Anti-Bribery and Corruption Policy
Latitude Investment Management LLP values its reputation for ethical behaviour and for financial probity and reliability. It
recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:Setting out a clear anti-bribery policy;
Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others;
Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
Notifying all third parties that Latitude Investment Management LLP engages with of its policy and zero tolerance of bribery and/or corruption.
Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
Taking firm and vigorous action against any individual(s) involved in bribery.
The Policy
Latitude Investment Management LLP prohibits the:
any individual consultant, agent or other person or body acting on Latitude Investment Management LLP’s behalf
to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company
by any individual consultant, agent or other person or body acting on Latitude Investment Management LLP’s behalf
in order to gain any commercial, contractual or regulatory advantage for Latitude Investment Management LLP in a way which is unethical
in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual
Further Clarification
Latitude Investment Management LLP recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of Latitude Investment Management LLP or of the person or body employing or contracting with them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded :
normal and appropriate hospitality:
the giving of a gift for a corporate reason or at another special time, as long as it is reported in the proper manner within the firm on the gifts register;
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the
Compliance Officer.
Consultants and Principles Responsibility within Latitude Investment Management LLP
The prevention, detection and reporting of bribery is the responsibility of all consultants throughout the Partnership. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.
Useful resource: www.transparency.org.uk for the Transparency Index
Pillar 3 Risk Disclosure
Latitude Investment Management LLP (“Latitude” or the Firm) is required by the FCA to disclose information relating to the capital it holds and each material category of risk it faces in order to assist users of its accounts and to encourage market discipline.The Capital Requirements Directive (CRD) created a revised regulatory capital framework across Europe covering how much capital financial services firms must retain. In the United Kingdom, rules and guidance are provided in the General Prudential Sourcebook (GENPRU) for Banks, Building Societies and Investments Firms (BIPRU).The FCA framework consists of three "Pillars":Pillar 1 sets out the minimum capital requirements that companies need to retain to meet their
credit, market and operational risk;
Pillar 2 requires companies to assess whether their Pillar 1 capital is adequate to meet their risks
and is subject to annual review by the FCA;
Pillar 3 requires companies to develop a set of disclosures which will allow market participants to
assess key information about its underlying risks, risk management controls and capital position.
These disclosures are seen as complimentary to Pillar 1 and Pillar 2.
Rule 11 of BIPRU sets out the provisions for Pillar 3 disclosure. The rules provide that companies may omit one or more of the required disclosures if such omission is regarded as immaterial. Information is considered material if its omission or misstatement could change or influence the decision of a user relying on the information. In addition, companies may also omit one or more of the required disclosures where such information is regarded as proprietary or confidential. The Firm believes that the disclosure of this document meets its obligation with respect to Pillar 3.Firm OverviewLatitude is incorporated in the UK and is authorised and regulated by the FCA as an Investment Management Firm. Latitude’s activities give it the BIPRU categorisation of a “Limited License” and a “BIPRU” firm.The Governing Body of Latitude has the daily management and oversight responsibility. It generally meets quarterly and is composed of:
1. Freddie Lait
2 . Freddie Ryecart
3. James Foster
4. Patrick ValentineThe Governing Body is responsible for the entire process of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Governing Body decides Latitude’s risk appetite or tolerance for risk and ensures that Latitude has implemented an effective, ongoing process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed. Senior Management is accountable to the Governing Body for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of the Firm.Capital Resources and RequirementsCapital ResourcesPillar 1As at 30 April 2021, the Firm held regulatory capital resources of £513,567, comprised solely of core Tier 1 capital of members' capital contribution.
The Firm’s capital requirements are the greater of:
- Its base capital requirement of €50,000;
- The sum of its market and credit risk requirements; or
- Its fixed overhead requirement (FOR).
As at 30 April 2021, the Firm's Pillar 1 capital requirement was £398,880
Satisfaction of Capital Requirements
Pillar 2
The Firm has adopted the “Structured” approach to the calculation of its Pillar 2 Minimum Capital Requirement as outlined in the Committee of European Banking Supervisors Paper, 27 March 2006 which takes the higher of Pillar 1 and 2 as the ICAAP capital requirement. It has assessed Business Risks by modeling the effect on its capital planning forecasts and assessed Operational Risk by considering if Pillar 2 capital is required taking into account the adequacy of its mitigation.
Since the Firm's Internal Capital Adequacy Assessment Process (ICAAP or Pillar 2) process has not identified capital to be held over and above the Pillar 1 requirement, the capital resources detailed above are considered adequate to continue to finance the Firm over the next year. No additional capital injections are considered necessary and the Firm expects to continue to be profitable.
Risk Management
The Firm has established a risk management process in order to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the Firm's members.
As risks are identified within the business, appropriate controls are put in place to mitigate these and compliance with them is monitored on a regular basis. The frequency of monitoring in respect of each risk area is determined by the significance of the risk. The Firm does not intend to take any risks with its own capital and ensures that risk taken within the portfolios that it provides advice to is closely monitored. The results of the compliance monitoring performed is reported to the partners by the Compliance Officer.
