Legal/Policies

This website is designed solely for the use of UK-resident professional clients and eligible counterparties.

Please read these terms carefully before using our website as they contain important information about how you may use the website. By using this website, you confirm that you agree to be bound by these Terms of Use. If you don't agree to these Terms of Use you should not use this website.

The Privacy and Cookie Policies apply to your use of the Atlantic House Group website. By using this website, you are consenting to us processing any personal data that you provide to us or that we collect from you because of your use of our website. Our Privacy and Cookie Policy set outs what we do with that personal data.

In the unfortunate circumstances you have any cause to make a complaint please email: info@atlantichousegroup.com or write to us at Atlantic House, 135 Bishopsgate, London EC2M 3TP.

About us

This website is operated by the Atlantic House Group Limited (Registered no: 09770730) and its subsidiary, Atlantic House Investments Limited (registered no:11962808). Both are private limited companies, registered in England and Wales. Registered Office: One Eleven Edmund Street, Birmingham B3 2HU. Atlantic House Solutions is a trading name of Atlantic House Group Limited.

Atlantic House Group Limited (FRN: 719605) and Atlantic House Investments Limited (FRN: 719605) are authorised and regulated by the Financial Conduct Authority.

Our website information

Our website is made available to you free of charge. We do not guarantee that access to our website, or the content on it, will always be available or uninterrupted. Your right to access our website is given on a temporary basis only.

The information on this website is provided for general information and does not constitute or form part of any offer, recommendation or invitation to buy or sell investments, nor is it intended to be any form of advice.

If you have any doubt about the suitability of this site for your needs you should seek relevant professional advice.

Atlantic House Group Limited and its affiliates do not provide tax, legal or accounting advice. This website has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction.

We regularly review the content on our website. However, we cannot guarantee that all content on our website is accurate, complete or up to date. We therefore make no warranties, representations, undertakings or guarantees that the content on our website is accurate, complete or up to date.

We make no warranties, representations, undertakings or guarantees that our website or any content on it will be free from errors or omissions.

Changes to this website or terms of use

We reserve the right to change any content on this website from time to time without notice.

Every time you wish to use our website, please check these Terms of Use to ensure that you are aware of the terms that apply at that time.

We may update these Terms of Use and the Privacy and Cookie Policy from time to time. By continuing to use this website after we make any such updates, you confirm that you've understood and agreed to be bound by them. You should revisit the relevant pages regularly to ensure that you've seen and are aware of the current terms and conditions that will apply to your use at that time. We also recommend that you always review the current Privacy and Cookie Policies.

We reserve the right to change any material on this website from time to time without notice.

Intellectual property

We, or our licensors, own the copyright and all other intellectual property rights in our website and all content on it, including the Atlantic House Group of companies logos, names and trademarks.

Unless specifically prohibited by a notice on any page, you may print or download individual sections of this website for your own personal information and use only, provided that you retain all copyright and other proprietary notices.

You must not use, extract or reproduce logos or any content from our website for commercial purposes without first obtaining the written consent of Atlantic House or any party which licenses any content to us. If you use, download, print or reproduce content from our website in breach of these Terms of Use your right to use our website will immediately end and you must return to us or destroy (at our option) all digital and paper copies of the content that you have made.

Third Party Links

Our website may contain links to other websites from time to time, including to pages and other websites operated by us or by a third party operating on our behalf. Where our website contains links to other websites and resources provided by third parties, these links are provided for your information and for your convenience only. We have no control over the contents of those sites or resources, we accept no responsibility for them and you shouldn’t take our providing these links as an endorsement or guarantee by us of the websites or the information on them.

You must not link to this website in a way that implies endorsement or partnership without our permission.

Viruses

We don't guarantee that our website will be free from malicious programs or materials, bugs or viruses. You're responsible for configuring your information technology and software to access this website and should use your own virus protection software.

Responsibility for loss or damage

We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for:

death or personal injury as a result of our negligence;

fraud or fraudulent misrepresentation.

We won't be liable to you for any loss or damage (even if foreseeable) arising under or in connection with:

use of, or inability to use, our website;

use of or reliance on any content displayed on our website; or

viruses, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our website or to your downloading of any content on it, or on any website linked to it.

