Leadenhall Capital Partners Strategy News Contact About Us Media UCITS Sustainability & ESG Disclaimer and Regulatory Information Leadenhall Capital Partners LLP These general terms of use set out the basis on which you may make use of this website under the domain name leadenhallcp.com, whether as a guest or as a registered user with access to restricted areas. By using the website, you indicate that you accept these terms of use and agree to abide by them. If you do not agree to these terms, please refrain from using this website. Information on this Site The information on this site is issued by Leadenhall Capital Partners LLP. This website contains documents and information which are financial promotions for the purposes of the FCA Handbook. Restrictions on Access to the Information on this Site United Kingdom The investment funds referred to on this site (together, the "Funds") are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the "Act"). Information on this site is exempt from the restriction in section 238 of the Act on the communication of an invitation or inducement to participate in a collective investment scheme on the grounds that such information is communicated to and/or directed at only persons who are categorised as professional clients or eligible counterparties (within the meaning set out in the FCA Handbook) in relation to the Funds. The investments and investment services to which this site relates are only available to such persons and other persons should not act or rely on it. In particular, any investment or investment service to which this site relates is not intended for persons who are retail clients and will not be made available to retail clients. Investors in the Funds will not benefit from the rules and regulations made under the Act for the protection of investors, nor from the Financial Services Compensation Scheme. Shares in the Funds are not dealt in or on a recognised or designated investment exchange for the purposes of the Act, nor is there a market maker in such shares, and it may therefore be difficult or impossible for an investor to dispose of his shares otherwise than by way of redemption. United States The information on this site is not directed at any person in the United States and this site is not intended to be used by any person in the United States. This website and the related information do not represent a prospectus or invitation in connection with any solicitation of capital, an offer to sell securities, a solicitation of an offer to buy securities, or a distribution of securities in the United States or to a US person. Other jurisdictions The information on this site is not directed at any person in any jurisdiction where it is unlawful to access and use such information. It may be illegal to download the information contained in this site in certain countries and Leadenhall Capital Partners LLP and its associated companies disclaim all responsibility if you download any information from this site in breach of any law or regulation of the country in which you are residing. Password Protection Where access to any part of this site is restricted and requires possession of a valid password, no other person should attempt to gain access to such part of the site. If you are granted a password, you must treat it as confidential and not disclose it to any other person or in any way facilitate another person’s access to restricted areas of the site. Leadenhall Capital Partners LLP reserves the right to disable access to this site if it determines that you have breached the terms of use. Applications for Shares in the Funds An application for shares in any of the Funds should only be made having read fully the relevant prospectus. It is your responsibility to read such prospectus and by making an application you will be deemed to represent that you have read such prospectus and agree to be bound by its contents. Role of Leadenhall Capital Partners LLP Leadenhall Capital Partners LLP does not provide investment advice to, nor receives and transmits orders from, investors in the Funds. Nothing contained in this site constitutes investment, legal, tax or other advice, nor is anything on this site a recommendation to invest in the Funds, any security, or any other instrument, nor is this site to be relied upon when making investment or other decisions. The information on this site is provided solely on the basis that you make your own investment decisions. Should you have any queries about the investment funds referred to on this site, you should contact your financial adviser. Risk Factors Past performance is not a reliable indicator of future performance. The value of investments in the Funds, and the income from them may go down as well as up, and investors in the Funds may not get back all or any amount originally invested. Because of this, investors in the Funds are not certain to make a profit on their investments and investors may lose some or all of the money invested in the Funds. Returns also may increase or decrease as a result of currency fluctuations as well as for other reasons. Where this site refers to a particular tax treatment, please note that tax treatment depends on the particular individual circumstances of each investor in the Fund and may be subject to change in the future. Investors should consult their own tax adviser in order to understand any applicable tax consequences. Leadenhall Capital Partners LLP and its associated companies make no representation or warranty of any kind as to the tax treatment of any particular investor and offer no tax advice of any kind. Forward Looking Statements This website may contain forward-looking statements concerning future financial and business performance. These statements represent the beliefs of Leadenhall Capital Partners LLP and its associated companies concerning future operations, strategies, financial results or other developments, and contain words such as "may," "expects," "should," "believes," "estimates," or similar expressions. Because these forward-looking statements are based on assumptions that are subject to significant business, economic and competitive uncertainties, many of which are beyond the control of Leadenhall Capital Partners LLP and its associated companies or are subject to change, actual results could be materially