Operational Risk
The Firm places strong reliance on the operational procedures and controls that it has in place in order to mitigate risk and seeks to ensure that all personnel are aware of their responsibilities in this respect.
The Firm has identified a number of key operational risks. These relate to disruption of the office facilities, system failures, trade failures and failure of third party service providers. Appropriate policies are in place to mitigate against risks, including appropriate insurance policies and business continuity plans.
Credit Risk
The main credit risk to which the Firm is exposed is in respect to the failure of its debtors to meet their contractual obligations. The majority of the Firm's receivable is related to investment management activities. The Firm believes its credit risk exposure is limited since the Firm’s revenue is ultimately related to management fees received from funds. These management fees are drawn throughout the year from the funds managed. Other credit exposures include bank deposits and office rental deposits.
The Firm undertakes periodic impairment reviews of its receivables. All amounts due to the Firm are current and none have been overdue during the year. As such, due to the low risk of non-payment from its counterparties, management is of the opinion that no provision is necessary. A financial asset is overdue when the 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.
The Firm has adopted the standardised approach to credit risk, and therefore follows the provision within BIPRU 3 standardised credit risk of the FCA handbook. The Firm applies a credit risk capital component of 8% to its non-trading book risk weighted exposure. As the Firm does not make use of an external credit rating agency, it is obligated to use a risk weight of 100% to all non-trading book credit exposures, except cash and cash equivalents which are held by investment grade firms and currently attract a risk weighting of 20%.
The table below sets forth the Firm's credit exposures and corresponding capital resource requirements as at 30 April 2021:
Market Risk
Since the Firm holds no trading book positions on its own account, and all bank accounts are in GBP and all advisory fee income is in GBP, the Firm’s exposure to foreign currency risk is not significant. Since the settlement of debtor balances take place without undue delay, the timing of the amount becoming payable and subsequently being paid is such that it is not considered to present a material risk to the Firm. The Firm has excluded Market risk on the basis that it is not a material risk to the Firm.
Remuneration Code
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19C of the FCA's Senior Management Arrangements, Systems and Controls Sourcebook (SYSC), as interpreted in accordance with the FCA's guidance publication entitled "General Guidance on Proportionality: The Remuneration Code (SYSC 19C) & Pillar 3 Disclosures on Remuneration (BIPRU 11)" and subsequent items of guidance issued by the FCA, including its document entitled "Frequently Asked Questions on the Remuneration Code".
As a BIPRU limited license firm, the Firm falls within proportionality level 3. The Firm has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the Governing Body sets, and oversees compliance with, the Firm's remuneration policy including reviewing the terms of the policy at least annually.
As at 30 April 2021, the Firm currently sets the variable remuneration of its partners and staff in a manner which takes into account partner and firm performance, by reference to individual performance, performance of the Firm. As permitted for firms falling within proportionality level 3, the Firm takes into account the specific nature of its own activities (including the fee based nature of its revenues) in conducting any ex-ante risk adjustments to awards of variable remuneration and, given the nature of its business, has disapplied the requirement under the Remuneration Code to make ex-post risk adjustments.
Senior management and members of staff whose actions have a material impact on the risk profile of the Firm are classified as Code Staff. In accordance with SYSC 19C, the Firm discloses that theInvestment Team received a total of £441,678 (£340,678 fixed and £101,000 variable) and the Non- investment Team received £699,140 (£619,140 fixed and £80,000 variable).
Privacy Policy
Latitude Investment Management LLP is committed to ensuring that your privacy is protected, so please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. Should you have any questions, please email us at info@latitudeim.com.
This Cookies and Privacy Policy, together with our Website terms of use and any other documents referred to in it, set out the basis on which any personal data Latitude Investment Management LLP (Latitude Investment Management LLP, us, we or our) collects from you, or that you provide to us, will be processed by us. For the purposes of the General Data Protection Regulation (‘GDPR’), the data controller is Latitude Investment Management LLP who are authorised and regulated by the Financial Conduct Authority (the FCA) and entered on the Financial Services Register with the firm identification number FRN # 774437.
What data privacy principles does the Firm adhere to:
We will process all personal data in a lawful, fair and transparent manner;
We will only collect personal data where it is necessary; for the Firm to provide a service to you; for you to provide a service to the Firm; for the Firm to keep you informed of its products and services; or for the Firm to comply with its legal and regulatory obligations.
The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
We will take all reasonable steps to ensure that personal data is accurate and, where necessary, kept up-to-date;
We will maintain personal data in a form that permits identification for no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention requirements as mandated by the Financial Conduct Authority;
We will hold and process personal data in a manner that ensures appropriate security;
We will only share personal data where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal and regulatory requirements.
We will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.
