourcebook for Investment Firms (“IFPRU”) and in the Senior Management Systems and Controls Sourcebook (“SYSC”) (SYSC 19A) regarding remuneration.

CRD IV replaces the existing capital requirements for banks, building societies and a number of investment firms and, for firms within its scope, is applicable at a solo (entity), sub-consolidated and consolidated basis. Under CRD IV, Credo Capital plc ( the “Firm”) is categorised as an IFPRU €125k firm (as defined by the FCA) and will need to comply with the CRR and the FCA’s IFPRU handbook. CRD IV introduced a stricter definition of capital resources, increased capital requirements, increased reporting obligations (COREP), binding liquidity ratios and new requirements on remuneration. However, the existing Pillar 2 ICAAP assessment, and the FCA’s Individual Capital Guidance (“ICG”), is materially unchanged from the previous regime and has been effectively transcribed into the IFPRU handbook.

Pillar 3 complements the minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2) and requires firms to disclose information regarding their risk assessment process and capital resources with the aim of encouraging market discipline by allowing market participants to assess key information on risk exposure and the risk assessment process. The Firm has considered the changes arising from the implementation of CRD IV in its latest ICAAP assessment and the Firm remains comfortably in excess of its minimum capital requirements under CRD IV.

Frequency

The Firm will make Pillar 3 disclosures annually. The disclosures will be as at the Accounting Reference Date, which is 31 January. The Pillar 3 disclosures have been reviewed and approved by the Firm’s Board.

Media and Location

This document has been prepared and is displayed on this website to meet the Firm’s Pillar 3 disclosure obligations.

Verification

The information contained in this document has not been audited by the Firm’s external auditors, does not constitute any form of financial statement and must not be relied upon in making any judgement concerning the Group of companies of which the Firm is a member.

Materiality

The Firm regards disclosure information as material 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. If the Firm deems a certain disclosure to be immaterial, it may be omitted from this document.

Confidentiality

The Firm regards information as proprietary if sharing that information with the public would undermine its competitive position. Proprietary information may include information on products or systems which, if shared with competitors, would render the Firm’s investments therein less valuable. Further, the Firm must regard information as confidential if there are obligations to customers or other counterparty relationships binding the Firm to confidentiality. In the event that any such information is omitted, the Firm will disclose that fact and explain the grounds why it has not been disclosed.

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Summary

The CRD requirements have three pillars. Pillar 1 sets out the minimum capital resource requirement firms are required to maintain to meet credit, market and operational risks; Pillar 2 deals with the Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by a firm and the Supervisory Review and Evaluation Process through which the firm and regulator satisfy themselves on the adequacy of capital held by the Firm in relation to the risks it faces. In summary, Pillar 2 requires firms to assess firm-specific risks not covered by Pillar 1 and, where necessary, maintain additional capital (or such capital that is sufficient to cover the higher of the Pillar 1 and Pillar 2 risks; and Pillar 3 which deals with public disclosure of risk management policies, capital resources and capital requirements.

The Firm is an Investment Management Firm and acts solely as an agent. The Firm’s main risks have been identified as Operational Risk, Credit Risk, Market Risk and Liquidity Risk. The Firm is required to disclose its risk management objectives and policies for each separate category of risk which include the strategies and processes to manage those risks; the structure and organisation of the relevant risk management function or other appropriate arrangement; the scope and nature of risk reporting and measurement systems; and the policies for hedging and mitigating risk, and the strategies and processes for monitoring the continuing effectiveness of hedges and mitigating controls.

The Firm has assessed its Operational, Credit and Liquidity Risks in its ICAAP and in which it also sets out appropriate actions to manage those risks.

The Firm has an Operational Risk framework (described below) in place to mitigate Operational Risk.

The Firm’s main exposure to Credit Risk is the risk that management and stockbroking fees cannot be collected and accordingly we deem Credit Risk to be low. The Firm holds all cash balances with banks that have been awarded high credit ratings.

Market Risk exposure has been assessed by the Firm and is limited to the Firm’s exposure to any cash amounts held by the Firm in a foreign currency. Most foreign currency is converted into GBP on a regular basis.

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Background to the Firm

Background

The Firm is incorporated in the UK and is authorised and regulated by the FCA as an Investment Management Firm. The Firm is categorised as an IFPRU €125,000 limited licence firm, which holds client assets but does not trade on its own account for capital requirements pursuant to IFPRU. The Firm is a Solo regulated entity.

The Firm has also been assigned a C4 conduct classification and a P3 prudential classification by the FCA.

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Risk Management Objectives and Policies

Risk Management Objective

The Firm’s general risk management objective is to develop systems and controls to mitigate risk to a level that does not require the allocation of Pillar 2 capital.

Governance Framework

The Credo Executive Committee is the Governing Body of the Firm. It meets bi-monthly and is composed of:

  • Chief Executive Officer
  • Finance Director
  • Legal and Compliance Director
  • Chief Investment Officer
  • Managing Director of the Firm
  • Two additional directors of the Firm
  • A non-executive director of the Firm

The Executive Committee has chosen to delegate its day-to-day risk management activities to the Firm’s Compliance Committee (“Compliance Committee”). The Compliance Committee is responsible for determining the Firm’s risk appetite or tolerance for risk and ensures that the Firm has implemented an effective, on-going process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed.

In addition, the Executive Committee has chosen to delegate the day-to-day general management of the Firm to a new Management Committee (“Manco”). Manco meets bi-monthly and the minutes of these meetings are provided to the Executive Committee prior to their bi-monthly meetings. The Financial Director sits on both the Executive Committee and Manco, and in addition to the minutes distributed, he provides feedback to the Executive Committee on issues which Manco want the Executive Committee to discuss further and where applicable provide final approval.

Risk Framework

Risk within the Firm is managed by the use of the following:

  • Compliance Committee which has oversight of the day-to-day risk management activities of the Firm with the financial risks being managed by the Finance Director, the regulatory risks being managed by the Compliance Officer and the Legal and Compliance Director and the operational risks being managed by the Head of Operations;
  • The Firm has a conservative approach to risk;
  • The Firm has identified its risks and recorded them in its ICAAP;
  • The ICAAP is reviewed at an annual meeting of the Executive Committee;
  • The Firm has undertaken scenario Analysis and Stress Tests on the most significant risks identified. This informs the Firm how risks are likely to behave and what, if any, impact there is likely to be to our balance sheet;

The Firm undertakes an assessment of all risks identified which are documented in the Operational Risk Document (“ORD”). It involves three stages.