different. Any forward-looking statements speak only as of the date of this release or as of the date they are made and should be regarded solely as the current estimates and beliefs of Leadenhall Capital Partners LLP and its associated companies. Leadenhall Capital Partners LLP and its associated companies undertake no obligation to update these forward-looking statements. Accuracy of Information The information contained on this site (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by Leadenhall Capital Partners LLP and its associated companies to be reliable, but is not guaranteed as to its accuracy or completeness. Such information is provided without obligation on the part of Leadenhall Capital Partners LLP and its associated companies and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at his own risk. The information contained on this site does not constitute an offer to buy or sell or an invitation to make an offer to buy or sell shares in any Fund. Information posted on this site is current only as at the date it is first posted and may no longer be accurate or complete when viewed by you. All information contained on this site may be changed or amended without prior notice, but neither Leadenhall Capital Partners LLP nor any of its associated companies undertakes to update this site regularly. No Liability The information and opinions contained in this site have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, no representation, warranty or undertaking, express or implied, is made by Leadenhall Capital Partners LLP, its associated companies or any other person as to the reliability, accuracy or completeness of the information contained on this site and no liability is accepted by such persons for the reliability, accuracy or completeness of such information. In no event will Leadenhall Capital Partners LLP or any of its associated companies or any of their directors or other employees be liable to any person for any direct, indirect, special or consequential losses or damages of any kind arising out of any use of this site or any other third party website or information or in reliance on the information and opinions contained in it from time to time, including without limitation, any loss of profit, business interruption, loss of programs or data on your equipment or otherwise. You should be aware that the Internet is not a completely reliable transmission medium. Neither Leadenhall Capital Partners LLP nor any of its associated companies accepts any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. In addition, neither Leadenhall Capital Partners LLP nor any of its associated companies accept any responsibility for the security or confidentiality of information transmitted across the internet to or from Leadenhall Capital Partners LLP or any of its associated companies and any such transmission of information is entirely at your own risk. Notwithstanding any statement on this website, Leadenhall Capital Partners LLP does not exclude or restrict any duty or liability that it has to its clients under the regulatory system in the United Kingdom. Material Interests Leadenhall Capital Partners LLP, its associated companies and its and their members and/or directors, officers and/or employees may have holdings in the investment Funds and may otherwise be interested in transactions that investors effect in the Funds. Linked Websites This website may be linked to third party websites or contain information provided by third parties. These links are provided solely for your convenience. Neither Leadenhall Capital Partners LLP nor any of its associated companies makes any representation as to the accuracy or completeness of such websites or information, have not and will not review or update such websites or information Leadenhall Capital Partners LLP cautions users of this site that any use made of such websites or information is at their own risk. Neither Leadenhall Capital Partners LLP nor any of its associated companies accepts any liability arising out of the information contained on any linked website or information on this site provided by a third party and the use of such sites and information is at your own risk. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Leadenhall Capital Partners LLP, its associated companies, their licensors or relevant third party content providers. You may use the information on this site and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means - electronic, mechanical, photocopying, recording or otherwise - without the prior written permission of Leadenhall Capital Partners LLP. Nothing on this site should be considered as granting any licence or right under any trademark of Leadenhall Capital Partners LLP, its associated companies or any third party. Governing Law You agree that your use of this website, and any dispute arising from or in relation to these terms of use and your use of this site, is subject to English law and you submit to the exclusive jurisdiction of the English courts in connection with any such dispute. Non Waiver The failure of Leadenhall Capital Partners LLP to enforce any term or condition of these terms of use shall not be deemed a waiver of such terms or the right to enforce such terms and conditions. Leadenhall Capital Partners LLP Leadenhall Capital Partners LLP is a Limited Liability Partnership Registered in England and Wales with Registration Number OC336969 and Registered Office: Leadenhall Capital Partners LLP, Level 15, 70 Mark Lane, London, EC3R 7NQ. The UK Stewardship Code Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Leadenhall Capital Partners 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 firm pursues an investment strategy to which the aims of the Code are not relevant. The firm does not invest in any investments for its own account. The firm does provide investment management and advisory services with a strategy of investing in insurance linked investments. The firm’s strategy does not involve investing in UK equities. Consequently, while the firm supports the general objectives that underlie the Code, the provisions of the Code are not relevant to the type of trading currently undertaken by the firm. If the firm's investment strategy changes in such a manner that the provisions of the Code become relevant, the firm will amend this