uk-disclosure

General

Stewardship Code Statement

Shareholder Rights Directive

Sustainable Finance Disclosure Regulation

Regulatory Disclosures

Verition Advisors (UK Partners) LLP (“Verition UK”) is authorised and regulated by the Financial Conduct Authority (“FCA”) with FRN: 989410.

U.K. Stewardship Code Statement

Pursuant to Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook (“COBS”), Verition UK is required to disclose whether it commits to the UK Financial Reporting Council's Stewardship Code (the "Code") or explain why it does not, taking into consideration its investment approach.

Verition UK, as a sub-advisor within the broader structure of the Verition group, deploys multiple investment strategies across a broad range of jurisdictions and asset classes. As a result, most of its investment activities relate to assets other than UK listed equities or fixed income assets. As noted in its Shareholder Rights Directive II disclosure, Verition UK does not have an activist approach to its investments, and the limited cases of interaction with UK investee companies are managed in accordance with various firm policies designed to act in the best interest of investors.

If the investment strategies utilised by Verition UK change in such a manner that the provisions of the Code become relevant, this disclosure will be amended accordingly.

Shareholder Rights Directive (SRD II)

Verition UK is required by Rule 2.2B.5R of COBS to develop and publicly disclose its shareholder engagement policy; alternatively, it must provide a clear and reasoned explanation of why it has chosen not to adopt such a policy.

Verition UK has considered carefully whether it wishes to adopt an engagement policy and to make the disclosures described above and has, for the time being, decided not to do so. Verition UK is a sub-advisor within the broader structure of the Verition group, and manages assets in accordance with a multi-strategy investment approach that involves a wide variety of assets and timeframes. Where Verition UK investment strategies include investing in shares, in accordance with Verition group policy, Verition UK does not vote proxies. Upon the exceptional specific request of an individual portfolio manager, Verition may consider granting permission to vote proxies, if it determines that the vote is in the best interest of investors.

Therefore, while Verition UK supports the general principles of shareholder engagement, it does not at this time (for the reasons set out above) consider it appropriate to adopt an engagement policy or make the relevant public disclosures. Verition UK will keep its position under review and will update this section of its website accordingly, if there is a change in its approach.

Sustainable Finance Disclosure Regulation

As Verition Fund Management LLC (“Verition”) is the alternative investment fund manager of an alternative investment fund (“Fund”) that is registered for marketing under the Alternative Investment Fund Managers Directive (2011/61/EU) in one or more member states of the European Economic Area, it is required by the Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (“SFDR”) to make certain disclosures on its website.

For the purposes of these disclosures, a “sustainability risk” is an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment; and “sustainability factors” means environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

Sustainability risk policies

The Fund does not seek to promote environmental or social characteristics nor does it have a specific sustainability investment objective. Given the nature of the investments held by the Fund, Verition does not integrate sustainability risks into its investment decision‐making process. Verition employs a wide variety of investment strategies for the Fund and the relevant sustainability/ESG considerations vary according to these different strategies. As a result, Verition does not incorporate a centralised ESG approach as part of its multi-strategy model for the Fund, but seeks to consider all material factors relevant to a particular investment.

No consideration of adverse impacts of investment decisions on sustainability factors

At present, Verition does not consider the principal adverse impacts of its investment decisions on sustainability factors, as contemplated by Article 4 of the SFDR, as the nature of the Fund’s investment strategies does not provide for the consideration of such adverse impacts. In addition, Verition has assessed that it cannot gather and/or measure all of the data for its multi-strategy model on which it would be obliged by the SFDR to report, in a systematic and consistent manner and at a reasonable cost to investors. Verition will continue to keep this policy under periodic review.

Remuneration policy

Verition’s remuneration policy takes into account a broad range of factors in order to determine the appropriate level of fixed and variable remuneration for an individual employee. As Verition does not integrate sustainability risks into its investment decision-making process, but instead seeks to consider all factors relevant to a particular investment, Verition does not assess sustainability risks as a separate component of any variable remuneration that may be awarded to an individual employee. Accordingly, variable remuneration takes into account, among other factors, the wider risk performance of an investment or portfolio that the employee actively manages, the Fund’s performance, and Verition’s overall financial performance.

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Privacy Policy

VERITION FUND MANAGEMENT LLC (THE “MANAGER”) IS COMMITTED TO MAINTAINING THE PRIVACY OF CURRENT AND PROSPECTIVE INVESTORS IN THE VERITION FUNDS (THE “FUNDS”). THE MANAGER RECOGNIZES THAT INVESTORS IN THE FUNDS ENTRUST THE MANAGER WITH HIGHLY CONFIDENTIAL PERSONAL AND FINANCIAL INFORMATION, AND THE MANAGER UNDERSTANDS THAT PROTECTING AND SAFEGUARDING THIS INFORMATION IS IMPORTANT.