What type of information do we collect from you
In the course of providing products or services to you, we may collect information that is considered personal; we may collect and process the following information from you:
What data privacy principles does the Firm adhere to:
Information that you provide by filling in forms on our website www.latitudeim.com (our Website); e.g. your name, address, email address and phone number.
If you contact us, we may keep a record of that correspondence; and
Details of your visits to our Website and the resources that you access.
IP Addresses and Cookies
We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration purposes.
Cookies contain information that is transferred to your computer's hard drive. Cookies allow a web application to tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
This statistical data does not identify an individual. We only use this information:
to gather information on IP addresses and pages visited;
to analyse trends;
to administer the website;
to track users’ movements on the website; and
for purposes of statistical analysis.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you log on to our Website.
How do we use your personal data
We use information held about you in the following ways:
to carry out our obligations arising from any contracts entered into between you and us;
to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purpose
to ensure that content from our Website is presented in the most effective manner for you and for your computer; and to notify you about changes to our service.
We may also use your data, or permit selected third parties who work on our behalf to provide a product or a service to you;
If you do not want us to use your data in this way please indicate in the relevant box situated on the form.
How we protect your data
We take all reasonable care to ensure the security of the website and of your personal information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will not share your information other than as specified for in this Cookies and Privacy Policy or as required by law, court order or other government or law enforcement authorities.
Your right to access your information
We take all reasonable care to ensure the security of the website and of your personal information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will not share your information other than as specified for in this Cookies and Privacy Policy or as required by law, court order or other government or law enforcement authorities.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm at info@latitudeim.com. The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
As a client, you have the right to request that any information the Firm holds about you be provided to another company in a commonly used and machine-readable format, otherwise known as ‘data portability’.
You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact info@latitudeim.com.
You have the right to object to your information being processed, for example for direct marketing purposes.
You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
You have the right to object to any decisions based on the automated processing of your personal data, including profiling.
You have the right to lodge a complaint with the Information Commissioner’s Office if you are not happy with the way that we manage or process personal data.
How long does the Firm retain personal data
As a regulated entity, the Firm is required to maintain its books and records for a prescribed period (five years from either the ceasing of a business relationship, or, in the case of non-clients, from the making of a record – or alternatively, for seven years, where specifically requested to do so by the Financial Conduct Authority). As such, information that falls in scope of either of these requirements is retained in line with the mandated timeframe.
Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.
How have I been categorised in accordance with GDPR
The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. Typically, the Firm will reach out to you personally to confirm this; however, as a general rule the following is applicable:
Service providers – Information is maintained on the basis of contractual obligation.
Contact
Questions, comments and requests regarding this Cookies and Privacy Policy are welcomed and should be addressed to info@latitudeim.com
From time to time, Latitude Investment Management LLP may send you emails, email newsletters or news updates alerting you to new features, products, promotions, or services pertaining to our Website. If you no longer wish to receive materials from us and/or from such third parties, you may opt-out of receiving these communications by writing to us at Latitude Investment Management LLP, 6 Arlington Street, London SW1A 1RE or by emailing us your request to unsubscribe to info@latitudeim.com. Latitude Investment Management LLP’s Data Protection No. is ZA188320 or you can contact the ICO on www.ico.org.uk.
Our Cookies and Privacy Policy may be reviewed and enhanced from time to time. The most up-to-date version of our Privacy Policy will always available on our Website and we encourage you to check regularly or by emailing info@latitudeim.com. It may be necessary to contact you and obtain your consent regarding any significant changes to our Privacy Policy.
UK Stewardship Code Statement Summary
Latitude is an independent investment boutique set up in 2016. It manages a fundamental global equity strategy and a global absolute return strategy, with Stewardship at the core of the business.
Central to its investment philosophy is a rigorous process of fundamental research with ESG analysis fully integrated into its
research. The research process includes meeting with company management, as well as analysis of publicly available information and proprietary and independent research.
At Latitude, we consider ourselves stewards of our clients’ capital. Stewardship serves as a powerful philosophy that is focused on what really matters to our clients:
Absolute performance, sustainability and the delivery of enduring value.
Systemic problems exist in markets and Asset Owners and Asset Managers are well-placed to see problems and implement change. Stewardship is as much about responsible ownership as a considered approach to selecting investments.
As long-term investors we believe it is critical to take a holistic view of the underlying financial performance of an investment, the risk and the sustainability.
When we invest on behalf of our clients our core principles at Latitude are:
We are long-term in our approach to managing money; As active managers we look for businesses that will deliver absolute performance and create enduring value. We aim to actively own, as opposed to trade, these companies.
We seek out and support exceptional senior management teams, but hold them to account where we have concerns. We believe that responsible companies will tend to create more durable economic value. Specifically, we favour businesses that articulate compelling longterm strategies, and take seriously the irresponsibilities to their customers, workforce, local communities, the environment and their shareholders.
