The information contained in this website is being issued by Craigmore Sustainables LLP (“CSLLP”), which is authorised and regulated by the Financial Conduct Authority in the United Kingdom (FRN 535871).
None of the information published or made available via this website is intended to be published or made available in any jurisdiction where to do so would result in the breach of any applicable law or regulation in that jurisdiction. This website is not directed at you if we are prohibited by any law of any jurisdiction from making the information on this website available to you.
The information published or made available via this website has been compiled from sources believed to be reliable but no warranty, expressed or implied, is given that the information is complete or accurate nor that it is fit for a particular purpose. All such warranties are expressly disclaimed and excluded. Any opinions, recommendations and forecasts provided are not necessarily the current opinions, recommendations and forecasts of the contributors and may be changed at any time.
As with all investments, our products place capital at risk. There is no guarantee that the target return will be achieved, and investors may get back less than the amount they invested. Past performance and forecast are not a reliable indicator of future performance. Any tax reliefs referred to may be subject to change and tax treatment will depend on the individual circumstances of the investor. CSLLP does not provide investment or tax advice, and information on this website should not be construed as such. Potential investors should seek specialist independent tax and financial advice before investing in any alternative investment. Nothing on this website constitutes an offer, or invitation to treat, or inducement for you to engage in any investment activity.
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, CSLLP is required to include on its website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is voluntary and sets out a number of principles relating to engagement by investors with UK equity issuers.
The Code is directed in the first instance to institutional investors by which is meant asset owners and asset managers with equity holdings in UK listed companies. Whilst CSLLP is supportive of the objectives that underlie the Code, it has chosen not to commit to the Code. CSLLP does not currently invest in UK listed companies. CSLLP acts as an investment manager which invests in non-listed real assets,
Although CSLLP seeks to align its approach with the broad aims of the Code, the provisions of the Code are primarily not relevant to the type of investment activity currently undertaken by CSLLP. Should any of those factors change, CSLLP will review its commitment to the Code at that time and make appropriate disclosure.
The Craigmore Remuneration Policy (the “Policy”) sets out CSLLP’s policy regarding its remuneration policies and practices, as subject to certain regulatory requirements under the Directive 2011/61/EU as amended (the “AIFMD”) or equivalent legislation. The Policy describes how CSLLP’s remuneration policies and practices are consistent with the principles in the AIFMD and equivalent legislation. CSLLP aims to ensure that its remuneration policies and practices encourage sound and effective risk management and align financial incentives for staff with the risks undertaken and rewards achieved by investors in the funds managed or advised by Craigmore. Compensation may include a variety of components and may vary from year-to-year based on a number of factors. The principal components of compensation include fixed base compensation and variable discretionary compensation. The risk-limiting features of the Policy include (amongst other things) the application of non-financial metrics, such as an assessment of compliance with the Firm’s risk management and compliance policies. In extreme cases, a negative assessment of overall compliance by an individual with the Firm’s risk management and compliance policies may result in a reduction in the variable remuneration amount which would otherwise have been awarded to that individual. The Policy is reviewed at least annually.
Although CSLLP has taken all reasonable care that the information contained within this website is accurate at the time of publication, no representation or warranty (including any liability towards third parties), expressed or implied, is made (or accepted) as to its accuracy or completeness or fitness for any purpose by CSLLP or any of its affiliates or contractual partners. Under no circumstances will CSLLP or any of its affiliates1 be liable for any direct, indirect, incidental, special or consequential loss or damages caused by reliance on this information or for the risks inherent in the financial markets.
To the maximum extent permitted by applicable law and regulatory requirements, CSLLP specifically disclaims any liability for errors, inaccuracies or omissions on its website and for any loss or damage resulting from its use, whether caused by negligence or otherwise. Viewers agree to assume responsibility for determining whether any legal or regulatory considerations limit access to or use of information, services or products described on this website and for the use of any information on such website.
This website may contain or be linked to websites, advice or statements of third parties, and such links are for information purposes only. CSLLP makes no representation as to the accuracy or timeliness of such information, has not and will not review or update such information and so does not take responsibility for the contents of such other websites. CSLLP cautions that any use made of such information (or links to such information) is at the user’s own risk.