We accept no liability for the information contained on any third-party websites linked to on our website and we won't be liable for any loss or damage that may arise from your use of them.

These Terms of Use (and any non-contractual obligations arising out of or in connection with them) are governed by the law of England and Wales and the courts of England and Wales have exclusive jurisdiction to determine any dispute arising out of or in connection with them (including without limitation in relation to any non-contractual obligations).
This website is designed solely for the use of UK-resident professional clients and eligible counterparties. This website contains marketing communications. Please refer to the relevant legal documentsbefore making any final decision to invest. For example before investing in an Atlantic House fund, please refer to the Prospectus for the GemCap Investments (Ireland) Plc and the relevant Fund Supplement and Key Investor Information Document before making any final decision to invest.

The information on this website is provided for general information and does not constitute or form part of any offer or invitation to buy or sell shares. It is intended for UK domiciled professional clients, eligible counterparties and institutional investors only.

The value of investments and income from them can go down and you may get back less than originally invested. There is no guarantee that investments will achieve their objective.

Fluctuations in exchange rates may have a positive or an adverse effect on the value of foreign-currency denominated securities and financial instruments. Certain investments involve an above-average degree of risk and should be seen as long-term in nature.

The investment products and services described in the website may have tax consequences. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. You acknowledge that levels and bases of taxation may change. We do not provide tax advice. You should consult your own tax adviser in order to understand the tax consequences of the products and services described in the website.

Pricing & valuations throughout the website

Indicative pricing or valuations throughout the site do not represent a firm bid or offer, or value and does not commit Atlantic House Group Limited or Atlantic House Investments Limited to any transaction. Firm price quotations and values may vary significantly from an indicative price because of various factors. Whilst we exercise the utmost care in our understanding and listing of the tax treatment of securities and funds, we are not tax advisers and cannot be held responsible for the taxation of securities or funds issued and managed. Investors should take advice from their usual tax adviser if they are in any doubt.

Important information about Atlantic House Funds

A comprehensive list of risk factors is detailed in the Risk Warnings Section of the Prospectus and the relevant Supplement and key investor information document (KIID) for the Atlantic House Investment funds. A final investment decision should not be contemplated until the risks are fully considered. A copy of the English version of the Supplement, the Prospectus, and any other offering document and the KIID can be viewed on each Fund page on this website and at www.geminicapital.ie.

A summary of investor rights associated with an investment in the Fund is available in English www.geminicapital.ie.

Financial Indices

Funds managed by Atlantic House Investments Limited may gain exposure to financial indices for tracking or replication, investment or efficient portfolio management purposes. Details of how each fund may gain exposure to financial indices are provided in the relevant fund’s Supplement. Due to the intentionally broad nature of the funds’ strategies, it is not possible to comprehensively list all of the financial indices to which exposure may be taken, and they may change from time to time. Details of any financial indices used by the funds will be provided by Atlantic House Investments Limited on request and will be set out in the GemCap Investment Funds (Ireland) plc semi-annual and annual accounts. For further information please contact: info@atlantichousegroup.com.

The information on this website is provided for general information and does not constitute or form part of any offer or invitation to buy or sell shares.

The value of investments and income from them can go down and you may get back less than originally invested. There is no guarantee that the funds will achieve their objective.

A decision may be taken at any time to terminate the arrangements for the marketing of the Fund in any jurisdiction in which it is currently being marketed. Shareholders in affected EEA Member State will be notified of any decision marketing arrangements in advance and will be provided the opportunity to redeem their shareholding in the Company free of any charges or deductions for at least 30 working days from the date of such notification.

Gemini Capital Management (Ireland) Limited, trading as GemCap, is a limited liability company registered under the registered number 579677 under Irish law pursuant to the Companies Act 2014 which is regulated by the Central Bank of Ireland. Its principal office is at Ground Floor, 118 Rock Road, Booterstown, A94 V0Y, Co. Dublin and its registered office is at 7th Floor, Block A, One Park Place, Upper Hatch Street, Dublin 2, D02 E762. GemCap acts as both management company and global distributor to GemCap Investment Funds (Ireland) plc.

GemCap UK Limited (FRN 924419) is an appointed representative of Connexion Capital LLP (FRN 480006), which is authorised and regulated by the Financial Conduct Authority and provides distribution oversight services to GemCap acting as global distributor and is responsible for the oversight of all distribution arrangements for the sub-funds.