We are not preoccupied with short-term market movements, but look at underlying fundamentals, financial performance and sustainability. Environmental and social factors also play a material role in determining risk and return. These are considered alongside other value drivers in determining a company’s ‘investment case’ or ‘associated risks to investment”. We believe that companies’ long-term success depends on strategies that sustainably deliver goods and services, such that companies earn an attractive return on investment, maintain their license to operate and deliver improving and durable returns to shareholders.
Our core investment principles guide our approach to investment and stewardship, but we avoid hard and fast rules in implementation, preferring a pragmatic approach. We also believe that our clients’ long-term interests are not best served by a narrow focus on relative performance against a market index. Performance goes beyond beating a benchmark: positive absolute performance achieved by the market as a whole is what really matters and we aim to do so sustainably with long term consistency.
A key Stewardship policy at Latitude is the use of leverage, short selling and derivatives. These more risky portfolio management techniques were a significant factor in causing the global financial crisis in 2008 and have no place in our portfolios. There is little alignment of interest between investment managers and clients. Managers are incentivised to maximise AUM. As Stewards of our clients capital we believe portfolio managers should focus on generating added value at a reasonable cost to their end investors.
UK Stewardship Code
The UK Stewardship Code, published in July 2010, is a voluntary code which sets out a number of principles relating to engagement by investors with UK equity issuers.
Latitude welcomes the publication of the UK Financial Reporting Council (“FRC”)'s Stewardship Code and is supportive of its objectives. The Code aims to enhance engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. The Code sets out good practice on engagement with UK investee companies to which the Financial Reporting Council believes institutional investors should aspire. Through our stewardship policy, we aim to provide a robust and pragmatic framework to ensure our ownership responsibilities are exercised appropriately, that we effectively monitor the companies in which we invest for our clients and that, where we believe it is necessary, we intervene with those companies on issues that are likely to adversely impact the interests of our clients.
The principles of the Code, which is applied on a “comply or explain” basis, are that institutional investors should:
Publicly disclose their policy on how they will discharge their stewardship responsibilities.
Have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.
Monitor their investee companies.
Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.
Be willing to act collectively with other investors where appropriate.
Have a clear policy on voting and disclosure of voting activity.
Report periodically on their stewardship and voting activities.
We have set out below our approach to the recommendations of the UK Stewardship Code and explained our reasons for taking this approach. Any questions on our statement and Latitude’s approach to Stewardship should be addressed to James Foster, Chief Operating Officer at james.foster@latitudeim.com
Principle 1:
Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.We acknowledge our fiduciary duty to preserve and enhance value on behalf of our clients however as active asset managers we also believe we are stewards of our clients capital.
Stewardship goes above and beyond just investment and at Latitude we have a distinct approach whereby Stewardship and ESG considerations are integrated into every aspect of our business.
Stewardship embodies the responsible planning and management of all our resources. From the decisions made by senior management to how we invest on behalf of our clients. We believe that if the business in its entirety has adopted a Stewardship “mindset” this then filters down and effects every level of the organisation. We believe it will
then ultimately have a positive impact on how we deliver outperformance for our clients.
All investment activities and research are undertaken and monitored in-house. On the investment side Stewardship is fully embedded into our decision-making process to the extent that we believe issues may affect the long-term success of a company and investment returns. Central to our stock analysis is a rigorous process of fundamental research with ESG analysis fully integrated into our research. The logic of selecting companies based on narrow “ESG scores” and rejecting the worst, has not historically been rewarded by the markets. ESG factors are not an overlay of the process and ESG analysis
directly impact our earnings assumptions, discount rates, asset values, underlying cashflows and the long-term return on capital. Integrating ESG analysis allows for greater insight into a number of intangible factors such as operational excellence and risk that can improve investment outcomes.
We invest on behalf of a variety of clients, from direct investors in our funds to segregated mandates on an institutional basis. As we hold investments in companies on a long-term basis, we regard the process of stewardship as a natural part of our investment approach.
We aim to ensure that investee companies are conscious of all risk factors, including social and environmental risks and we believe that good robust engagement on how shareholder interest can be improved adds value to the investment chain in producing superior returns for our clients.
The goal of our stewardship activities is to support decisions that we believe will maximise the longterm value of securities we hold in client portfolios. Our fundamental analysis helps tell us how companies go about their business as well as what they actually do or produce as a business activity.
Maintaining constant dialogue with company management is central to how we discharge our stewardship responsibilities on behalf of our clients. We do this through engaging with company managements and voting proxies on our clients behalf. We also monitor all investee companies through ongoing proprietary research, third party research and written communications to discuss a range of issues relating to strategy, governance, social issues, the environment, share value,
performance, risk and remuneration. This engagement serves to confirm and support the investment thesis and establish a good ongoing channel of communication with companies to ensure that the strategy is being executed with the appropriate level of risk whilst monitoring effective control of the Board and relevant sub-committees. We believe that such monitoring provides us with a clear indication of the quality of the management and the board and consequently the company’s ability to deliver its key goals and anticipated operational performance.
