Legal Information

Important information regarding the use of this website:

By using this website you agree to these terms and conditions. If we amend or update these terms and conditions, which we may do without giving you any notice. Your continued use of the website indicates your continued acceptance of the amended terms and conditions. If you do not agree to accept and be bound by these terms and conditions you should not use this website and should exit it immediately.

The information on this website has been carefully prepared, and it is believed to be accurate when published. We make no representations, warranties or undertakings as to the accuracy of the content or our website or as to whether any information you download is virus or error free. We cannot accept any liability for any damages whatsoever arising to you as a result of your use of our website.

There are certain legal and regulatory limitations that apply to the information contained on this website. By proceeding to use this website you are deemed to have understood and accepted these terms and conditions.

It also indicates your acknowledgement of the Regulatory Information.

There may be occasions during which our website becomes unavailable, through no fault of our own. We may take our website offline to enhance and update it.

Intended audience:

RM Capital Markets Limited (“RM Funds”) is authorised and regulated by the Financial Conduct Authority in the United Kingdom. Unless specifically identified otherwise, all information and any of the funds managed by RM Funds is intended solely for UK professional investors.

In particular, none of the information in this website is intended for use by any person outside of the United Kingdom, unless specifically identified otherwise.

The information in this website does not in any way constitute investment, legal, tax or other advice. Before making any investment you should read, understand and retain the relevant investment product or service documentation. You should remember that past performance of an investment is not a guide to future performance. If you are in any doubt about any of the information on this website, or the suitability of any investment service or product to your needs, please speak to your financial or other professional adviser.

In particular, RM Funds’ products or investment services may not be suitable for private investors. Private investors should not access this website and should consult their financial or other suitably experienced or qualified advisor.

Privacy and cookies

We may collect and use personal data about you in accordance with our Privacy Notice. We may use cookies in accordance with our Cookies Policy.

Intellectual Property

Recording of calls

For the protection of all parties, your telephone calls may be recorded. Where calls are recorded, they will be retained for a period of five years.

Links to other websites

We do not endorse, sponsor or approve any other website. Any links to any such website are solely for your convenience.

Viruses etc

You must not transmit any virus, ‘worm’, ‘Trojan horse’, or other item of a destructive nature to this website and it is your responsibility to ensure that whatever you download or select for your use from the website is free from such items.

Governing law

This website shall be governed by, and your browsing in and use of the website shall be regarded as a deemed acceptance of, English law. A condition of using this website is that, in the event of any dispute or proceeding, you irrevocably submit to the exclusive jurisdiction of the English Courts.

Each time you use the site, a condition of use is that you comply with the above terms.

Regulatory Information

Important Regulatory Information:

Please read this section which contains the legal and regulatory restrictions which apply to any investment in our products or services referred to in this website.

The information contained in this site has been compiled with considerable care to ensure its accuracy at the date of publication. However, no representation or warranty, express or implied, is made to its accuracy or completeness. Nothing in this information or elsewhere in this website shall exclude, limit or restrict our duties and liabilities to you under the Financial Services and Markets Act 2000 or any conduct of business rules with which we are bound to comply. Any research or analysis contained in this website has been procured by RM Capital Markets Limited (“RM Funds”) for its own use and may be acted on in that connection. It is provided to you only incidentally, and any opinions expressed are subject to change without notice.

The information on this website does not in any way constitute investment, tax, legal or other advice. If you are in any doubt about any of the information on this website please consult your financial or other professional adviser.

RM Capital Market Limited is authorised and regulated by the Financial Conduct Authority with company number SC380707 and FCA number 562209. You can access the Financial Services Conduct’s register on the FCA website for more information.

RM Capital Markets Limited has its registered office at 4^th Floor, 7 Castle Street, Edinburgh EH2 3AH.

Engagement Policy

We believe that constructive engagement and working with management teams to support them in making improvements is a key part in delivering on our responsible investment approach and is our preferred route to delivering on our mission to make a difference through investing in, and working with, businesses with strong underlying potential to create value. We will conduct engagement with our investee companies in accordance with our Voting, Engagement and Escalation Policy, a copy of which is available on request.

UK Stewardship Code

RM Funds is supportive of the UK Stewardship Code but does not consider it necessary to commit formally to the Code at the present time.

Privacy Statement

This policy describes the information that we collect from you using this website, why we collect it, and your rights under the Data Protection Act 2018 and General Data Protection Regulation.

Use of Your Information

Before entering into an agreement with us to obtain our services:

You will be required to provide us with certain information about you which is necessary for the purpose of entering into the agreement with you and for the purposes set out below and, in our terms, and conditions. If, for whatever reason, you fail to provide us with the information we require, we will not be able to proceed with Know Your Customer (“KYC”) checks and, consequently, will not enter into the agreement with you.

