ABOUT STRATEGIES ESG NEWS AND RESEARCH CAREERS CONTACT Legal Legal PCA Stewardship Code Disclosure Modern slavery statement Pemberton Asset Management S.A. disclosures German prospects: Information requirements Pemberton ESG policy Acknowledgement of complaints Whether you complain during a telephone conversation or meeting, or in a letter, email or other communication, we will record your concerns and pass the details to our Compliance Officer for investigation. You will receive an acknowledgement from the Compliance Officer within five business days, giving you the name of the person who will handle your complaint. Investigation and Resolution The Compliance Officer will investigate your complaint and attempt to resolve it as quickly as possible. You may be asked to provide additional information to assist in this process. Within four weeks of making the complaint you will receive either a final response or a holding response indicating when you may expect a final response from us. Within eight weeks of making the complaint you will receive either a final response or a letter explaining why we are still not in a position to make a final response and when this can be expected. We only have dealings with Professional Clients and Eligible Market Counterparties so we are exempt from the right to use the Financial Ombudsman Service which applies only to “eligible complainants”. We aim always to resolve complaints within eight weeks; it should only take longer than this if we have to request further information from you or from a third party to establish all the facts. The final response will set out the facts that have been established during the investigation. The policy PCA prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement: 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 partner, employee, consultant, agent or other person or body acting on PCA’s behalf in order to gain any commercial, contractual or regulatory advantage for PCA in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual. Further clarification PCA 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 the recipient, and which is intended to influence them to take action which may not be solely in the interests of the Partnership or of the person or body employing or contracting with the recipient or represented by the recipient. 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; and the giving of a gift for a corporate reason or at another special time, as long as this is reported in the proper manner within the firm on the Gifts Register maintained by the Compliance Officer. 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 Managing Partner of PCA before proceeding. If necessary, guidance should also be sought from the Compliance Officer. Partners, consultants and principles responsibility within PCA The prevention, detection and reporting of bribery is the responsibility of all partners, employees and 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. About us Strategies News and research Careers Contact Copyright © 2021 Pemberton Capital Advisors LLP Authorised and regulated by the Financial Conduct Authority Terms and conditions of use Privacy policy Legal Cookie consent By clicking “Accept All Cookies”, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. Cookies Settings Accept All Cookies