Atlantic House Group Limited, Atlantic House Investments Limited and Albemarle Street Partners (“Our Companies”) are part of the Atlantic House Group of companies. This privacy policy will explain how our organisations uses the personal data we collect from you when you use our websites.

Topics:

What data do we collect?

How do we collect your data?

How will we use your data?

Purpose and legal basis for using your personal information

How do we protect your information?

Do we pass on your data to Third Parties?

Do we have Third-party links on our Website?

How do we store your data?

Marketing

What are your data protection rights?

What are cookies?

Privacy policies of other websites

Changes to our privacy policy

How to contact us

How to contact the appropriate authorities

What data do we collect?

Our Companies collects the following data:

We collect information on the use of our site, where you are a registered user or explicitly give your personal details, this information will be linked to you, otherwise it will be anonymous;

Personal identification information (Name, email address, phone number, etc.) or any other information about you that you disclose to us;

Information we collect from the way you do business with us, such as or when you use our telephone services, websites or when you apply for our products or services;

Details of any complaints or concerns raised by you.

How do we collect your data?

You directly provide Our Companies with most of the data we collect. We collect data and process data when you:

Register online or place an order for any of our products or services.

Use our website after registration or enter information on our website.

Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.

Use or view our website via your browser's cookies.

How will we use your data?

Our Companies collects your data so that we can:

send periodic emails regarding your investments, related products and associated services.

target market and sales and to tailor and customise our services, communications and marketing for you,

follow up after correspondence (live chat, email, webinar or phone enquiries).

administer the "My Solutions" part of this website.

analyse and improve the technical function of this website.

process complaints.

comply with contractual obligations, regulatory requirements and in order to manage risk effectively.

enhance and develop our products and services, testing the quality and effectiveness of our products and services, and defining customer types and target markets.

enhance your user experience and monitor site performance.

administer our sites and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes.

Purpose and legal basis for using your personal information

We will process your personal data only in accordance with the applicable Data Protection Legislation. We will use your personal data for the purposes and on the legal bases set out in the table below. We do not rely on consent as a legal basis for processing your personal data. Where we have asked for your consent and you have given it, you have the right to withdraw it at any time by contacting us. You always have the right to unsubscribe from any direct marketing that you receive from us, by clicking the link that is included in each message or by contacting us. For more detail on your rights regarding your personal data, see below.

This table describes in more detail the various categories of personal data we collect (as set out above in "What data do we collect") and the lawful ground on which we rely for processing this personal data.

Category of personal data collected

We collect information on the use of our site, where you are a registered user or explicitly give your personal details.

Personal identification information (Name, email address, phone number, etc.) or any other information about you that you disclose to us.

Information we collect from the way you do business with us, such as or when you use our telephone services, websites or when you apply for our products or services.

Purpose for collection

to manage and administer any of the services provided by us to you;

for day to day operational and business purposes;

investor relationship management;

for record keeping, security and/or training purposes;

for any other specific purposes where you have given specific consent to that processing for those purposes;

to carry out statistical analysis and market research;

to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes;

certain marketing purposes, unless you have opted out of this; and

for other legitimate business purposes as may be determined by us from time to time.

Legal basis for processing

Where we need to perform the contract we are about to enter into or have entered into with you.

Where we need to comply with a legal or regulatory obligation.

Where it is necessary for our legitimate interests (or those of a third party):

to prevent money laundering and fraud;

to protect our business interests;

to evaluate, develop or improve our products and services;

to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.

Details of any complaints or concerns raised by you

Purpose for collection

For day to day operational and business purposes;

investor relationship management;

for any other specific purposes where you have given specific consent to that processing for those purposes;

to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings); or

for other legitimate business purposes as may be determined by us from time to time.

Legal basis for processing

Where we need to comply with a legal or regulatory obligation.

Where it is necessary for our legitimate interests:

to protect our business interests;

to ensure that complaints are investigated; or

to evaluate, develop or improve our products and services.

How do we protect your information

Our website is scanned on a regular basis for security holes and known vulnerabilities to make your visit to our site as safe as possible.

Do we pass on your data to Third Parties?

We do not sell or trade your Personal Information.