1. Determining the probability and impact of a risk before considering the effect of any controls, is known as an ‘inherent risk assessment’. It is important to ensure that a realistic scenario is generated; otherwise each inherent risk assessment will indicate a catastrophic impact, whereas realistically, for most risks, other mechanisms will restrict the impact.

2. Departments must assess the effectiveness of the controls in mitigating the risks identified. This is known as ‘residual risk assessment’. This enables the department to understand the key risk exposures and where there are weaknesses in the areas of control.

By reviewing the inherent and residual risk assessments, departments will be able to ascertain those risks which are not adequately controlled. In these instances, departments must prepare action plans which:

  • Clearly articulate the risk that requires management;
  • Assign achievable timescales to mitigate the risk;
  • Clearly detail the proposed solution, including resources required (where appropriate);
  • Ensure that a risk owner is assigned with responsibility for managing the action plan.

3. The final stage is to determine the likelihood and impact of the risk given the effectiveness of the control.

Risk Monitoring and Management

It is essential that key controls and the overall risk environment are subject to constant, on-going monitoring to assess unacceptable levels of risk. This can be achieved by:

  • Identifying and monitoring appropriate triggers and thresholds;
  • Identifying and monitoring external risks;
  • Identifying and monitoring internal risks;
  • Assessing non-financial impacts;
  • Having annual risk and control self-assessments;
  • Implementing action planning.

Each department within the Firm monitors its own risk using the self-assessment process. The Firm believes that the self-assessment process is a valuable tool for building a better risk management culture as it facilitates accountability and transparency from the bottom to the top of the Firm.

The Firm controls its risks through the avoidance, transfer, prevention or reduction of the likelihood of the occurrence and/or the reduction of the potential impact of a risk exposure. This includes:

  • Embedding a risk culture throughout the Firm;
  • Ensuring that robust internal processes, controls and systems are maintained;
  • Utilising outsourcing arrangements, where appropriate;
  • Accepting risks within the stated risk tolerance level;
  • Providing for potential losses.

To ensure that appropriate controls are in place and being adhered to, the Compliance Committee (or a member or sub-committee with delegated authority) (the Relevant Committee) will review the controls on an annual basis. A list of the controls for the identified risks will be presented and then assessed. Where controls are not sufficient, the Relevant Committee will work with the department to develop and deliver new or enhance existing controls in accordance with an action plan, to ensure the department is actively managing its own risks.

Each department’s risk owner is required to confirm annually that all potential risks, including any new emerging risks, have been identified and are recorded. All controls must be reviewed for effectiveness and updated and action plans prepared, where appropriate.

When the Risk Management process is undertaken, it must be supported or ‘championed’ at the highest levels of management by the Finance Director and the Legal and Compliance Director.

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Own Funds

The Firm is an IFPRU €125k Limited Licence Firm because it does not deal for its own account or underwrite issues on a Firm commitment basis. It manages individual portfolios and it holds Client Money. An IFPRU firm must maintain at all times capital resources equal to or in excess of the base requirement (€125,000). The Pillar 1 capital requirement for an IFPRU €125K Limited Licence Firm is set out in Article 95 (2) of the CRR and is the higher of the credit risk capital requirement and the market risk capital requirement, or the Fixed Overheads Requirement (“FOR”) (i.e. one quarter of the Firm’s relevant fixed expenditure multiplied by 12.5).

The “Total Risk Exposure Amount” (“TREA”), which, for the Firm, is defined as 12.5 times the FOR is the amount used for the Pillar 1 capital adequacy purposes.

The Firm must maintain at all times capital resources equal to or in excess of the Pillar 1 requirement. During the 12 month accounting period to 31 January 2017, the Firm complied fully with all capital requirements and operated well within regulatory requirements. At the accounting reference date, the Firm held the following capital position:

Tier 1 Capital

Share Capital 750,000
Audited Retained Earnings 4,922,235
Total Tier 1 Capital and Own Funds 5,672,235
   
Total Risk Exposure Amount 20,727,750
   
Total Capital Ratio 27.37%
Surplus capital over minimum requirement 4,014,015

There are three tests of capital adequacy, which relate to the TREA figure. Firms are required to have:

  • Common Equity Tier 1 capital of 4.5% of TREA. Our minimum requirement based on the above TREA is £932,749 and we currently have a Common Equity Tier 1 capital amount of £5,672,235 (27.37% of TREA);
  • Tier 1 capital of 6% of TREA. Our minimum requirement based on the above TREA is £1,243,665 and we currently hold a Tier 1 capital amount of £5,672,235 (27.37% of TREA);
  • Total capital (Own Funds) of 8% of TREA. Our minimum requirement based on the above TREA is £1,658,220 and we currently hold Own Funds of £5,672,235 (27.37% of TREA).

The Board is therefore comfortable that the Firm is, and has been throughout the financial year, adequately capitalised for Pillar 1 purposes.

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Credit Risk and Dilution Risk

The Firm is primarily exposed to Credit Risk from the risk of non-collection of stockbroking and management fees. It holds all cash balances with Banks assigned high credit ratings. Consequently risk of past due or impaired exposures is minimal. A financial asset is past due when a counterparty has failed to make a payment when contractually due. Impairment is defined as a reduction in the recoverable amount of a fixed asset or goodwill below its carrying amount.

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Market Risk

The Firm has Non Trading Book potential exposure only. The firm holds minimal cash in foreign currencies. Any major foreign currency fluctuations will have a minimal impact on the cash held by the firm.

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Operational Risk

Operationally, the Firm is also exposed to the following risks:

  • People
  • Regulatory
  • Technology

People

The Firm’s business is heavily dependent on the people who provide the services to the Firm’s clients. The Firm accordingly ensures that it employs people with the necessary skill sets appropriate for its business needs. Recruitment policies are in place to ensure that the right calibre of persons are recruited and that the appropriate level of training and competence is achieved and maintained for the relevant service providing people. The Firm aims to attract and retain staff by paying market related remuneration (that complies with SYCS 19A) but also to provide a work environment that is inclusive, supportive and flexible whilst maintaining high professional standards.