Principle 2:
Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.Latitude maintains a robust policy on managing conflicts of interest which is designed to ensure its decisions are taken wholly in the interest of its clients. Latitude aims to ensure that all potential and actual conflicts are identified, evaluated, managed, monitored and recorded.
Latitude’s ownership structure is that of a private Limited Liability Partnership managing assets for a pooled investment fund and segregated managed accounts. Material potential conflicts of interest are disclosed to clients and prospective clients. Our principal objectives are always to act in the best interests of our clients and to treat them fairly.
It is the responsibility of all Latitude staff members to familiarise themselves with the contents of the Policy and report conflicts of interest to the Compliance Officer using the appropriate channels.
A summary of the Latitude’s conflicts of interest policy is attached.
Principle 3:
Institutional investors should monitor their investee companies.Comprehensive and continuous research and monitoring of investee companies is fundamental to Latitude’s investment process. This allows for greater insight into intangible factors such as operational excellence and risk that can improve investment outcomes.
Monitoring, engagement and an active use of voting rights helps deliver better performance for our clients and encourages sustainable business behaviour and lower risk.
Latitude utilises various research and support tools to meet this principle. The monitoring process will include meeting with senior management of the investee companies, analysing annual reports and financial statements, using independent third party and broker research and attending company meetings.
Latitude endeavours to identify problems at a very early stage to minimise any loss of shareholder value and we do this through direct interaction. Engagement is always undertaken by our investment team. This analysis will happen at the very start of the work we do on our investments and typically ahead of them being selected for portfolios. If the investment team has concerns, where appropriate, they will use their best efforts to ensure that the appropriate members of the investee company’s board are made aware of them. Such concerns may include societal issues where we believe they have an impact on shareholder value. These range from diversification, culture and fair employment. Environmental issues where there are concerns about future capital expenditure and the impact on climate change, pollution and fresh water. Corporate governance issues where we believe they have an impact on shareholder value. These range from disclosure, board structure, business ethics, audit, tax, reporting, executive remuneration and fees/pricing.
However, in seeking to act in the best interests of its clients, Latitude may also consider it better to reduce or eliminate an investment rather than to continue such dialogue. The Latitude investment team reviews the effectiveness of their monitoring on an ongoing basis as part of the investment process.
Latitude maintains records of votes cast and these votes are publicly available. Latitude may attend General Meetings of companies in which its clients have a major holding where this is considered appropriate and practicable.
Latitude does not generally wish to be made insiders in any circumstances, and therefore expects investee companies and their advisers to ensure that information that could affect Latitude’s ability to deal in the shares of the company concerned is not conveyed to Latitude without its prior agreement.
Principle 4:
Institutional investors should establish clear guidelines on when and how they will escalate their stewardship activities.As part of Latitude’s investment strategy, it seeks to build effective relationships with boards and management at the companies in which it invests. Latitude will generally look to invest in companies that it believes to be well managed. As part of the research and monitoring process, Latitude may look to intervene by holding meetings with management and/or directors to express Latitude’s concerns or express its views through other channels. These concerns will generally be motivated by the failure of management to uphold shareholder value and the failure to deliver products and services for the benefit of society.
Examples of recent engagement: Executive pay, remuneration, capital allocation, new share issuance, disclosure policy, cross-shareholdings, buybacks, environmental policies, pollution, shareholder value.
Latitude will continue to meet with the company and monitor developments to assess changes in the company’s approach. Should concerns persist, Latitude may seek to intervene formally through written letters addressed to the appropriate company board or committee members. In addition, Latitude will consider whether it would be more effective to intervene jointly with other institutions but will only do so where this is considered appropriate and in the best interest of its clients and where it is felt management are not maximising shareholder value.
Latitude acknowledges that it is a boutique asset manager and there are a variety of factors will make each situation unique. Therefore the approach taken to escalation of concerns will vary on a case by case basis.
Principle 5:
Institutional investors should be willing to act collectively with other investors where appropriate.Principle 5: Institutional investors should be willing to act collectively with other investors where appropriate.
Latitude is fully supportive of collective action by investors to seek change. It will however consider any specific action on a case by case basis subject to regulatory restraints, company strategy or governance.
Whilst Latitude may communicate with other shareholders regarding a specific proposal, it will not agree to vote in concert with another shareholder without approval from Latitude’s Chief Operating Officer.
We would normally pursue engagements with investee companies on our own, however as we are a emerging asset manager with a small but growing level of assets under management we believe a collaborative effort with other investors will be more effective. The extent to which we are listened to by a Board depends on a number of factors, including the power of our argument (i.e. how compelling it is); how deeply our points resonate with board directors; our size as a shareholder; and the level of shared concern of other shareholders.
A collective approach to engagement can help to ensure our concerns are listened to. These may be implemented jointly, or we may reach out to other investors to share concerns and seek a common position, which we may decide to communicate to a company.