Do we have Third-party links on our Website?

We do not include or offer third-party products or services on our website.

How do we store your data?

Our Companies securely stores your data in the Cloud.

The Cloud services used to process personal data complies to ISO27017 certification, with adherence to the standard considered the best way of a supplier proving that it has met the GDPR principle of privacy by design.

All Data and Applications are hosted in Microsoft 365’s multiple data centres which conform to the highest security standards and ISO requirements. Microsoft 365 uses Azure Active Directory and all accounts have Multi Factor Authentication enabled via Security policies.

Our Companies will hold your personal information in line with our Record Keeping Policy. Once the time period has expired, we will securely delete your data.

Marketing

Our Companies would like to send you information about products and services of ours that we think you might like.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Our Companies from contacting you for marketing purposes or giving your data to other members of the Our Companies Group.

If at any time you would like to unsubscribe from receiving future emails, you can email us at info@atlantichousegroup.com and we will promptly remove you from ALL correspondence.

What are your data protection rights?

Our Companies would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access - You have the right to request Our Companies for copies of your personal data. We may charge you a small fee for this service.

The right to rectification - You have the right to request that Our Companies correct any information you believe is inaccurate. You also have the right to request Our Companies to complete information you believe is incomplete.

The right to erasure - You have the right to request that Our Companies erase your personal data, under certain conditions.

The right to restrict processing - You have the right to request that Our Companies restrict the processing of your personal data, under certain conditions.

The right to object to processing - You have the right to object to Our Companies processing of your personal data, under certain conditions.

The right to data portability - You have the right to request that Our Companies transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us see below for our contact details.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information on our cookie policy please click the link below https://www.atlantichousegroup.com/cookieinformation or visit allaboutcookies.org.

Privacy policies of other websites

Our website does not contain links to other websites. Our privacy policy applies only to our website.

Changes to our privacy policy

Our Companies keeps their privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 29 January 2024.

How to contact us

If you have any questions about Our Companies privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@atlantichousegroup.com

Call us: (+44) 020 7043 0100

Or write to us at: Atlantic House Investments Limited, 135 Bishopsgate, London, EC2M 3TP

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Our Companies have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner's Office.

Website: https://ico.org.uk/global/contact-us/contact-us-public/

Telephone: 0303 123 1113
What are cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org

How we use cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.

How do we protect your information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

The cookies we set

We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.

More information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information you can contact us through one of our preferred contact methods.

Email: info@atlantichousegroup.com

Phone: 020 7043 0100

Stewardship Code Disclosure Statement

Atlantic House Investments (“AHI” / the “Firm”)

Under COBS 2.2.3 of the FCA Handbook, AHI is required to make a public disclosure in relation to the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code (the “Code”). Adherence to the Code is voluntary.
The Code aims to enhance the quality of engagement between asset managers and companies to help improve long-term risk-adjusted returns to shareholders and promote the efficient exercise of governance responsibilities. It also describes steps asset owners can take to protect and enhance the value that accrues to the ultimate beneficiary and sets out several areas of good practice on engagement with investee companies to which the FRC believes institutional investors should aspire.
The Code is directed in the first instance to institutional investors by which is meant asset owners and asset managers with equity holdings in UK listed companies.

The Principles of the Code

The seven principles of the Code are that institutional investors should:

Publicly disclose their policy on how they will discharge their stewardship responsibilities.

Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship.

Monitor their investee companies.

Establish clear guidelines on when and how they will escalate their stewardship activities as a method of protecting and enhancing shareholder value.

Be willing to act collectively with other investors where appropriate.

Have a clear policy on voting and disclosure of voting activity.

Report periodically on their stewardship and voting activities.

The FRC encourages signatories to the Code to review their policy statements annually and update them as necessary to reflect changes in actual practice.

UK Financial Reporting Council’s Stewardship Code

FCA COBS Rule 2.2.3R requires FCA authorised firms to disclose the nature of their commitment to the FRC’s Stewardship Code (the ”Code”) or, where it does not commit to the Code, its alternative investment strategy.

AHI employs a discretionary opportunistic equity long/short trading strategy with the ability to invest across the capital structure. Whilst AHI is typically a passive investor, there are situations where the Firm will formally engage with investee companies through voting rights. These typically cover instances where we have concerns over the strategic direction of the company or over alignment between us as a shareholder and management.