Regulatory

Regulatory risk involves the loss arising from the failure to meet regulatory requirements in those jurisdictions in which the Firm operates. The financial services sector is heavily regulated and breaches lead to fines or disciplinary action both for the Firm and for individual staff. The Compliance function (which also covers the Risk function) supports the business to meet such obligations. They closely monitor actual and planned changes in regulation to ensure ongoing compliance with regulatory standards and to this end the Firm is assisted by professional consultants. The Firm carries professional indemnity cover in excess of the minimum FCA requirement. In addition to day to day oversight of regulatory impacting matters, the Compliance Committee meets (at a minimum) on a monthly basis to assess the risks and compliance related topics that the Firm and the industry face. Some of the major strategic areas such as Conduct, Governance, Financial Crime, Systems and Controls are also key areas that are overseen by the Management Committee, the Board and the Compliance team. Staff receive training to address the key areas in the regulatory field.

Technology

The Firm is reliant on technology to maintain its infrastructure. Significant investment has been made in core IT systems over the last few years as part of a strategy of upgrading and strengthening procedures and management information. The Firm has used the services of IT consultants to assist in the development of those strategies and also to advise the Firm on any cyber security risks and the Firm has taken steps to address such risks. The Firm has a Business Continuity Plan in place.

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Remuneration

The Firm follows the prescribed FCA guidance on applying the Remuneration Code (the “Code”) proportionately. The Firm falls into Proportionality level three Category within SYSC 19A Remuneration Code and we have disapplied the following rules under the remuneration principles proportionality rule: SYSC 19A.3.40R; SYSC 19A.3.47R; SYSC 19A.3.49R; SYSC 19A.3.51R and SYSC 19A.3.44R. No external consultant has been used to determine the Firm’s remuneration policy.

1. Decision-making process

The Board has delegated to an informal Remuneration Committee (comprised of the Group CEO, Finance Director and two other directors of the firm) responsibility for monitoring compliance with the Firm’s remuneration policy to ensure that it operates as intended and that it continues to be appropriate.

The policy is subjected to a review at least annually. This review will take account of any relevant FCA and industry guidance, including that relating to the Code.

In considering remuneration structures, the Board will seek to ensure that arrangements take account of potential risks and:

  • Do not give rise to conflicts of interest, particularly as between the actions of employees and the interests of clients, shareholders, investors and other stakeholders; and
  • Are designed to comply with applicable laws and regulations.

2. Remuneration Principles

In setting remuneration for directors and staff the following overarching principles are applied, such that the Firm:

  • Rewards performance at the individual, team and corporate level;
  • Does not link the variable remuneration of Code and non-Code Staff directly to performance;
  • Ensures remuneration is sufficient to attract, motivate and retain high calibre individuals;
  • Ensures remuneration is aligned to the long-term performance of the business, and accordingly that its remuneration structure promotes effective risk management.

3. Determination of Salaries

The Firm aims to pay fixed salaries that are competitive and based on the individual’s responsibilities and own performance as well as that of the Firm, sufficient to allow for the possibility of no variable component being paid, save that variable remuneration, when awarded, is done so on a discretionary basis.

Guaranteed variable remuneration is not generally awarded, paid or provided save in the exceptional circumstances allowed for by and then only in accordance with, FCA rules. The Firm will monitor the fixed to variable compensation to ensure that SYSC 19 is adhered to with respect to the total remuneration paid to Code Staff, where applicable.

Code Staff Remuneration

Senior management and members of staff whose actions have a material impact on the risk profile of the Firm are classified as Code Staff. No staff have aggregate remuneration over £500,000 p.a. or have variable remuneration that is more than 50% of total remuneration. The table below shows the number of Code Staff in each business unit.

Sector No of Code Staff
Senior Management and Compliance 11
   
Code Staff Remuneration
Total Remuneration £2,535,522
Fixed Remuneration (incl. Pension) £1,765,022
Variable Remuneration £770,500
   
All Staff  
Total Remuneration £5,257,815

Credo Capital plc Stewardship Code Disclosure

Introduction

In accordance with the requirement under COBS 2.2.3R of the FCA Handbook, Credo Capital plc (Credo) is obliged to make a disclosure in relation to its commitment to the Financial Reporting Council’s Stewardship Code (the Code).

The Code was originally published by the Financial Reporting Council (FRC) in 2010 and subsequently updated in September 2012. The principal aim of the Code is to enhance the quality of engagement between institutional investors and the listed companies they invest in (Investee Companies) to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities by Investee Companies. The FRC believes that institutional investors should aspire to achieve the standards of engagement with Investee Companies in accordance with the good practice that it describes in the Code.

The Code sets out the principles of effective stewardship by investors and aims to assist asset owners and asset managers to exercise their stewardship responsibilities. Adherence to the Code is governed on a ‘comply or explain’ basis.

Although Credo supports the principles underlying the Code, Credo’s investment strategy is not supported by the Code and so it is no longer a signatory to the Code. This document describes the extent to which Credo has applied the seven principles of the Code and where appropriate, its alternative investment strategy.

Principle 1

Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

Credo’s policy is set out in this document which is available on the Credo website at www.credogroup.com. Credo currently manages investments on behalf of a limited number of professional clients who are not natural persons. Credo seeks to act in the best interests of its clients and as part of managing designated investments, engages and monitors companies on a wide range of matters such as performance, risks, strategy, capital structure and corporate governance, including culture and remuneration.

Good stewardship and monitoring of companies contributes to the Credo investment philosophy. These responsibilities are discharged internally as part of an integrated investment process. Although Credo recognises the importance of quality engagement between Investee Companies and institutional investors and the appropriate exercise of governance responsibilities in line with the investment objectives and needs of individual clients, we are not usually in a position to facilitate such engagement between our clients and Investee Companies.

Principle 2

Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.

The latest version of the Credo conflicts of interest policy is available at the top right tab on this page.

Credo seeks at all times to act in the best interests of clients, including with regard to conflicts of interest as required by the 8th principle of the FCA Principles for Business (PRIN 2.1) and SYSC 10 of the FCA Handbook. Under these obligations Credo is required to take all reasonable steps to identify, record, manage and disclose conflicts that may arise in the course of business. This includes identifying and managing actual or potential conflicts of interest that may arise either between Credo and its clients or between two separate clients.

Credo has in place a robust conflicts of interest policy, which is regularly reviewed and is committed to managing and resolving complaints fairly and efficiently.

In addition to the conflicts of interest policy, Credo also maintains and reviews on a regular basis a conflicts register which records actual or potential conflicts of interest and sets out how these conflicts are managed or mitigated.