Units or any other investment instrument in any fund or investment proposition managed by CSLLP (or any other member of the CSLLP group) have not been and will not be registered under the US Securities Act of 1933 for offer or sale and such units or instruments public have not been and will not be registered under the US Investment Company Act of 1940. No offer to sell securities in the USA or elsewhere is made, nor is an offer to purchase securities solicited, by this website.
This website is only available to persons who do not fall within the definition a “U.S. Person” within Regulation S.
Units or any other investment instrument in any fund or investment proposition managed by CSLLP (or any other member of the CSLLP group) are not registered for sale in Australia, Canada, Hong Kong or Singapore.
As a general rule, the Units or any other investment instrument in any fund or investment proposition managed by CSLLP (or any other member of the CSLLP group) may not be sold, offered or delivered in any other countries without registration. The information contained on this website is therefore not directed at specific persons, but to readers generally interested in the Craigmore group.
Access to the information contained within this website may be restricted by laws and regulations applicable to the user. The information in this website does not constitute either an offer to sell or a solicitation or an offer to buy in a country in which this type of offer or solicitation is unlawful, or in which a person making such an offer or solicitation does not hold the necessary authorisation to do so, or at all. Accordingly, persons accessing the information on this website are responsible for ascertaining the legal requirements which would affect their acquisition of any investment, including any foreign exchange control requirements.
This website is intended for those who access it from within the United Kingdom. Because of this we cannot guarantee that the website, or the information thereon, complies with the local laws or regulations of, or is appropriate for use in, any other jurisdiction other than the United Kingdom. If you choose to access the website from a jurisdiction other than the United Kingdom you do so at your own risk and CSLLP will not be liable for any breach of local law or regulation that you commit as a result of doing so.
The website may include information related to unregulated collective investment schemes that may not be marketed to the retail public.
The parts of the website relating to unregulated collective investment schemes are directed only at persons who (1) are authorised under the UK Financial Services and Markets Act 2000 or are otherwise “Investment Professionals” within the meaning of Article 14(5) of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001, (2) who are otherwise categorised as eligible counterparties or professional clients for the purpose of Section 4 of the Conduct of Business Sourcebook of the Financial Conduct Authority’s Handbook of Rules and Guidance (”permitted recipients”) or (3) are persons outside the United Kingdom (all such persons together being referred to as “relevant persons”).
The sections of the website relating to unregulated collective investment schemes are not designed for, and the services of CSLLP relating to unregulated collective investment schemes are not available to, persons of any other description and such persons should not rely on any information contained within these sections of the website. Should you be in any doubt about your status, you should not access these sections of the website and should consult an independent financial adviser who specialises in providing advice on participation in unregulated collective investment schemes.
Risk Management Objectives
The Firm is governed by its partners who determine its business strategy and risk appetite. The Partners are also responsible for establishing and maintaining the Firm’s governance arrangements along with designing and implementing a risk management framework that recognises the risks that the business faces.
The partners also determine how the risks the business faces may be mitigated and assess, on an ongoing basis, the arrangements put in place to manage those risks. They meet on a regular basis and discuss current projections for profitability, cash flow, regulatory capital management, business planning and risk management. They manage the Firm’s risks having regard to relevant laws, standards, principles and rules (including principles and regulations set by the FCA) with the aim to operate a defined and transparent risk management framework. These policies and procedures are updated as required.
The partners of the Firm place a high priority on a strong risk management culture. The partners recognise that risk is inherent to their business and the market in which they operate. The Firm has a low risk appetite in respect of the risks highlighted above and this is reflected in its governance and controls. There is an experienced management team of proven ability to ensure that the business remains tightly controlled within the standards that the Firm aspires to.
The partners have identified that investment, credit, market and operational risks are the main areas of risk to which the Firm is exposed. Periodically the senior management of the Firm formally review risks, controls and other risk mitigation arrangements and assess their effectiveness. Where the Firm’s senior management identify material risks they consider the financial impact of these risks as part of its business planning and capital management and conclude whether the amount of regulatory capital held is adequate.