We may obtain information about you from credit reference and fraud prevention agencies to assist with our legitimate interest of assessing KYC. This search will not leave a “footprint” on your credit file.

We may collect and process the following data about you:

Information that you provide by filling in forms on our website, which includes information provided at the time of registering to use our website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our website.
If you contact us, we may keep a record of that correspondence.
Information that you may provide to us in relation to the prospect of entering into business with us.
Information that you may provide to us in relation to business operations with us including name, address, email address etc.

Marketing

We may use your personal data for marketing purposes. If you wish to stop receiving any marketing materials from us, please inform us and we will use all reasonable endeavours to remove your details from our database.

How we use your personal information

Personal data collected by us will be used by us when we first engage with you as a potential client, after we have entered into any agreement with you and after the agreement has ended. We may use this information to:

Provide services to you.
Verify your identity.
Comply with legal, regulatory and compliance obligations that apply to us (for example, anti-money laundering and counter-terrorism checks, or in relation to the detection and prevention of fraud and other crimes).
Report on any services we provide to you.

We shall retain your information for no longer than is necessary for the purposes set out above whereupon it shall be removed from our records.

Security

The security of your Personal Information is important to us. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. Please contact us if you have any questions about the security of your personal information.

Other Websites

This privacy policy only covers this website. Any other websites which may have links to or from our website are subject to their own policy, which may differ from ours.

Changes to this policy

We may update this privacy policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.

Cookies Policy

Our website uses a number of cookies to gain access to, and store data on, our visitors’ computers. For more information about cookies and what they are used for, please see www.aboutcookies.org. The following is our position in relation to current cookies in use on our website, and how we store and use them.

First Party Cookies

First-party cookies are used to monitor how our clients and visitors find and use our website. We report on this activity in aggregate and use this information solely for the purposes of improving the monitoring and functionality of our website.

Session ID (PHPSESSID) – We use these to keep track of movement from page to page, so that a user does not get asked for the same information that they have already given to our site.
Consent cookies – These are used to keep track of whether or not the user has granted consent for cookies to be stored on their computer.

Third Party Cookies

Third party cookies are cookies created by another party external to RM Funds, when a user accesses a page on our website. These cookies are specific to the third-party’s domain and accordingly the data held in them can be seen and managed by the third party, and not by us. We control whether or not we use the third-party service with our website, and how it is integrated and presented on our website. We do not, however, have control over the content or the cookies themselves, the use made of them or the security of that data once held by the third party.

These third parties may collect information about a visit to our website, and they may then use this along with other data in order to serve advertising which may be more relevant to a user and their interests.

We believe there is no reason for our website visitors to be concerned about the privacy implications of any of the cookies we use, but we do understand that clients may need to be made aware of the intention and scope of data stored in the cookies, which are created or updated on their computer when they visit our website. Visitors always have the option to delete these cookies from their computer between visits to our website if desired.

If you have concerns about the privacy implications of the cookies we use, then we recommend you manage your cookie settings using the cookie management tools in your web browser.

Conflicts of Interest Policy

What are the general requirements with regard to Conflicts of Interest?

RM has a duty to avoid conflicts of interest arising or, in circumstances in which such conflicts do arise, to ensure fair treatment of clients. Importantly, RM must not unfairly place its own interests above those of its clients. It is therefore essential that any conflicts of interest are identified and managed appropriately.

Conflicts are best handled early in the context of a client relationship or in any transaction. All members of staff must be alert to potential conflicts of interest both actual and those matters that a client might perceive as such. Consideration should be given to actual or potential conflicts at the time the client is taken on.

A conflict of interest may arise between the firm and a client, or between one client and another, or in some combination of these situations.

Once a conflict has been identified, it must be brought to the attention of the CIO and the Compliance Officer. On some occasions, RM may have to decline to act because of a conflict on other clients. A combination of appropriate disclosure and allocation of staff may allow the transaction or situation to proceed. Where RM relies on disclosure, it is important that the disclosures are documented (initial disclosure, particularly with any client(s), may be oral but should be followed up in writing).

Where a conflict is difficult to resolve it is important to involve Senior Management. In extreme cases, if a member of staff has disclosed concerns but is not satisfied with the way in which they are being acted upon, he or she has the right to “blow the whistle” – see the Whistleblowing Policy for details.

What is RM’s Policy?

RM Group’s policy is to follow FCA’s guidelines regarding the management of conflicts of interest by taking one or more of the following steps if required:

disclosure of an interest to a customer;
relying on a policy of independence;
establishing internal arrangements (Chinese Walls); and/or
declining to act for a customer.