Principle 3

Institutional investors should monitor their investee companies.

Effective monitoring and review of investments is a vital element of good stewardship. Whilst the holdings that our clients have that fall within the scope of the Code is small, and our ability to influence company management is limited, we nevertheless regularly monitor holdings and companies as part of our investment process.

Credo takes a variety of factors into consideration as part of its monitoring including company performance and corporate governance arrangements and uses a variety of research tools and publically available information to monitor company performance and developments. Where possible a call may be held with the company to discuss performance and developments.

Credo does not seek to be made an insider on company information, however if inside information is received this will be recorded and managed in accordance with the Credo Market Abuse Policy in respect of which all relevant staff have received training.

Principle 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.

Credo forms its own view on the strategy and governance of an Investee Company as a result of its monitoring and that will influence the investment decisions made in relation to those Investee Companies. Generally, the holdings that our institutional investor clients hold is small and so our ability to influence the management of Investee Companies is limited, however Credo may speak to other shareholders or third parties if an issue arises in an Investee Company that we feel should be escalated, but we wouldn’t usually take the lead in any engagement with an Investee Company.

Credo’s investment strategy where an issue is identified with an Investee Company would usually be that it would be more effective and efficient for our clients to sell their holdings rather than to take any action.

Principle 5

Institutional investors should be willing to act collectively with other investors where appropriate.

We are willing to act collectively with other investors where appropriate and where this may be in the best interests of our clients. We would be willing to work with other regulated entities including members of recognised industry associations such as the Wealth Management Association (WMA) or Investment Management Association (IMA), but we would not usually take the lead in initiating any such action.

Due to the size of our clients' holdings, any arrangement would be informal and determined on a case by case basis.

Anyone seeking to act collectively should contact Credo at info@credogroup.com or call 020 7968 8300.

Principle 6

Institutional investors should have a clear policy on voting and disclosure of voting activity.

Credo does not have a voting policy per se and we will act on our clients’ instructions in relation to a vote where appropriate or where we have discretion, we may vote our client’s shares having due regard to the nature of the issues at hand, the relevant clients’ investment objectives as well as our obligation to act in the best interests of our clients.

Credo will not automatically support the Board of an Investee Company and may abstain from voting if it cannot get instructions from a client or it determines that to do so would be in the best interests of clients.

Credo does not routinely attend company meetings but may attend a meeting depending on the issues being addressed at the meeting and the impact on the interests of our clients.

Principle 7

Institutional investors should report periodically on their stewardship and voting activities.

Credo maintains records of voting activities and how votes have been exercised and that information would be made available only to a client in relation to their own shares (upon request) or as required by legal/regulatory obligations. Credo will not normally disclose voting intentions, make public statements or advise any third party of its voting activities due to client confidentiality.

Any personal data obtained in the course of providing our services to you will be held and processed by us in accordance with the relevant data protection legislation.

Personal information may be transferred to any connected companies of the Credo Group to fulfil our service obligations.

We respect your privacy and will not supply personal information to anyone else unless you have given your permission for us to do so.

From time to time, Credo Capital plc ("Credo") may publish investment research and recommendations on this website. Such investment research will usually be impartial or not. Set out below is Credo 's policy on the impartiality of research.

Policy of impartiality

Investment research issued by analysts is conducted under the following circumstances:

  • The analysts have no relationship with the issuer of securities;
  • The analysts' remuneration is not linked in any manner to the outcome of the recommendation;
  • The analysts do not receive any inducement from the issuer of securities to provide favourable research;
  • The research is not reviewed by any persons whose impartiality might reasonably be considered to conflict with the interests of the clients to whom the investment research is to be distributed.
  • The analysts are not involved in any other activities in the Credo Group that will place their impartiality in question.

In addition, Credo does not undertake proprietary trading.

In terms of Credo's policy, no dealing is permitted by staff or clients (other than an unsolicited client order) until the clients for whom the publication is principally intended have had (or are likely to have had) a reasonable opportunity to act upon it.

In the event that a company in the Credo Group has a mandate to provide services or advice to the Issuer of the securities which are the subject of an investment recommendation, such securities are placed on a restricted list and will be subject to the policy referred to above.

The above policies and procedures are strictly monitored by the compliance team.

Research that is not impartial

In the event that a newsletter or recommendation does not comply with the above policy, readers will be warned that the research cannot be relied upon as being impartial, objective or independent.

If you are a UK resident retail client who wishes Credo Capital plc ("Credo") to advise you in connection with certain types of retail investment products (such as units in collective investment schemes (regulated and unregulated), interests in investment trust savings schemes, securities in investment trusts, other designated investments in a packaged form or structured capital-at-risk products (collectively "RIPs")), Credo is obliged to bring to your attention that the advice that Credo will give to you will not be independent advice covering the whole range of RIPs (as defined in the Conduct of Business Rules of the Financial Conduct Authority) but will be given on a limited range of products and/or in respect of a limited number of providers and accordingly the advice will be restricted.

This Policy has been drafted to comply with the relevant rules of the Financial Conduct Authority in the United Kingdom (FCA) in particular Principle 8 and SYSC 10 (the FCA Rules).

The Policy is divided into six sections:

1. Scope and Purpose
2. Application and Fair Treatment
3. Managing Conflicts
4. Updating the Policy
5. Consenting to the Policy
6. Contact Details


1. Scope and Purpose

Conflicts of Interest and potential conflicts are ubiquitous in the financial services industry. Although the potential for conflicts to arise is most likely to be greater in large organisations providing a full range of financial services, even smaller firms may have interests which conflict with the duties owed to clients. The failure to deal appropriately with any conflict leads to the undermining of confidence in the financial markets in general. At the individual firm level, firms failing to address such conflicts may be exposed to the risk of litigation and loss of reputation. Therefore, the world's regulatory authorities are rightly concerned with the standards in firms' organisational arrangements and expect strong management oversight and control in this respect. The Policy adopted by the Credo Group and that applies to Credo Capital plc (Credo) and Credo Corporate Finance Limited (CCF) is set out below. References below to “we” mean Credo or CCF as the case may be.

2. Application and Fair Treatment

2.1. Normally we do not take positions or deal on our own account. However, we or a company in the Credo Group that is an associated company (a Group Company) or some other person connected with us (including an employee or director of Credo), may have (1) a material interest in a transaction to be entered into with or for a client; (2) a relationship that gives, or may give, rise to a conflict of interest relating to the investment, transaction or service concerned; (3) an interest in a transaction that is, or may be, in conflict with the interest of any of the firm's clients; or (4) clients with conflicting interests in relation to a transaction.