We set out below our approach to the recommendations of the Code and explain our reasons for taking a different approach where relevant.

Principle 1

Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
This document sets out how the Firm seeks to discharge its stewardship responsibilities. AHI has outlined in this statement each of the principles of the Code and how it complies with them or explains why it does not. In particular, it sets out how the Firm monitors the companies in which it has invested as investment manager to its clients, its strategy on engagement and its policy on the exercise of voting rights on behalf of its clients.
Engagement with investee companies is primarily the responsibility of the Firm’s Investment Team and the Chief Investment Officer (“CIO”). The Firm’s proxy voting procedures and recordkeeping are overseen by the Firm’s COO.
AHI does not outsource its stewardship responsibilities.

Principle 2

Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.
AHI maintains a robust policy on managing conflicts of interest which is designed to ensure its decisions are taken wholly in the interest of its clients. AHI aims to ensure that all potential and actual conflicts are identified, evaluated, managed, monitored and recorded.
Should a conflict of interest arise, the senior management of AHI would take appropriate steps to ensure fair treatment of all clients including disclosure of the conflict to the affected clients as a measure of last resort (if it be deemed appropriate).
As part of the Firm’s policy, all members of staff must notify the Firm’s Compliance Officer if they become aware of any material conflict of interest arising, including in relation to voting proxies on behalf of clients. Where such a material conflict of interest is identified, voting instructions will be subject to assessment and approval by the Compliance Officer.
A summary of the Firm’s conflicts of interest policy is available to clients upon request.

Principle 3

Where appropriate, the Firm will monitor its investee companies to determine when dialogue with management may be necessary. AHI’s monitoring process may include the following:

Keeping abreast of the company’s performance.

Keeping abreast of developments, both internal and external to the company that drive the company’s value and risks.

Satisfying itself that the governance arrangements of the companies, including the operation of the Board and any non-executive oversight adhere to the spirit of the UK Corporate Governance Code.

Considering the quality of the company’s reporting.

Retaining adequate records of company meetings and of votes cast on behalf of its clients.

Records of reasons for voting against a company’s management or for abstaining.

Attending General Meetings.

The Firm is typically a passive investor and is careful to select companies that have sufficient business strength and corporate governance so as not to require the intervention of shareholders. The Firm will, however, seek to influence management when it believes it to be in the best interests of shareholders.
Influence would take the form of verbal engagement with C level management, if concerns remain, the Firm will take up the issue in written form with the board. Whilst the Firm are cognisant, of concert party rules and restrictions, the Firm may discuss the issue with other investors, though does not expect to enter into concert party arrangements.
In normal circumstances, the Firm does not wish to be made an insider. The Firm expects investee companies and their advisers not to convey information to the Firm that could affect its ability to deal in the shares of the company concerned without prior agreement.

Principle 4

Institutional investors should establish clear guidelines on when and how they will escalate their stewardship activities.
If AHI becomes concerned about any aspect of an investee company’s investment strategy, performance, governance or any other matter, the Firm may wish to escalate this to the management of the company.
Examples of the way in which such matters could be escalated include:

Holding additional meetings with management.

Expressing concerns through advisers.

Meeting with Chairman or other independent directors.

Intervening jointly with other investors.

If the Firm’s concerns are not addressed during this process the Firm will consider further actions, which may include the sale of its holding.

Principle 5

Institutional investors should be willing to act collectively with other investors where appropriate

AHI typically does not act collectively with other investors in any way it could be deemed to be acting in concert. Whilst there may be situations where it is appropriate to act collectively with other shareholders in order to engage with an investee company, generally we believe that we have sufficient expertise and knowledge of investee companies to deal with any concerns that we might have about the investee company’s business activities, strategy or corporate governance. In most cases we would expect to engage with the board on our own initiative or we may decide to dispose of or reduce our holding.

