Legal & Regulatory

To the best of our knowledge and belief, we consider the information contained herein as accurate as at the date of publication. All information and opinions in this web page are subject to change without notice. No representation or warranty is given, whether express or implied, on the accuracy, adequacy or completeness of information provided in the website or by third parties. The materials in this web page could include technical inaccuracies or typographical errors, and could become inaccurate as a result of developments occurring after their respective dates. We undertake no obligation to maintain the currency of such information. Any links to other websites contained within this web page are for the convenience of the user only and do not constitute an endorsement by us of these websites. We are not responsible for the content of other websites referenced in this web page. Neither we nor our affiliates and our respective shareholders, directors, officers and employees assume any liabilities in respect of any errors or omissions on this web page, or any and all responsibility for any direct or consequential loss or damage of any kind resulting directly or indirectly from the use of this web page. Unless otherwise agreed with us, any use, disclosure, reproduction, modification or distribution of the contents of this web page, or any part thereof, is strictly prohibited. We expressly disclaim any liability, whether in contract, tort, strict liability or otherwise, for any direct, indirect, incidental, consequential, punitive or special damages arising out of, or in any way connected with, your access to or use of this website. This web page is not an advertisement and is not intended for public use or distribution. This website has been prepared for the purpose of providing general information only without taking account of any particular investor’s objectives, financial situation or needs and does not amount to an investment recommendation. An investor should, before making any investment decision, consider the appropriateness of the information in this website, and seek professional advice, having regard to the investor’s objectives, financial situation and needs. In all cases, anyone proposing to rely on or use the information contained in the website should independently verify and check the accuracy, completeness, reliability and suitability of the information. The information contained in this web page does not constitute financial, investment, legal, accounting, tax or other professional advice or a solicitation for investment in our funds, nor does it constitute an offer for sale of interests issued by funds that are managed or advised by us. Any offer can only be made by the relevant offering documents, together with the relevant subscription agreement, all of which must be read and understood in their entirety, and only in jurisdictions where such an offer is in compliance with relevant laws and regulatory requirements. Simulations, past and projected performance may not necessarily be indicative of future results. Figures may be taken from sources that are believed to be reliable (but may not necessarily have been independently verified), and such figures should not be relied upon in making investment decisions. We, our officers and employees do not assume any responsibility for the accuracy or completeness of such information. For the purpose of compliance with the UK Financial Services and Markets Act 2000 as amended, this material is communicated by Whitecroft Capital Management LLP, authorised and regulated by the UK Financial Conduct Authority. Whitecroft Capital Management LLP is registered in England and Wales with registered number OC414721.

UK Stewardship Code. FCA Conduct of Business Rule 2.2.3R requires FCA authorised firms to either disclose their compliance or explain their non-compliance with the principles set out in the UK Financial Reporting Council’s Stewardship Code (the “Code”). Whitecroft Capital Management LLP (the “Firm”) is authorised and regulated by the FCA in the United Kingdom and therefore subject to the Code. The Firm does not take an activist shareholder approach strategy and its investment process does not involve significant engagement with underlying investee companies. Accordingly, whilst the Firm supports the Code as a mechanism to promote best practice in the institutional shareholder conduct of UK listed companies, the Firm does not consider the Code or its principles to be appropriate for its funds’ investment strategies.

The Firm’s Pillar 3 disclosures are set out below as required by the FCA’s rules, specifically BIPRU 11. Unless otherwise stated, all figures are based on the audited financial statements of the Firm for the financial year ended 31 December 2021. This disclosure will be reviewed at least annually. The information contained in this disclosure has not and is not required to be audited by the external auditors and does not constitute any form of financial statement. The information should not be relied on in making any judgement on the Firm. The Firm is categorised by the FCA, for capital purposes, as a limited licence company. The Firm is a limited liability partnership and its total Tier 1 members’ interests are £130,000. The Firm’s Capital Resources Requirement is £64,000. The Firm has determined that its Tier 1 capital is sufficient to cover its Pillar 1 and Pillar 2 requirements. Due to limited size, nature, scale and complexity of the Firm, there is no independent risk management function. Firm’s partners determine the business strategy and risk appetite along with risk management policies and procedures. The partners have identified operational risk as the main area of risk to which the Firm is exposed. The Firm has procedures and policies in place to mitigate the risk wherever practical. The Firm is required to disclose aggregate information on remuneration in respect of its code staff. Aggregate remuneration in 2021 for code staff was £nil.

The best execution obligations in MiFID II aim to ensure that firms take all sufficient steps to obtain the best possible results for clients when executing orders. The Firm is required to publish the top five execution venues in terms of trading volumes for all executed client orders per class of financial instruments. The latest reports compiled in order to meet the requirements established in Article 27 of MiFID II and the MiFID II Regulatory Technical Standards (RTS) 28 could be found here and here and here.