Are we required to disclose an interest to a client?
At all times the RM must be able to demonstrate that it has taken reasonable steps to ensure that the customer does not object to that material interest or conflict of interest and this, where appropriate, should be evidenced in writing. RM will comply with all requirements in this regard.

What is the policy of independence?

In exceptional situations when it is not practical to act in accordance with the disclosure policy RM ensures fair treatment for its customers by relying on a policy of independence.

An independence policy is designed to ensure that in providing services to clients, RM employees act independently of any interest which may conflict with the duties owed to different clients or between the firm and its clients.

Where conflicts are significant, the independence policy may not of itself be sufficient to ensure fair treatment for clients. In these circumstances it may be necessary to take other appropriate steps such as the establishment of a Chinese Wall, specific disclosure of an interest to the client, reallocating responsibilities, ceasing to act, or some combination of any of these.

RM employees must comply with the following independence policy.

All members of staff must disregard any of the interests described below and must not allow the existence of such interests to influence them when dealing with clients or potential clients:

any personal interests which they or members of their family may have. Where appropriate, a client should be advised of such an interest, notwithstanding this policy;
any existing, proposed or prospective business relationship between any member of the RM Group and any third party;
any agreement or transaction which has been, will or may be, entered into by any member of the RM Group;
the holding by, interest or position of any member of the RM Group in any investments issued by the client or any third party.

It is important to note that the examples above are not exhaustive. Employees are reminded that they are required to consider conflicts of interest and the need to act independently of such conflicts at all times. For further information contact the Compliance Officer.

When should we decline to act for a client?

In the event RM determines that it is unable to manage a conflict of interest using one of the methods described above, it should decline to act on behalf of a new customer. The decision to do so must be made by those responsible for managing conflicts (as outlined in the allocation of responsibilities) who may seek guidance or help from the CIO or Compliance Officer.

Does any of this affect the acceptance of Directorships and consultancies?

RM employees are not allowed to accept directorships or other positions in any company outside the RM Group, nor to carry out any consultancy work for any company or person, without the prior written consent of the CIO of RM.

Personal Dealing

These rules are covered in the Personal Account Dealing Policy.

Gifts and Hospitality

These rules are covered in the Gifts and Hospitality Policy.

Order Execution and Allocation Policy

This policy is the “order execution policy” for the purposes of the Financial Conduct Authority (“FCA”). It also sets out RM’s approach to order aggregation, allocation and narrates the approach RM will take to providing best execution to its clients across fund asset classes.

Best execution is the process to be followed to achieve the best trading outcome for the RM Clients, for whom RM provides investment management services. This service involves executing investment decisions, including trading in financial instruments, investing in direct property and making loans. This policy sets out the approach to delivering RM’s aim of consistently executing deals on the best terms for the RM Clients in the asset classes they invest in, as well as how trades to the RM Clients are allocated. To deliver this, various factors have to be balanced, some of which may conflict.

The RM Clients are funds investing in equities, direct property and loans on behalf of underlying UK and international investors, including potentially pension funds, government agencies, financial and other institutions, wealth managers, family offices, financial advisers and individual investors, although RM will not act directly for retail clients. In relation to the equities funds for which RM is fund manager, RM must take all sufficient steps to obtain, when executing orders, the best possible results, taking into account its execution factors. It is RM’s policy to apply this standard to the other funds it manages, to the extent consistent with relevant fund’s strategy or the asset class in which those funds invest.

The consistent delivery of the best possible result when executing client orders is called “Best Execution”. RM will always act in the best interests of the RM Clients in providing Best Execution.

When executing orders (either directly or by instructing third parties to execute orders on RM’s behalf), RM must ensure that it consistently obtains the best possible results, taking into account the different execution factors so far as they apply to each strategy and asset class. The process by which RM delivers Best Execution will vary from strategy to strategy and asset class to asset class and this policy intends to describe what those factors are, how they are ranked and how they will provide best execution to clients in each strategy and asset class.

The RM individual managing the relevant RM Client will oversee which venues are most likely to provide the best possible outcomes for the RM Clients on a market by market and asset class by asset class basis. They may choose to use one venue or several, depending on achieving the best outcome for the RM Clients.

This policy covers all trading that RM carries out on behalf of the RM Clients.

Execution factors

The execution factors are the price at which they can trade, the cost of trading, the speed of trading, the likelihood of successful execution and settlement, the size of the order, the nature of an order and any other consideration relevant to the execution of an order (for instance, the liquidity of the market or venue on which they are trading, or whether the order is being traded on-exchange or “over-the-counter” (off exchange)).