Principle 6

Institutional investors should have a clear policy on voting and disclosure of voting activity. AHI maintains proxy voting policies and procedures that are designed to ensure that it makes a best effort attempt to vote proxies in the best interests of its clients and will generally seek to vote all of its shares. AHI generally votes in favour of routine corporate housekeeping proposals, including election of directors (where no corporate governance issues are involved). For other proposals, AHI will assess what is in the best interests of its clients and, in doing so, may take into account the following factors:

whether the proposal was recommended by management and AHI’s opinion of management;

whether the proposal acts to entrench existing management;

whether the proposal fairly compensates management for past and future performance;

Environmental, Social and Governance factors (where appropriate); and

the proxy voting research provided by ISS (or equivalent) to the investment teams before shareholder meetings.

AHI does not publicly disclose voting records as it considers that such information belongs to its clients on whose behalf it has voted and not the general public.

AHI generally does not lend securities on behalf of its clients.

Principle 7

Institutional investors should report periodically on their stewardship and voting activities.

The Firm does not believe it is in the investors’ interest to disclose publicly its shareholdings or how it may have exercised its voting rights on behalf of a client. However, subject to underlying client confidentiality and investment strategy considerations, the Firm may provide clients with information on voting, engagement and stewardship activity on request or where required by law and or regulation.
Atlantic House Investments Limited

BIPRU Firm Renumeration Policy

The Remuneration Policy is designed to support key business strategies and create a strong, performance-orientated environment. At the same time, the policy must attract, motivate and retain talent.

It is important that the policy follows the Financial Conduct Authority’s SYSC rules (namely SYSC Chapter 19C – Remuneration Code) and addresses the importance of ensuring that all variable remuneration is subject to risk- based profit performance and is not seen to reward misconduct or poor performance at the individual, unit or firm level.
Executive directors (and other senior/management/control function staff, namely those falling within the definition of Remuneration Code Staff – taken to include senior management, risk takers, those performing a significant influence function or who are paid like senior management or risk takers) receive base salaries proportionate with companies of their size with the added opportunity to enhance total remuneration by receiving bonuses based upon the overall performance of the company and takes this into account when determining remuneration policy and practice for other employees.
The components of remuneration for code staff comprises of a base salary, which takes the form of a fixed sum payable monthly which is reviewed annually and other benefits including non-contributory health insurance, a potential quarterly annual bonus and pension contributions.
A successful remuneration policy must ensure that a significant part of the remuneration package is linked to the achievement of stretching corporate performance targets. The policy adopted by the company ensures that a proportion of the remuneration of executives and others is aligned with corporate performance. As a result, depending on the performance of the company, some staff may receive a bonus exceeding 33.3% of their base salary.
The Committee has agreed that the Company falls within Proportionality Level 3 in accordance with the revised remuneration code and has identified those employees that fall within the scope of that code.

In the FCA’s view, it will be normally appropriate for a BIPRU firm to disapply, under the BIPRU remuneration proportionality principles, the following rules:

retained shares or other instruments (SYSC 19C.3.47R);

deferral (SYSC 19C.3.49R);

performance adjustment (SYSC 19C.3.51R); and

the ratios between fixed and variable components of total remuneration (SYSC19C.3.44R).

Policy on Salary Executive Directors

It is the company policy to pay base salaries to the executive directors broadly at market rates compared with those of executives of companies of a similar size, whilst also taking into account the executives’ personal performance and the performance of the Group. All directors and senior managers are required to sign a conflict of interest disclosure.

Policy on Bonus

The bonus in the case of all employees including executive directors is designed to reward outstanding performance and to be consistent with the company's approach to risk. The company bonus pool will be based on risk-adjusted profits. All bonuses will reflect the performance of the individual, the business unit and the firm. No bonus will be guaranteed.

ESG

The Firm has determined that sustainability risk (which is defined as an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the relevant investment (an "ESG Event") is not relevant for the funds the firm manages.

The funds are based on major financial indices and derivatives structured around major financial indicies and, as such an ESG event would not be relevant to the funds.

Policy on Long-Term Incentives, Executive Share Options, Performance and Share Plans or Pensions

Should any of these become applicable they will be added as an annex to this document.

Policy on Service Contracts

In relation to contracts with executive directors, the company sets notice or contract periods at three months. If it is necessary to offer longer notice or contract periods to new directors recruited, it is the company’s policy to reduce these as soon as contractually possible after the initial period to a notice period of one year.

Executive directors are permitted, where appropriate and with Board approval, to take non-executive directorships with other organisations in order to broaden their knowledge and experience in other markets and countries.