2.2. Although we only provide restricted advice, we do offer a wide range of financial and investment advisory services, investment management services, securities trading and brokerage services and other commercial and investment products and services to a wide range of individuals and organisations and as a result we or any Group Company may at times have interests which conflict with those of our/its clients. We aim to treat our clients fairly, suitably and appropriately. One of the ways in which we seek to achieve these aims is to have regard to the conflicts of interest that may arise through our business activities where such conflicts may involve a material risk of damage to our clients. Under the provisions of the FCA Rules we are required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage such conflicts of interest. We have put this Policy in place to meet this obligation and set out below a summary of that Policy and the key information that is needed by clients to understand the measures we are taking to safeguard the interests of our clients.

2.3. Our internal policies and procedures are designed to ensure that we identify potential conflicts of interest that arise or may arise between us and our clients and between one of our clients and another.

2.4. The circumstances in which such a conflict of interest or potential conflict of interest may arise, include, but are not limited to, where we or any of our associates (as defined in section 345 of the Companies Act, 2006) (including any Group Company) may:

2.4.1. act on your behalf, as agent and also act for an associate (including any Group Company) or a third party client or investor in the same transaction or act as a distributor of an investment and receive a benefit, including a placement fee, commission, rebate or reduction (whether from standard rates of commission or otherwise), in connection with any service or transaction provided or entered into. Where we are not prohibited by any relevant rules of the FCA, we may retain such benefit and we undertake to provide you with further details of any such benefit that we receive on request;

2.4.2. act in relation to investments where any of us is involved in a new issue, rights issue, takeover or similar transaction concerning the investments;

2.4.3. act in relation to investments where it or any director or staff member may hold an interest or shareholding in the Issuer of the securities or the entity that is facilitating the investment;

2.4.4. invest you in or advise you to invest in a fund(s) of which we are the investment manager;

2.4.5. execute a transaction for or with you in circumstances where we have knowledge of other actual or potential transactions in the relevant investment;

2.4.6. hold a position in, or trade, deal or make markets in, investments purchased or sold by you;

2.4.7. recommend the purchase or sale of a designated investment in which one of our clients has given instructions to buy or sell;

2.4.8. act as adviser to, or have any other business relationships with, or interest in, the issuer (or any of its associates or advisers) of any investments purchased or sold by you or advise any person in connection with a strategic transaction in relation to such investments, including but not limited to, a merger, acquisition or takeover by or for any such issuer (or associates or advisers);

2.4.9. recommend the purchase or sale of a designated investment in which we have the opposite position; or

2.4.10. in exceptional circumstances and where a Group Company is dealing as principal for its own account, buy or sell the investment concerned and therefore make a profit (or loss) or take a mark-up, mark-down or credit for its own account.

3. Managing Conflicts

3.1. We have implemented and maintain a number of procedures and measures for managing conflicts of interest that arise in the course of our business. Such measures may include, but are not limited to, the following:

3.1.1. structural separation. Such separation may be physical or otherwise, including but not limited to information barriers;

3.1.2. compensation arrangements and/or management and supervisory structures which are aligned with this Policy;

3.1.3. oversight of contacts between and within business units whose clients have adverse or competing interests with the clients of other business units;

3.1.4. regulation of personal investment and business activities of our employees by our Compliance Department to prevent conflicts of interest arising against the interests of clients; and

3.1.5. disclosure on this site, in Credo's Terms of Business, in any specific information document and/or in person, that conflicts of interest situations may arise and by accepting those Terms of Business or the specific investment, the client agrees that he/she/it does not object to the material interest or conflict of interest generally or specifically disclosed.

3.2. Where these measures are not sufficient to ensure, with reasonable certainty, that risks of damage to the interests of one or more clients will be prevented, and if we believe there is no practicable way of preventing damage to the interests of one or more clients, we may decline to act.

3.3. You acknowledge that the circumstances set out in section 2.1 above may result in conflicts of interest, nevertheless you agree that we and any relevant Group Company may provide the relevant services despite any such interest and that we are not required to account to you for any income, gain, profit, benefit or other advantage arising from doing so, provided that we do not contravene the FCA Rules.

3.4. Group Companies and/or their employees may make markets or specialise in, have positions in and effect transactions in securities of companies and may also perform or seek to perform investment advisory or corporate finance activities for those companies. As a result, we may not be able to advise or deal for you in certain investments and we reserve the right at any time in our absolute discretion to decline to deal or arrange any transaction or give advice or make any recommendation to you.

3.5. Where we act as an intermediary for packaged products (such as collective investment schemes and/or close ended companies), we may advise you and/or buy or sell units for you in, any packaged products, including those where we are or a Group Company is the trustee, operator, manager, administrator or an adviser of/to the scheme.

3.6. Where we have a discretionary or advisory mandate from you and invest or advise you to invest some or all of your assets in a fund (or funds) that we act as the investment manager for (an in-house fund), there could be a conflict of interest which must be managed. However, for clients who want an investment based on Credo’s investment methodology (CIM), there won’t be a conflict where the in-house fund essentially reflects the CIM which is the same investment methodology used for Credo’s segregated model portfolios. Credo will always act in a client’s best interests in making any recommendation to invest in an in-house fund and where it is a suitable investment, Credo’s intention is that clients invest in an in-house fund in preference to its segregated model portfolios, save where you wish to invest or we believe you should invest in an asset class that our in-house fund(s) don’t cover. In any event and whether or not an in-house fund reflects the CIM, we will assess on an annual basis whether the investment remains suitable for you and such assessment may include a review of other similar funds

3.7. We may match your transaction with that of another client by acting on his/her/its behalf as well as yours.

3.8. We may recommend or buy investments where we are or a Group Company is involved in a new issue, rights issue, takeover or similar transaction concerning the investment and/or where we or a Group Company has given advice to the issuer.

3.9. We will be entitled from time to time, at our absolute discretion, to delegate to any person or entity the performance of any of our duties, functions or powers. If required by any applicable regulations, appropriate details of any delegation will be provided to you.

4. Updating the Policy

How often will we update the policy?

We will update the Policy periodically to take into account changes as and when appropriate.

How can you obtain the most recent version of the Policy?