The relevant execution factor’s importance will depend to some extent on the strategy, market or asset class in which trading is happening. When assessing these factors, the RM team will already have taken into account the relevant RM Client categorisation, the characteristics of the order, the characteristics of the instrument that is the subject of the order and the characteristics of the execution venues to which the order can be directed.

Obtaining the best price for each trade will be a significant factor in all trading. Cost will typically also be a major consideration, whether of the individual trade or the market or venue on which each trade is conducted. In addition, in order to deliver the best possible result, RM may also consider the speed of the transaction, likelihood of execution and settlement, the size and nature of the order, market impact and any other implicit transaction costs over the immediate price and costs considerations.

While RM ordinarily expects price to have the highest degree of importance, the process for determining the relevant importance of each factor will typically depend on the circumstances and on the fund manager’s objectives. This will dictate which of the execution factors will ultimately take precedence. Execution will also be influenced by market conditions at the time.

The nature of the instrument being traded will determine how it can be executed and on which venue. These factors together are the biggest determining factor in how Best Execution is delivered for the RM Clients. Ordinarily, price will merit a high relative importance in obtaining the best possible result. Based on experience, the next most important factor after price is typically the size of the order and available liquidity, followed by speed of execution. However, RM may decide that any of these factors, or other factors, may be more important in determining the best possible execution results, based on the circumstances, orders, financial instruments or markets relevant at the time. In those circumstances, the team may choose what to prioritise according always to what is most likely to achieve the best possible results for the RM Clients.

Aggregation

Merging orders may avoid delays in execution and keep costs to a minimum. Accordingly, orders may be grouped together so that trades for a number of clients in a certain instrument are executed together. In these circumstances, individual merged trades may operate to the disadvantage of certain clients on individual transactions, but in all cases, RM will treat clients fairly when aggregating orders. If merged orders cannot be fully executed, the financial instruments will (as far as material and subject to market constraints) be allocated to clients in proportion to the size of the relevant client’s interest comparative to the size of the original order(s).

Crossing

In certain circumstances, RM may decide to “cross” trades, i.e., trade between portfolios which are both managed by RM. In these circumstances, the team will ensure that the price is fair in accordance with such market information as is available and will only make such a trade if it is in the best interests, taking into account all factors, of both parties.

Venues

The venues used by RM are listed in Appendix 2. The team will normally assess venues on a transaction by transaction basis but typically look to provide Best Execution by finding the best price available for a particular instrument; the best price may only be available on a particular venue, so the aim of Best Execution may dictate the venue for a particular trade. If possible, RM will check this price by investigating the depth of trading in the relevant instrument and the price which is available publicly, through the different venues on which the instrument is available. Additionally, any client may have restrictions on their ability to trade, such as the list of venues on which the relevant client is allowed or wishes to trade. Any restriction on venue may of course affect the ability to deliver Best Execution.

In certain cases (typically due to the financial instrument being traded or the asset class of the transaction), there may only be one execution venue. In executing a trade in these circumstances, RM will try to validate the trading price by all available means but may not be able to obtain the same level of comfort that the price is truly the best available as we would if an instrument was available on multiple venues or otherwise widely traded.
Public market trading venues include:

Regulated markets and recognised investment exchanges, set out in more detail in Appendix 2;
Multilateral trading facilities,
Systematic internalisers. These are firms that execute orders from their clients against their own book or against orders from other clients; and
Third party investment firms acting as market makers or other liquidity providers. This may include non-EU entities carrying out these functions.

Accordingly, in certain circumstances, RM may trade outside of a regulated market or multilateral trading facility. It will provide on request additional information about the consequences of this means of execution.

A list of the venues on which RM places significant reliance in meeting its obligation to obtain the best result for order execution is set out in Appendix 2. The majority of these venues are used for equities trading only. The variety of venues available does not mean that all instruments are easily available. The trading venues for private market instruments will depend on the instrument concerned.

The RM Clients have given their consent to trading outside regulated markets or multi-lateral trading facilities. In all cases, the general commitment to provide Best Execution will apply and RM will assess in each case the risk of the relevant trade so that it does not take unreasonable risks with clients’ funds.

For strategies which invest in equities, fixed income and derivatives, counterparties are chosen which the RM team believe will be able to access the required venues to provide Best Execution. Counterparties in this sense includes brokers and other intermediaries which can trade financial instruments on RM instructions.

