Legal and Compliance

Inducements

Double Black Partners Limited may from time to time receive acceptable minor non-monetary benefits permitted under applicable law and regulation as set out in COBS 2.3A.19 of the FCA Handbook, including; 

  • information or documentation relating to financial instruments or investment services;

  • issuer-commissioned research coverage;

  • participation in conferences, seminars or training events on the benefits and features of specific financial instruments or investment services;

  • hospitality of a de minimis value during meetings or those events specified;

  • connected research on an issuer in the context of an issuer capital raising;

  • research provided for a trial period, openly and publicly available, or relating to fixed income, currency or commodity instruments (with the exclusion of macro-economic research); and

  • such other services and/or benefits that can be considered minor non-monetary benefits under applicable law from time to time.

 

UK Stewardship Code 

The UK Stewardship Code 2020 (the “Code”), consists of, inter alia, 12 stewardship principles for asset managers and asset owners. The Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society”. The Code is voluntary and applies on an ‘apply or explain’ basis.

Our Approach
We manage investments globally across a range of asset classes and follow several diversified strategies.
We determine our approach to stewardship on a case-by-case basis, taking into account the actions that will lead to the most favourable outcome for the value of our investments. Having considered the Code and while supporting the general objectives of the Code, we believe that the principles set out therein are not applicable to our investment activities at this time and therefore we have not applied to be a signatory to the Code. Should our approach or investment strategy change in the future, we will review our commitment to the Code and update the firm’s website disclosure accordingly.
Notwithstanding our decision with respect to becoming a signatory to the Code, the firm, in principle, supports the Code’s underlying objectives.

 

SRD II Disclosure

The revised Shareholder Rights Directive (SRD II) aims to strengthen shareholder engagement and increase transparency for asset managers and owners; and also to promote effective stewardship and long-term investment decision making. SRD II sets requirements in several areas, including transparency of engagement policies and investment strategies across the institutional investment community.

Under FCA rules, we are required to develop and publicly disclose a shareholder engagement policy and publicly disclose on an annual basis how that policy has been implemented. Where we do not comply with such requirements, we must disclose why we have chosen not to do so.

While we support the objectives of SRD II, our investment strategies do not significantly involve investing in equity holdings in publicly listed companies, and such equities form only a small component of our overall assets under management. In general, we would expect shares in relevant investee companies only to be held as an investment ancillary to, or as a result of, a credit investment. In cases where we do have exposure to publicly listed equities, and consequently the voting rights associated with them, we will exercise such voting rights as agreed with our clients.

Accordingly, we do not consider it appropriate to adopt a shareholder engagement policy as described by SRD II at this time. If our investment strategies change so that the provisions of SRD II become relevant, we will update this disclosure accordingly.

 

Complaints

If you have a complaint, please write to:

Double Black Partners Limited

C/O Centralis UK Limited

The Bee House

140 Eastern Avenue,

Park Drive, Milton Park,

Oxford, OX14 4SB

United Kingdom

Or by email to: contact@dbpartners.com

Double Black Partners Limited will send a prompt written acknowledgement that the firm has received the complaint and is dealing with it.

Double Black Partners Limited (FRN 1046925) is authorised and regulated by the Financial Conduct Authority. Double Black Partners Limited is a limited company registered in England and Wales (with registered number 16301406). The registered office of Double Black Partners Limited is C/O Centralis UK Limited, The Bee House, 140 Eastern Avenue, Park Drive, Milton Park, Oxford, England, OX14 4SB.

Telephone and communications recording

Provided for the purposes of compliance with rule 10A.1.11 of the Senior Management Arrangements, System and Controls (“SYSC”) Sourcebook of the UK Financial Conduct Authority Handbook.

General

Telephone conversations between Double Black Partners Limited, a client and/or third parties may be recorded without the use of a warning tone and used as evidence in the event of a dispute or investigation.

Double Black Partners Limited may retain records of all communications with a client for, in principle, a period of five years and, where requested by the competent authority, for a period of up to seven years. A copy of the recording of such records will be available on request from a client during the applicable period.

Conversation notes

Double Black Partners Limited is required, in the case of personal conversations with clients relating to investment services, to record in a durable medium notes of the conversation which include at least the following:

  • Date and time of the meeting,

  • Location of the meeting,

  • Identity of the attendees,

  • Initiator of the meeting, and

  • Relevant information about the order including the price, volume, type of order and when it shall be transmitted or executed.