This is most recent version of the Policy. If you would like to receive a copy, please contact us in the manner described in section 6.

5. Consenting to this Policy

We are required to obtain your written consent to this Policy before we undertake any transaction or provide any service to you. Your consent will be given in the Declarations and Signatures section in our Application Form and is deemed to refer to the most current version of this Policy.

6. Contact Details

How do you contact us in connection with this Policy?

If you have queries about the Policy, please contact our Compliance Officer via email to or at the address below:

Compliance Officer
Credo Capital plc
8-12 York Gate
100 Marylebone Road
London NW1 5DX
Tel: +44 (0)20 7968 8300

This Policy summarises the general basis on which Credo Capital plc (referred to hereafter as “we” or “our”) will provide "best execution" when required by the European Union's Markets in Financial Instruments Directive (known as "MiFID") and the Conduct of Business Rules of the UK Financial Conduct Authority (“FCA”) to all retail and professional clients.

The Policy is divided into seven sections:

1. Scope and Purpose
2. Achieving Best Execution
3. Compliance with Client Instructions
4. Choosing an Execution Venue
5. Updating the Policy
6. Consenting to the Policy
7. Contact Details

1. Scope and Purpose

What is the purpose of the Policy?

We recognise the importance of achieving the best possible result when executing trades for you. This is important for maintaining and developing our relationship with you. We strive at all times to act fairly and reasonably in dealing with you. In certain cases where we are providing order execution services to our clients, we are required under MiFID and the applicable FCA Rules to establish and comply with a policy on order execution. The purpose of this Policy is to set out in this obligation to you in a clear and concise manner.

When does this Policy apply?

The Policy applies where we act on your behalf in the execution of orders of financial instructions that are covered by MiFID and we agree to provide the best price or other terms for you in the market.

The Policy will not apply when we are not executing an order on your behalf, for example where or to the extent:

  • We transact with you as principal on the basis of a published quote;
  • We transact with you as counter party for our own account;
  • We are following your specific instructions to execute a specific part or aspect of an order.

The financial instruments covered by MiFID include most financial instruments but do not include:

  • spot foreign currency exchange transactions; and
  • spot commodity derivative transactions.

The Policy applies to all transactions we arrange or execute on your behalf, whether arranged or executed through affiliated companies or otherwise.

2. Achieving Best Execution

What does "best execution" mean?

"Best execution" means:

  • That we have a set policy (namely this Policy) that is designed to achieve the best possible result (taking into account all relevant factors described below) across all orders on a consistent basis for any financial instrument covered by MiFID when placing the orders for execution with execution venues identified in this Policy.
  • That we are committed to comply with the Policy.
  • That we will take steps to monitor, review and update the Policy to ensure that it continues to achieve such results.

Complying with our best execution obligations under MiFID does not involve a transaction-by-transaction analysis. Instead, we are required to take all reasonable steps to obtain the best result overall when executing orders on your behalf having regard to the execution factors set out in MiFID and the applicable FCA Rules.

What factors do we take into account to achieve best execution?

In achieving best execution, we take into account a number of factors (unless otherwise instructed by you, as discussed in Section III below). These include:

  • price;
  • costs;
  • speed;
  • likelihood of execution and settlement (liquidity);
  • size;
  • nature;
  • type and characteristics of financial instrument;
  • characteristics of the possible execution venues;
  • nature of the client (retail/professional); and
  • any other consideration relevant to the execution of the order.

While total consideration (price and costs) are generally key factors, the overall value to you of a particular transaction may be affected by the other factors listed above. We may conclude that factors other than price and costs are more important in achieving the best possible result for you. The relative importance of each of the factors will differ depending on:

  • you are categorised as a retail or professional client and any special objectives you may have in relation to the execution of the order;
  • the characteristics of your order;
  • the characteristics of the financial instruments to which your order relates; and
  • the characteristics of the venues (if there is more than one) to which your order may be directed.

Normally, we act as your agent when buying or selling or subscribing for securities. We monitor transactions for our clients so that we can try to ensure that clients receive the best possible result in the circumstances. If a client’s proposed transaction falls outside the market size, the best price may not always be possible but we monitor the price offered and ensure that so far as practicable it is not significantly outside the market price.

What is our responsibility when your order is executed for us by a third party?

Where we are not a member of an exchange in a particular jurisdiction or where we believe it is in the client’s best interest to do so, we will pass your order to a third party (which may be a broker) to execute.

We may pass an order to a non-affiliated third party broker or dealer to execute. In respect of such cases we have internal processes and procedures in place to periodically review our choice of third party brokers and dealers to determine that, taking into account all the factors specified above, the third party broker or dealer is providing the best results for your orders on a consistent basis. In making this determination we will have regard to:

  • prices offered for the particular type of instrument over time;
  • average costs per trade charged for the type of trade over time;
  • the best execution policy of and any other guidance issued by, the relevant broker or dealer, from time to time.

3. Compliance with Client Instructions

What happens if you give us specific instructions as to how to execute your order?

Where we have accepted your instructions with respect to the execution of your order, whether or not we have given you advice on any aspect of it, we will follow those instructions to the extent it is possible for us to do so.

We will not comply with our best execution obligations where we accept and follow your specific instructions when executing an order or a specific part of an order, although the Policy may apply to other aspects of the order to the extent that they are not covered by your instructions. For example:

  • Where you instruct us to execute an order for you at a particular price (for example, an instruction to subscribe for units in a fund, structured product or other securities at a specific price - we will execute the order at the specific price we have quoted to you;
  • Where you instruct us to execute your order on a particular venue, we will not be responsible for selecting the venue;
  • Where you instruct us to execute your order at a particular time or over a particular period, regardless of the price available, we will endeavour to execute your order at that time or over that period in the best possible manner but will not be responsible for the timing or any of the consequences for price or other factors that results from the timing of execution.

4. Choosing an Execution Venue

Which trading venues will we use?

For purposes of MiFID, a "venue" includes an exchange, a multilateral trading facility (i.e. a firm or market maker that creates liquidity off the exchange) and a broker. We will use a selection of venues that will be reviewed periodically.

A list of the venues/brokers we currently use appears in Annex A below and this list may be updated from time to time.

Where your order is executed through third-party brokers, we will periodically review the brokers that we use, taking into account the factors we describe below for determining the entities with which the orders are placed, or to which we transmit orders for execution, in order to ensure that the broker, or brokers, that we use are providing best execution, taking into account all orders executed during the review period.