The primary aim in selecting counterparties is that of best execution. RM currently pays commission to brokers for “execution only” services (i.e., payment for their broking activities), but does not believe that these payments affect the ability of brokers to supply Best Execution, nor does it affect the ability to deliver Best Execution to clients. In relation to RM’s business, commission paid to counterparties is not materially relevant to asset classes other than equities. RM does not pay or receive any remuneration, discount or non-monetary benefit for routing orders to a particular trading or execution venue which would infringe on its requirements to avoid conflicts of interest or not to pay or receive any inducement which is contrary to clients’ best interests.

Client orders and special circumstances

When trading financial instruments on behalf of the RM Clients, RM will normally use discretion to decide which financial instruments to trade, the size and speed at which it wishes to trade, the venues on which those instruments will be available and how to access those venues. However, RM Clients may instruct RM to execute a specific order or group of orders in a certain way. Depending on the specifics of the order the client has given RM, it may not be able to achieve Best Execution because the order may prevent that. In those circumstances, RM will try to achieve the best possible results whilst following clients’ orders.

Additionally, when there are special (market) circumstances at play, RM may deviate from this Order Execution and Allocation Policy. Examples of special circumstances include extreme volatility or disruption in financial markets, disruptions in order systems, power outages or other emergencies that are beyond the control of RM. It is possible that orders will only be partially executed, if at all, during these circumstances. In the case where partial execution occurs, RM will allocate executed trades across its clients’ portfolios fairly, by reference to the size of the relevant client’s interest in the partially executed trade compared to the original order.

Diversity in markets and the kinds of order that RM carries out on behalf of clients may mean that factors other than price and cost will have to be taken into account for each individual trade. For instance, market volatility or the absence of a regulated market may make the speed at which the team executes a priority. Lack of liquidity (i.e., that a particular instrument is not widely traded or available) may also mean that the ability to assess price is restricted and in certain circumstances there may even only be one price available, which will restrict the ability to validate that price. RM may, on a trade-by-trade basis, execute a transaction through a venue not currently included on the list of venues set out in Appendix 2, or through a new counterparty.

In summary, whilst all reasonable steps will be taken based on business resources to deliver Best Execution, no guarantee can be given that best price will be achieved in each and every individual situation. However, in all cases, RM will do its best to balance all execution factors to achieve the best result, whilst at the same time treating all RM Clients fairly.

Monitoring, review and reporting

RM monitors the execution outcomes it attains. Where appropriate it will correct any deficiencies identified as part of this monitoring. Usually, the monitoring process will focus on the outcomes achieved for the RM Clients and whether these are consistently ensuring the best outcome, depending on the relevant assessment criteria. Most monitoring will be done “real time” by RM, normally with the relevant individual fund manager double checking that the outcome achieved on trading is consistently as good as it could have been, although data will also be reported to a suitable management committee.

RM will review order execution arrangements including venues periodically and adjust this policy as required. In any event, RM will review the Order Execution Policy at least annually or in the event that there is a material change that affects its ability to continue to obtain the best possible results for clients. “Material change” for these purposes will include a significant development which impacts on the choice of execution venues available or where there is a significant change to the operating processes. A significant development could involve the development of a new recognised investment exchange, multilateral trading facility or a significant regulatory change impacting the market environment. RM has obligations to identify, prevent, manage and monitor conflicts of interest in order to prevent such conflicts from adversely affecting the interests of investors, in alignment with the RM conflict of interest policy. RM strives to ensure that each client is treated fairly, equitably and in a transparent manner.

Allocation

The following describes the allocation policy RM follows to ensure that trading is allocated to the RM Clients in a fair and consistent way.

Investment Preferences. All RM Clients will have an opportunity to participate in a transaction if the proposal meets the relevant fund investment parameters.
Interest of Clients. RM acts in the best interest of its clients when allocating participations in transactions.
Investment Strategy. Investments are made in accordance with the underlying fund investment mandate taking into account all investment restrictions and parameters.
Equal allocation. No RM Client receives preferential allocation over another. All RM Clients receive equal allocations up to the relevant fund’s respective limits, pro rata if they are otherwise equal.

Mobile phones and record keeping

RM’s policy is not to allow activities to be carried out using a mobile telephone or mobile handheld electronic communication devices and emails must be recorded. Further, RM may rely upon an EEA counterparty or broker to record conversations upon their behalf where an undertaking is in place and appropriately documented.
In all other events RM must take reasonable steps to retain all records of deals for a period of at least six (6) months from the date the record was created, and in a medium that allows prompt access, an ability to check whether any corrections, amendments have been made, and in any event in a medium that does not permit any manipulation or alteration of the records. In public market trading, this is normally done via Bloomberg.

Client consent

RM will obtain the consent of each RM Client to this policy and on any significant change.