We are also an active participant in a number of investor bodies such as the UK Investment Association, the board of the New City Initiative (NCI) and the United Nation’s Principles for Responsible Investment (UNPRI). Through these initiatives, we discuss and work with other investors on a range of collective engagement opportunities, including in the UK.
In participating in collaborative initiatives we remain alert to potential conflicts, issues of insider information and concert party rules. Where we believe there are any potential risks of falling foul of these rules, we ensure close involvement of our internal legal and compliance team.
Principle 6:
Institutional investors should have a clear policy on voting and disclosure of voting activity.
Latitude maintains proxy voting policies and procedures that are designed to ensure that it makes a best efforts attempt to vote proxies in the best interests of its clients and will always seek to vote all of its shares. We publicly disclose all our voting activity.
Latitude generally votes in favour of routine corporate housekeeping proposals, including election of directors (where no corporate governance issues are involved).
For other proposals, Latitude will assess what is in the best interests of its clients and, in doing so, may take into account the following factors:
whether the proposal was recommended by management and Latitude’s opinion of management;
whether the proposal fairly or unfairly compensates management for past and future performance;
While we are boutique and our voice is small there is a willingness to speak out and to use our vote wisely to support engagement.
Securities lending programs can reduce the level of voting activity as the exercise of voting rights may be hampered when securities are on loan at the time of a shareholders meeting. As an engaged shareholder, Latitude believes it is in the best interest of investors to execute voting rights where possible and therefore, Latitude does not participate in securities lending programs,
Principle 7:
Institutional investors should report periodically on their stewardship and voting activities.
Our stewardship activities are an integral part of how we manage money for our clients. Latitude believes that there must be an appropriate level of transparency designed to promote effective stewardship and assist the analysis and evaluation by asset owners.
We report regularly to clients on our stewardship activities in meetings and through our quarterly and annual reports. Our reports to clients include details of selected company engagements, voting activities, as well as updates on market-wide policy outreach.
Where acting as investment manager to a pooled fund, Latitude may provide to such underlying investors summary details of how it has voted.
In addition, Latitude may, on request, provide other details of its engagement approach and activities (such as number of company meetings held or examples of any concerns raised) to clients and underlying investors.
Latitude’s processes relating to its corporate governance activities are included within the scope of annual internal controls. The results of such testing are not generally made available but clients wishing to obtain further information should contact Latitude’s Chief Compliance Officer, Freddie Ryecart.
Information about Latitude’s Conflicts of InterestThis document is not intended to provide a comprehensive account of the controls and procedures in place to manage all conflicts of interest which may arise; it is intended to outline the main controls in place. We are committed at all times to ensuring that our business is conducted to high standards and in an ethical manner.
Introduction
The purpose Conflicts of Interest Policy for Latitude Investment Management LLP (“Latitude”) is to identify the circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of clients and to specify procedures to be followed and measures to be adopted in order to manage such conflicts.
Identifying Types of Conflicts of Interest
Latitude takes all appropriate steps to identify conflicts of interest between: Latitude and a client of the Firm; or One client of Latitude and another client that arise or may arise in the course of the Latitude providing any services in the course of carrying on regulated activities. The purpose of identifying the types of conflict that arise in the course of providing a service,
and, where there may be a material risk of damage to the interests of a client.
Arrangements for managing conflicts
Governance - Latitude has robust governance arrangements. Latitude has rules in place to govern employee conduct, including PAD rules which control and mitigate conflicts of interest.
Reporting Lines - Latitude has defined and clear reporting lines.
Segregation of Functions - Segregation of functions are met by segregating duties, as appropriate, to avoid conflicts of interest wherever possible.
Disclosure of Personal Conflicts - Employees and owners are required to disclose conflicts of interest.
Disclosure to Clients - If Latitude’s arrangements to manage a conflict of interest are not sufficient to ensure, with reasonable confidence, that the risk of damage to that client’s interests is prevented, Latitude is required to inform the client, in a durable medium, in order to allow them to take an informed decision before business is undertaken.
Restricted List and Insider List - In order to facilitate the monitoring of conflicts, Latitude maintains a global Restricted List and an Insider List.
Inducements – Latitude has a gifts and entertainment policy.
Recruitment - Latitude considers the fitness and propriety of all potential new employees.Training - Compliance training regarding conflicts of interest forms part of the annual training needs analysis.
Management Information - Management information regarding the identification of conflicts is reviewed.
Remuneration - Latitude’s remuneration policy is designed to avoid rewarding behaviour that could lead to disadvantage for its clients.
Conflicts Monitoring - Potential conflicts of interest are considered on an ongoing basis. In cases where a conflict is identified, a decision is made as to whether to proceed with the new client and, if so, what additional measures should be taken to mitigate the conflict. All such decisions are documented and are based on the nature of the conflict and the potential
for the conflict to entail a material risk of damage to the interest of one or more clients.