Where it appears in a particular case that better execution is available from a broker that we do not ordinarily use, we may use such other broker on a case-by-case basis.

What factors are taken into account in determining the execution venues?

Factors that we consider in selecting the entities with which your orders are placed or to which we transmit your orders for execution in respect of a particular financial instrument include:

  • general prices available;
  • depth of liquidity;
  • relative volatility in the market;
  • speed of execution;
  • cost of execution;
  • creditworthiness of the counterparties on the venue or the central counterparty; and
  • quality and cost of clearing and settlement.

How might factors vary between choices of venue?

In some markets price volatility may mean that the timely execution is a priority. In other markets that have low liquidity, the fact of execution may itself constitute best execution. In other cases, our choice of venue may be limited because of the nature of your order or your requirements. For example, when investment products are more illiquid, there may be little (or no) choice of venue.

How often do we review our venues?

Generally, we will annually review the venues we use to execute your orders.

Where we have a choice of venues in respect of a particular order, how do we choose?

We take into account factors such as cost and benefits of accessing multiple venues and accessibility in deciding which venues we use. In some circumstances we may have access to more than one venue for executing an order in a particular financial instrument. In such cases, we will endeavour to choose the best venue for the order taking into account the factors applicable to choosing venues.

5. Monitoring and Review

We regularly monitor the order execution arrangements that we have in place including the quality of the execution obtained. We maintain an audit trail for all executed orders which assists us in ascertaining whether the best possible results have been achieved. The results of our monitoring allow us to identify and implement changes to our order execution policy and arrangements as we deem necessary.

How often will we update the Policy?

This Policy is reviewed at least annually and the Policy may also be updated periodically to take account of any applicable changes.

How can you obtain the most recent version of the Policy?

The most recent version of the Policy is published on our website, but if you would like to receive a hard copy of the Policy, please contact us in the manner described in the next section.

6. Consenting to the Policy

We are required to obtain your prior consent to the Policy as well as your prior express consent before we execute orders in instruments admitted to trading on regulated markets or multilateral trading facilities away from a regulated market or multilateral trading facility When you sign the Application Form to become a client, we ask you to confirm (in the Declarations and Signatures section) that you accept this Policy.

7. Contact Details

How do you contact us in connection with this Policy?

If you have queries about the Policy, please contact our Compliance Officer at the address below or send an enquiry via email to .

Compliance Officer
Credo Capital plc
8-12 York Gate 100 Marylebone Road
London NW1 5DX
Tel: +44 (0)20 7968 8300

ANNEX A: LIST OF EXECUTION VENUES

Detailed below is a list of the execution venues, on which we currently place significant reliance in meeting our best execution obligation. The list is not exhaustive and we may execute on alternative venues so long as such venues are appropriate and consistent with the Execution Policy.

Types of Instrument Venues/Brokers Considered
EMEA Equities, Investment Trusts, Warrants, Depository Receipts and Exchange Traded Funds/Commodities All LSE Member Firms
Click here for EMEA venues
US / Canada Equities, Investment Trusts, Warrants, Depository Receipts and Exchange Traded Funds/Commodities Click here for US/CA venues
Asia Pacific Equities, Investment Trusts, Warrants, Depository Receipts and Exchange Traded Funds/Commodities Click here for Asia Pacific venues
Collective Investment Schemes (including Unit Trusts, Open Ended Investment Companies), Hedge Funds The managers of the relevant Collective Investment Schemes
Traded Options (Exchange Traded Options only) ADM Investor Services International Ltd
Fixed income (Govt & Corporate Bonds) London Stock Exchange
All LSE Member Firms
Bridport & Co (Jersey) Ltd
Bohler & Associates
RIA Capital Markets Ltd
Valcourt Investment and Advisory Services

We believe in being an active member of both global and local communities. In particular, we believe that to give our stakeholders – employees, clients, shareholders, investors, suppliers, business partners, the communities in which we operate and the environment - the best returns, we need to set high standards of responsibility and integrity.

Our Commitments:

Leadership, Values & Ethics:
We say what we do and do what we say. We embrace our core values of honesty, integrity, trust, confidentiality, fairness and equality. Credo maintains a strong code of ethics which underpins all of our business practices.

Our People:
Employees and the Workplace. We are committed to being a responsible employer which people choose to work for. We strive to ensure that both the physical working environment and our business practices are safe and allow our people to develop and deliver their best. As a people-oriented business our focus is on the professional development and wellbeing of all our employees. We have a culture where we respect and make best use of the diversity of our people as individuals.

Clients:
Collaborating with our clients, we engage to understand their real business needs and deliver long-lasting value with tangible results. We take customer dialogue and feedback very seriously. We also look to embed corporate social responsibility and sustainability considerations into our advice and technology offers.

Communities:
Ensuring a positive impact on the communities in which we live and operate. As a an employer in various jurisdictions the Credo Group works on both national and international levels to assist and promote various charitable endeavours to support community projects. We encourage the involvement of our employees in community development.

Suppliers & Business Partners:
Working with our suppliers and business partners and committing to sound and sustainable procurement procedures, to ensure that our suppliers and business partners adhere to the same principles as we do.

The Environment:
Recognizing our impact on the environment we strive to reduce any negative environmental impact in the areas most relevant to our business, in particular energy use, travel and waste management. Long term sustainability is the key and we strive to increase employee awareness, reduce our impact and increase our positive contribution.

Our Aim and Policy Statement

Our Equality and Diversity strategy is designed to bring about cultural and organisational change both in the make-up of our workforce and the way in which we do business. We strive to provide a first-class service to all our customers, are working hard to have an enviable and highly motivated workforce and aim to seek out new business by offering innovative products and solutions that meet people's needs. Achieving this means we must demonstrate fairness and respect in all our dealings with our people, customers, shareholders, investors, suppliers and the communities in which we operate.

At Credo we believe that managing diversity is about valuing people as individuals. The scope of 'diversity' includes age, colour, disability, ethnicity, economic status, family or marital status, nationality, religious belief, sexual orientation, spent convictions, part time working, political opinion/affiliation and gender reassignment.

It also embraces the range of individual skills, educational qualifications, work experience and background, languages and other relevant attributes and experiences that differentiate us; all differences that can result in varying experiences, values, and ways of thinking, behaving, communicating and working.