disclosure accordingly. Cookies We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that helps us to improve the Services and to deliver a better and more personalised service. For example, they enable us to identify who you are and to access your account information You may refuse to accept cookies by activating the setting on your Internet browser which allows you to refuse the setting of cookies. You can also delete cookies that have been installed on your hard drive – consult your software manual for further help. However, if you select the refuse setting, or delete cookies, you may be unable to access certain parts of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. Remuneration Policy The Manager is subject to remuneration policies, procedures and practices (together, the “Remuneration Policy”). The Remuneration Policy is consistent with and promotes sound and effective risk management. It is designed not to encourage risk-taking which is inconsistent with the risk profile of the Company. The Remuneration Policy is in line with the business strategy, objectives, values and interests of the Manager and the Company, and includes measures to avoid conflicts of interest. The Remuneration Policy applies to staff whose professional activities have a material impact on the risk profile of the Manager or the Company, and ensures that no individual will be involved in determining or approving their own remuneration. The Remuneration Policy will be reviewed annually. The Remuneration Policy will be made available for inspection and a paper copy may be obtained, free of charge, at the registered office of the Company. Modern Slavery Transparency Statement 2021 Modern Slavery Statement 2021 (Apr 2021) April 2021 Quantitative disclosure under RTS 28/Art.65(6) of the MiFID II Organisational Regulation RTS 28 and Art.65(6) of the MIFID II Organisational Regulation require Firms to disclose, for each class of financial instruments, a summary of the top 5 execution venues / brokers used to execute client order on / transmit client orders to where the trade volume is higher than an average of one trade per day. The below table shows that Leadenhall trades on average less than one trade per day. Class of Instrument Each of: bonds/debentures, ILWs, interest rate swaps, notes, rolling spot forex, shares, TRS, MMF Notification if <1 average trade per business day in the previous year Yes - Confirmed Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders Name and Venue Identifier(MIC or LEI) N/A N/A N/A N/A N/A Name and Venue Identifier(MIC or LEI) N/A N/A N/A N/A N/A Name and Venue Identifier(MIC or LEI) N/A N/A N/A N/A N/A Name and Venue Identifier(MIC or LEI) N/A N/A N/A N/A N/A Name and Venue Identifier(MIC or LEI) N/A N/A N/A N/A N/A Qualitative disclosure under RTS 28 / Art.65(6) of the MiFID II Organisational Regulation RTS 28 and Art.65(6) of the MIFID II Organisational Regulation require Firms to disclose, for each class of financial instruments, a summary of the analysis and conclusions drawn for the detailed monitoring of the quality of execution obtained on the execution venues / by the brokers they execute client orders on / transmit client orders to. The table below covers Leadenhall’s analysis for each of the relevant class of financial instruments: 1) Class of Financial Instrument: Each of: Bonds/debentures, ILWs, interest rate swaps, notes, forex futures, shares, TRS, MMF RTS 28 / Art. 65(6) requirement Analysis (a) an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution; The relevant importance of each of the factors will be determined for each venue by using the Firm’s experience and knowledge of the market, taking into account the following criteria: the characteristics of the client including the categorisation of the client as professional; the characteristics of the client’s agreed investment strategy; the characteristics of the financial instruments; and the characteristics of the execution venue to which the transaction can be directed. In the majority of cases for professional clients the Firm would typically expect that the most significant issue to be taken into account will be the total consideration to be paid or received in each case such that there will be greater weight on the price and costs associated with each trade. However, there will be circumstances when other factors may be more important or relevant and the Firm will use its judgement and experience to give greater prominence to them. Leadenhall takes a number of factors such as expertise, certainty of execution and credit worthiness into account when determining the choice of broker for an order. (b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues/brokers used to execute orders; N/A – there are no such links with execution venues or brokers (c) a description of any specific arrangements with any execution venues/brokers regarding payments made or received, discounts, rebates or non-monetary benefits received; N/A – the firm does not have in place any specific arrangements with any execution venues or brokers (d) an explanation of the factors that led to a change in the list of execution venues/brokers listed in the firm’s execution policy, if such a change occurred; An existing broker was removed from the list of approved brokers in January 2021 as whilst the entity still exists its staff set up a competing ILS fund without staff segregation and as such could no longer be considered independent. (e) an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements; N/A – the firm does not deal with retail clients (f) an explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client; N/A – the firm does not deal with retail clients (g) an explanation of how the investment firm has used any data or tools relating to the quality of execution (i), including any data published under Commission Delegated Regulation (EU) 2017/575 [RTS 27] (ii); N/A – the firm does not use data or tools relating to the quality of execution, however the firm does track execution rationale using its proprietary system (h) where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU. N/A – the firm has not used output of a consolidated tape provider Downloadable versions of our RTS 28 disclosures April 2021 April 2020 April 2019 Disclaimer and Regulatory InformationPrivacy Notice Website by Clock