Terms & Conditions
This page (together with the documents referred to on it) tells you the Terms and Conditions of Use (Terms of Use) on which you may make use of this website www.latitudeim.com (the Website).Please read these terms of use carefully before you start to use our Website. By using our Website, you indicate that you accept the Terms of Use and that you agree to abide by them. If you do not agree to the Terms of Use, please refrain from using our Website.
1. Information about us
1.1 We are a limited liability partnership registered in England and Wales at Companies House under the name Latitude Investment Management LLP (we, us, our, and Latitude Investment Management LLP). Our registered office is at 6 Arlington Street, London SW1A 1RE and our company number is OC411255.
1.2 Latitude Investment Management are authorised and regulated by the Financial Conduct Authority.1.3 If you have any queries about the Website or any information contained on it, please contact us at 6 Arlington Street, London SW1A 1RE or by telephone on + 44 (0)20 7087 9270; or by email info@latitudeim.com
2. Accessing our website
2.1 Access to our Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our Website without notice. From time to time, we may restrict access to some or all of our Website. We will not be liable if for any reason our Website is unavailable at any time or for any period.
2.2 If you breach these Terms of Use, your permission to use the Website terminates immediately and you must immediately destroy any downloaded or printed extracts from the Website.
2.3 You are responsible for making all arrangements necessary for you to have access to our Website.
2.4 By accessing our Website any person using your computer agrees to be bound by these Terms of Use. You are responsible for ensuring that all persons who access our Website through your internet connection and on your computer are aware of these Terms of Use and that they comply with them. You are also responsible for the use of our Website by any person using your computer.
3. Disclaimer
3.1 Nothing on this Website is intended, nor should it be taken, to create any legal or contractual relationship. Any transmission, downloading or sending of any information from the Website does not create any contractual relationship.
3.2 The content of the Website is designed for information purposes only. Neither the information nor any opinions stated in the Website constitutes a solicitation or offer by Latitude Investment Management LLP to buy or sell any securities or other financial instruments or to provide any investment advice.
3.3 The provision of investment services may be restricted in certain jurisdictions. It is your responsibility to acquaint yourself with any local laws and restrictions on the usage of this Website and the availability of any services described on it. The information on this Website is not intended for distribution to or use by any personal entity in any jurisdiction or country where such distribution would be contrary to local law or regulation. The Services are available only to persons in the United Kingdom and other European Economic Area countries. The Services are not available to United States persons directly, unless introduced to Latitude Investment Management LLP by a FINRA registered broker or their United States attorney.
3.4 Nothing in this Website may be published in the press or elsewhere without permission of Latitude Investment Management LLP.
3.5 Latitude Investment Management LLP does not provide legal or tax advice. Clients of Latitude Investment Management LLP and viewers of this Website are encouraged to consult their own legal and tax advisers before making any investment decision. Private companies in all jurisdictions and potential investors should take independent legal and taxation and investment advice before proceeding with any type of fund raising activity.
3.6 While we endeavour at all times to ensure information on our Website is clear, fair and not misleading at the date of publication, we do not hold the information as impartial and it should not be viewed as wholly objective. Information on this Website is based on sources that we believe to be reliable but we give no undertaking that it is accurate or complete and Latitude Investment Management LLP cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose or at all.
3.7 The contents of this website are subject to change without notice and Latitude Investment Management LLP is under noobligation to report updates and amendments or keep information accurate.
3.8 This Website is controlled and operated by Latitude Investment Management LLP in the United Kingdom. We make no representations that materials in the Website are appropriate or available for use in other locations. Those who choose to access the Website from other locations do so at their own risk and are responsible for compliance with all applicable laws.
4. Intellectual Property Rights
4.1 This Website, its contents, any materials downloaded, and all intellectual property pertaining to or contained on the Website (including but not limited to copyrights, patents, database rights, graphics, designs, text, logos, trade dress, trademarks and service marks) are owned by or licensed to us and/or from third parties and all rights, title and interest in them shall remain the property of Latitude Investment Management LLP and/or such third parties (collectively, the Content).
4.2 The Content is protected by copyright, patent and trademark laws, and various other intellectual property rights and unfair competition laws.
4.3 You are permitted to print copies and download extracts of the content on the Website for your own personal use for information purposes only, and may draw the attention of others within your organisation to material posted on the Website, subject to the following conditions:
4.3.1 our status (and that of any identified contributors) as the authors of material on our Website must always be acknowledged;
4.3.2 you must not modify in any way the paper or digital copies of any materials you have printed off or downloaded, and you must not use any illustrations, photographs, video or audio sequences or graphics separately from any accompanying text;
4.3.3 you must not duplicate, copy, publish, modify, create derivative works from, participate in the transfer of, post on the internet, or in any way distribute, redistribute or exploit the Website, or any portion of the Website, for any public or commercial use without our express prior written consent;4.3.4 you must not otherwise use any part of the Website in contravention of these Terms of Use.