Renumeration Code Staff

This comprises all employees whose professional activities have a material impact on the firm's risk profile, including senior management and other staff exercising control functions, risk takers and any staff whose pay puts them in the same remuneration bracket as senior management and risk takers. Code Staff are informed of their classification.

The identified Remuneration Code Staff are as follows:

All senior management and all staff holding a certified function as defined under the SM&CR regime.

Remuneration Code Staff can be exempt from certain strands of the code requirements on the basis that the variable proportion of their remuneration comprises no more than 33% of their total remuneration and their total remuneration is no more than £500,000. Applications to the FCA need to be made for any exemptions as outlined above. For a Proportionality Level 3 firm, the firm should carefully consider the wisdom of application for exemption as many of the requirements can be disapplied.

Remuneration Code Staff exemption applications:

No exemption applications.
Human Rights & Modern Slavery

Policy Statement

Modern slavery is defined as a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking (“modern slavery”), all of which include the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Atlantic House Group has a zero-tolerance approach to modern slavery within its business and supply chains. We believe that every human being has the fundamental right to be treated with respect and to be paid a fair wage for the work that they undertake. This policy applies to all persons working for Atlantic House Group or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, volunteers, agents, contractors, consultants and suppliers. Atlantic House Group strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain under Section 54 of the Modern Slavery Act 2015. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.

Modern Slavery and Human Trafficking examples:

• Domestic Servitude - Employees working in private homes are forced or coerced into serving and/or fraudulently convinced that they have no option to leave.

• Sex Trafficking - Women, men or children that are forced into the commercial sex industry and held against their will by force, fraud or coercion.

• Forced Labour - Human beings are forced to work under the threat of violence and for no pay. These slaves are treated as property and exploited to create a product for commercial sale.

• Bonded Labour - Individuals that are compelled to work in order to repay a debt and unable to leave until the debt is repaid.

• Child Labour - Any enslavement — whether forced labour, domestic servitude, bonded labour or sex trafficking — of a child.

• Forced Marriage - Women and children who are forced to marry another without their consent or against their will.

Signs of Modern Slavery or Human Trafficking

There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:

• The person is not in possession of their own passport, identification or travel documents.

• The person is acting as though they are being instructed or coached by someone else.

• The person allows others to speak for them when spoken to directly.

• The person is dropped off and collected from work.

• The person is withdrawn or appears frightened.

• The person does not seem to be able to contact friends or family freely.

• The person has limited social interaction or contact with people outside of their immediate environment.

All members of Atlantic House Group’s team are briefed on these indicators and instructed to remain watchful for any of the above signs when engaging with any of our suppliers. While modern slavery can be found in all countries and industries, we acknowledge that there is a heightened risk with:

• domestic and international migrant labour.

• contract, agency, and temporary workers.

• vulnerable populations such as refugees.

• young, or student workers.

Our processes focus on listening to employee’s and workers’ perspectives about their employment or supplier contracts to drive improvement. This is so we can offer continuous improvements across our organisation as we are committed to the equal treatment of our workforce and suppliers.

Due Diligence framework

Atlantic House Group operates a due diligence framework to ensure that we are consistent in our modern slavery and human trafficking approach to avoid inappropriate exploitation of our workforce and the workforce of our suppliers. We provide e-Learning training for all staff on an annual basis, made available on our internal Intranet the Home Office Modern Slavery Awareness Booklet and have a Modern Slavery and Human Trafficking Statement on our website.

Reporting Modern Slavery

Atlantic House Group employees must report any incidence or suspicion of modern slavery at the earliest possible stage to their Line Manager. Alternatively, if you are a supplier and have cause for your concern, your primary business contact with Atlantic House Group is the Head of Compliance and you should report any concerns to them.

Breaches of this policy

Any member of the Atlantic House Group who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. If a supplier is found to be in breach of this policy then Atlantic House Group may terminate its relationship with a supplier or issue an improvement notice which will confirm the steps that Atlantic House Group requires the supplier to take in order to remedy any issues and the time frame in which those improvements must be made.

Policy Review

Atlantic House Group is responsible for reviewing this policy as necessary to ensure that it meets legal and ethical requirements and reflects best practice. This policy does not form part of any contract of employment and may be amended at any time.