At Credo we're committed to treating all our stakeholders fairly and with respect regardless of their sex, marital or family status, ethnic or national origin, nationality, colour, race, religious belief, political opinion, spent convictions, disability, gender reassignment, sexual orientation, age, or economic status. We use this ethos to shape and implement all our policies, practices and procedures, so that they comply with standards of fairness and so no one is disadvantaged by any unjustifiable conditions or requirements.

Every manager, employee and worker has a personal responsibility for complying with our policy and doing their bit to make it work. We apply the spirit of our policy to include any contact with third parties, as we do not tolerate discrimination against our customers or clients.

The Scope of this Policy

Our Equality and Diversity policy applies to all areas of our work. From our employees, job applicants, contractors, people employed through agencies to our distributors and supplier chains as well as our customers and clients.

Our commitment:

Credo is committed to providing a website that is accessible to the widest possible audience, regardless of technology or ability. We are actively working to increase the accessibility and usability of our website and in doing so adhere to many of the available standards and guidelines.

Guidelines and standards:

This website makes every effort to conform to level A of the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines which is currently the widely accepted standard for website accessibility. The W3C guidelines explain how to make web content more accessible for people with disabilities. Conformance with these guidelines will help make the web more user friendly for all people.

Exceptions:

Whilst Credo strives to adhere to the accepted guidelines and standards for accessibility and usability, it is not always possible to do so in all areas of the website.

Accessibility features:

We respect the following standards to ensure the best use of our website by all of our users.

1. Text Resizing

We understand that not everyone has '20:20' vision and that to some of you the font on our site may be too small. We have tried to ensure that all text throughout the site can be scaled up and down as you require it. In most of the modern browsers, the 'text size' option can be found in the 'view' menu in the top left of the browser window.

If you have a general problem with the size of text on websites (ours and others) there are two simple ways of increasing the size:

a) Change Operating System Preferences
You can change settings within Windows or Mac operating systems to increase the size of text used - this makes all text on your computer larger (not just websites).

b) Change Browser Preferences
You can change settings within your browser to increase the default size of "normal" text - this has the effect of enlarging the text on all the websites that you visit (provided those websites have been built in an accessible way).

  • Internet Explorer 6
    From the top menu bar, select View and set the Text size.
  • Internet Explorer 7
    From the menu bar underneath the search field, select Page and set the Text size.
  • Internet Explorer 8
    From the Change Zoom Level button on the bottom right of the Internet Explorer screen just set the desired percentage.
  • Internet Explorer 9
    From the Tools button on the top right of the Internet Explorer screen, select zoom and set the desired percentage.
  • Google Chrome, Safari, Mozilla Firefox and most other browsers
    Increase Text Size: Hold down the CTRL key and press +
    Decrease text size: Hold down the CTRL key and press –

2. Images

All images used in this website include descriptive alt tag attributes. Where an image has no use other than being decorative the alt tag is set to null to allow easy reading of the site by all users.

3. Colours

We have taken care to ensure that the website's font and background colour combinations contrast significantly and are effective in ensuring information is still clear when viewed in different colour combinations.

If you wish to override the site's colours, you can do this by changing your browser settings to your own preference.

4. Browser Compatibility

We have tried to ensure that all of the pages on this site are readable in most browsers, including mobile devices. In particular we have checked compatibility with the latest versions of the most used browsers such as:

  • Internet Explorer
  • Chrome
  • FireFox
  • Opera
  • Safari

Contact us

If you are still having problems navigating or accessing content on this site then please to get in touch with us.

If you receive an email from the Credo Group, please be aware that the email is confidential and may be privileged. Please notify us immediately if you received it in error. Do not copy it for any purpose, nor disclose its contents to any other person. No confidentiality or privilege is waived or lost by any error in transmission. The Credo Group and, where relevant, its licensors retain all intellectual property rights in all emails sent by the Credo Group.

The Credo Group does not accept responsibility for the contents of the email message as it has been transmitted over a public network. Please call us if you suspect the message may have been intercepted or amended.

Opinions, conclusions and other information in email messages that do not relate to the official business of the Credo Group shall be understood as neither given nor endorsed by it.

The Credo Group may amend this disclaimer (or any other) at any time without notice. You should check this webpage from time to time to review the current disclaimers because they are binding on you.

Credo makes no warranty as to the accuracy or completeness of the content, data or information contained in any email and hereby disclaims any liability of any kind. Any opinions expressed in an e-mail are those of the author and do not necessarily reflect the opinions of the Credo Group.

Please send any comments you may have regarding our service to .

Credo Group (U.K.) Limited (reg.no.3563602); Credo Capital plc (reg.no.3681529); and Credo Corporate Finance Limited (reg.no.3745065) are incorporated in England and Wales with their registered addresses at 8-12 York Gate, 100 Marylebone Road, London NW1 5DX. Credo Capital plc and Credo Corporate Finance Limited are authorised and regulated by the Financial Conduct Authority in the United Kingdom. Credo Capital plc is also authorised and regulated as a financial services provider by the Financial Services Board in South Africa (reg. no. FSP 9757).

The Credo Group has adopted a Bribery Policy that is consistent with the Bribery Act, 2010 (the "Act") which came into force in the United Kingdom ("UK") on 1 July 2011. It is the Credo Group policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and to implement and enforce systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, but will regard the Act as regulating our conduct both at home and abroad. We do not make and will not accept facilitation payments or "kickbacks" of any kind as they may constitute bribes under the Act. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

The Act has introduced strict liability for a corporation where it fails to prevent a bribe being paid by those associated with it, including employees and third parties such as introducers, contractors, consultants and agents.

Please advise the Credo Group's Compliance Officer (at ) as soon as possible if you are offered a bribe by a person, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity in connection with any of the services we provide to you or in connection with any goods and/or services you provide to the Credo Group.

Credo Group (U.K.) Limited (reg.no.3563602); Credo Capital Plc (reg.no.3681529); Credo Property Group Limited (reg.no.3693932); and Credo Corporate Finance Limited (reg.no.3745065) are incorporated in England and Wales and registered at 8-12 York Gate, 100 Marylebone Road, London NW1 5DX. Credo Capital Plc and Credo Corporate Finance Limited are authorised and regulated by the Financial Conduct Authority in the United Kingdom. Credo Capital Plc is also authorised and regulated as a financial services provider by the Financial Services Board in South Africa (reg. no. FSP 9757).

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