IN THE COURSE OF PROCESSING AN INVESTOR’S SUBSCRIPTION AGREEMENT TO THE FUNDS AND THE MANAGER’S ONGOING DEALINGS WITH SUCH INVESTOR, THE MANAGER MAY OBTAIN NON-PUBLIC PERSONAL INFORMATION ABOUT SUCH INVESTOR. THIS INFORMATION MAY INCLUDE THE INVESTOR’S NAME, ADDRESS, TELEPHONE NUMBER, EMAIL ADDRESS, PASSPORT NUMBER, SOCIAL SECURITY NUMBER, TAXPAYER IDENTIFICATION NUMBER, BANK ACCOUNT NUMBER, TRANSACTION HISTORY AND OTHER PERSONAL INFORMATION. THE MANAGER MAY COLLECT DIFFERENT TYPES OF INFORMATION IN A VARIETY OF WAYS, INCLUDING:



  • INFORMATION IT RECEIVES FROM AN INVESTOR’S SUBSCRIPTION AGREEMENT, FROM OTHER FORMS AND QUESTIONNAIRES, OR OTHERWISE IN THE COURSE OF ESTABLISHING AN INVESTOR RELATIONSHIP.
  • INFORMATION ABOUT THE FREQUENCY OF AN INVESTOR’S OR OTHER PERSON’S USE OF THE MANAGER’S WEB SITE.
  • INFORMATION ABOUT AN INVESTOR’S TRANSACTIONS WITH THE FUNDS, ITS AFFILIATES OR OTHERS, SUCH AS SUCH INVESTOR’S INVESTMENT AND WITHDRAWAL HISTORY.


THE MANAGER USES THIS INFORMATION FOR MARKETING PURPOSES AS WELL AS INTERNAL ADMINISTRATION AND ANALYSIS. THE MANAGER DOES NOT DISCLOSE ANY NON-PUBLIC PERSONAL INFORMATION ABOUT INVESTORS OR FORMER INVESTORS IN THE FUNDS TO ANY NON-AFFILIATED PARTIES, EXCEPT TO THIRDPARTY SERVICE PROVIDERS WHO ASSIST IN THE OPERATION OF THE MANAGER’S AND THE FUND’S BUSINESS, AS REQUIRED BY LAW, AT THEIR REQUEST OR WITH THEIR CONSENT. THE MANAGER RESTRICTS ACCESS TO NON-PUBLIC PERSONAL INFORMATION TO THOSE PERSONNEL, AGENTS OR OTHER PARTIES WHO NEED TO KNOW THAT INFORMATION TO PROVIDE SERVICES TO SUCH PERSONS. THE MANAGER MAINTAINS PHYSICAL, ELECTRONIC AND PROCEDURAL SAFEGUARDS TO PROTECT NON-PUBLIC PERSONAL INFORMATION. THE MANAGER’S PRIVACY POLICY COVERS ALL INDIVIDUALS WHO ARE INVESTORS IN THE FUNDS, WHO HAVE BEEN INVESTORS IN THE FUNDS OR WHO ARE CONSIDERING AN INVESTMENT IN THE FUNDS.

FOR THE LIMITED PURPOSES OUTLINED ABOVE, THE MANAGER MAY DISSEMINATE INTERNALLY NON-PUBLIC, PERSONAL INFORMATION CONCERNING INVESTORS. HOWEVER, THE MANAGER WILL USE REASONABLE BEST EFFORTS TO ENSURE THAT SUCH INFORMATION IS TREATED IN ACCORDANCE WITH THIS PRIVACY POLICY.

BY DISCLOSING PERSONAL INFORMATION TO THE MANAGER, THE DISCLOSING PARTY CONSENTS TO THE COLLECTION, STORAGE AND PROCESSING OF ITS PERSONAL INFORMATION BY THE MANAGER IN A MANNER CONSISTENT WITH THIS PRIVACY POLICY.

THE MANAGER WILL PROVIDE INVESTORS IN THE FUNDS WITH A COPY OF ITS PRIVACY POLICY ANNUALLY, AND IF ANY MATERIAL CHANGES OCCUR TO ITS PRIVACY POLICY, THE MANAGER WILL NOTIFY INVESTORS AS PROMPTLY AS PRACTICABLE OF SUCH CHANGES. IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY, PLEASE CALL A REPRESENTATIVE OF THE MANAGER AT (203) 742-7700.

ALTHOUGH REGULATIONS ONLY REQUIRE THAT THE FOREGOING PRIVACY POLICY BE APPLIED TO NATURAL PERSONS, THE MANAGER APPLIES THE SAME PRIVACY POLICY TO ALL INVESTORS.

THE FOREGOING PRIVACY POLICY SHALL NOT PREVENT THE MANAGER OR THE FUND FROM DISCLOSING TO APPROPRIATE THIRD PARTIES SUCH INFORMATION AS THE MANAGER OR THE FUNDS MAY DEEM NECESSARY OR ADVISABLE IN ORDER TO COMPLY WITH APPLICABLE ANTI-MONEY LAUNDERING AND OTHER APPLICABLE LAWS AND REGULATIONS.