Important Regulatory Information

Pillar 3

Sloane Robinson LLP has documented the disclosures required by the FSA under BIPRU 11.3. These are available on the firm’s website for registered users or from the Compliance Officer at the registered office.

UK Stewardship Code

Under Rule 2.2.3R of the FSA's Conduct of Business Sourcebook, Sloane Robinson LLP (the "Firm") is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.

The Firm has a proxy voting policy in place, as required by the Hedge Fund Standards Board, which sets out the circumstances in which the Firm will vote on behalf of clients. The Firm also has a conflicts of interest policy in place to manage the risks of any conflicts of interest arising between itself and its clients and has in place procedures to deal with any conflicts that arise. These policies and procedures are regularly reviewed and updated.

The Firm invests in a variety of asset classes and in a variety of jurisdictions globally. The Firm takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests, in accordance with its proxy voting policy, and, consequently, does not consider it appropriate to commit further to any particular voluntary code of practice relating to any individual jurisdiction. This approach will be kept under review. 

Financial Crime Statement

We seek to comply with high standards of anti-money laundering, counter terrorist financing practice, anti bribery and economic sanctions in all our business dealings. We take our duty of compliance extremely seriously and have established strong policies and procedures to manage these issues, including awareness training, record keeping and compliance monitoring. We value our reputation for ethical behaviour and recognise that over and above the commission of any crime any involvement in bribery or corruption would of itself be unacceptable. We absolutely forbid corruption and the paying or receipt of bribes.