4.4 If you print off, copy or download any part of the Website in breach of these Terms of Use, your right to use the Website will cease immediately and you must, at our option, return to us or destroy any copies of the materials you have made.
5. Unlawful or prohibited use
5.1 We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, trojans, worms, logicbombs or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.
5.2 You must not misuse our Website by knowingly or recklessly introducing viruses, trojans, worms, logic bombs or any othermaterial which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack.
5.3 Any such unauthorised use of our Website may give rise to a claim for damages and/or be a criminal offence under the Computer Misuse Act 1990. We will report any such activity to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately and without further notice.
6. Privacy
6.1 Our Privacy Policy applies to use of our Website, and its terms are made a part of these Terms of Use by this reference.
6.2 Additionally, by using our Website, you acknowledge and agree that internet transmissions are never completely private or secure. You understand that any message or information you send to our Website may be read or intercepted by others, notwithstanding our efforts to protect such transmissions. We are not responsible for any messages which are lost, altered by third parties or intercepted and we will not be liable to you or anyone else for any damages or otherwise in connection with any message sent by you to us or by us to you via the internet.
6.3 Our Website makes use of cookies. Cookies are files which our server uses to identify your computer. Cookies cannot identify which person is using the computer. The cookies we use record which parts of our Site are being visited and for how long.
6.4 The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 requires that cookies can only be placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first access our Site. We require you to indicate your choice via an automated pop-up box, which explains the cookies we use and what we use them for. Most web browsers automatically accept cookies, but you can also usually modify your browser setting to decline cookies if you prefer. If you decline to accept our use of cookies or set your web browser to decline their use, you will have only limited functionality in the use of our Site. Our Privacy Policy contains further guidance on our use of cookies.
7. Exclusion of liability
7.1 The material displayed on our Website is provided without any guarantees, conditions or warranties as to its accuracy, originality or completeness. To the extent permitted by law, we and third parties connected to us hereby expressly exclude:
7.1.1 all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity;
7.1.2 any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in connection with the use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it, including:(a) loss of income or revenue;(b) loss of business;(c) loss of profits or contracts;(d) loss of anticipated savings;(e) loss of data;(f) loss of goodwill;(g) wasted management or office time; and(h) any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.
7.1.3 In jurisdictions which do not allow the exclusion or limitations of certain types of liability, Latitude Investment Management LLP liability will be limited to the maximum extent permitted by law.
7.2 Nothing in these Terms of Use limits or excludes our liability for death or personal injury arising from our negligence or any other liability which cannot be excluded or limited under applicable law.
8. Indemnity
8.1 By using our Website, you agree to indemnify and hold harmless Latitude Investment Management LLP from and againstany and all losses, claims, damages, costs and expenses (including reasonable legal and accounting fees) that Latitude Investment Management LLP may become obliged to pay, arising or resulting from your use of our Website, the Content, or your breach of these Terms of Use. Latitude Investment Management LLP reserves the right to assume or participate, at your expense, in the investigation, settlement and defence of any such action or claim.
9. Links to third party websites
9.1 Our Website may contain links to websites and resources maintained by third parties. These links are provided for yourinformation only. We have no control over the contents of those websites and resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. We are not responsible for the content, availability or privacy policies of those sites, and the existence of such links should not be considered an endorsement or recommendation of those sites or of any product or service offered on those sites or of any party that is associated with those sites.
9.2 Please note that other websites and resources linked to on our Website may be governed by separate terms and conditions,including privacy policies. You should refer to the applicable terms and conditions of those websites and resources before using them and you should direct any questions or comments about the linked website or resource to the appropriate website provider.
10. Linking to our Website
10.1 You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
10.2 You must not establish a link from any website that is not owned by you.
10.3 Our Website must not be framed on any other website, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice.
10.4 If you wish to make any use of material on our Website other than that set out above, please address your request toinfo@latitudeim.com.
11. Revision of terms
11.1 We may revise these Terms of Use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our Website.
12. Jurisdiction and Applicable law
12.1 The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our Website. We retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country.
12.2 These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation(including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.
13. Miscellaneous
13.1 Any failure by Latitude Investment Management LLP to exercise any rights or enforce any of these Terms of Use shall notconstitute a waiver of such rights or terms.
13.2 If any provision of these Terms of Use or their application in a particular circumstance is held to be invalid or unenforceable to any extent, the remainder of these Terms of Use, or the application of such provision in other circumstances, shall not be affected thereby, and each provision of these Terms of Use shall be valid and enforced to the fullest extent permitted by law.
13.3 These Terms of Use (together with any documents referred to in them) constitute the entire agreement between you and Latitude Investment Management LLP with regard to your use of our Website, and any and all other written or oral agreements or understandings previously existing between you and Latitude Investment Management LLP with respect to such use are superseded and cancelled.
14. Your Concerns
14.1 If you have any concerns about any material which appears on our Website, please contact info@latitudeim.com