Charteris - Treasury Portfolio Managers Limited
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Disclaimer

Legal Information – Including Disclaimer, GDPR & Pillar 3 disclosure document

Disclaimer

Acceptance of Terms
Charteris Treasury Portfolio Managers Limited ('Charteris') maintains this website as a service. By accessing, browsing and/or using this website, you acknowledge that you have read, understood, and agree to be bound by the following terms of use and to comply with all applicable laws and regulations.

Terms of Use
The contents of this website are for general information and illustrative purposes only and are not intended to serve as financial, investment or any other type of advice. Charteris makes no representation as to the accuracy of the information on this website. Any reliance on any information on this website shall be at the user's own risk.

The information contained in this website is believed to be accurate at the time of posting, however Charteris does not warrant the completeness nor accuracy of the information at all times. In addition, Charteris is neither responsible nor liable for any errors or omissions in the information contained in this website.

Charteris does not make any representations regarding any other websites which may be accessed through this website, and accordingly shall not be responsible for other content or use of such websites.

Charteris shall not be responsible for any loss or damage of whatsoever nature (including consequential loss or damage) suffered or incurred, directly or indirectly, by the user or any other person as a result of relying on, or incidental to, or the use of, or any matter relating to, the information contained on this website.

You agree to indemnify and hold Charteris harmless from any claim or demand that may be made by any third party, that is due to or arises out of your conduct or connection with this website or service, your provision of Content, your violation of these Terms of Use or any other violation of the rights of another person or party.

This website is hosted and maintained in England and its usage and content are subject to English law.

Forward-looking statements
This website may from time to time contain forward-looking statements relating to Charteris management's expectations, estimates and projections. Words such as 'expects,' 'intends,' 'plans,' 'projects,' 'believes,' 'estimates' and similar expressions are used to identify such forward-looking statements. Any such statements are not guarantees of future performance and can involve certain risks, uncertainties and assumptions that are difficult to predict. Further, certain forward-looking statements are based upon assumptions as to future events that may not prove to be accurate. Therefore, actual outcomes and results may differ materially from what is expressed or forecast in such forward-looking statements.

Privacy Policy (GDPR)

Charteris Treasury Portfolio Managers Limited treats your privacy very seriously and we are committed to ensuring that your personal data is protected.  Our Privacy Policy contains important information on how we comply with applicable UK data protection legislation. EU General Data Protection Regulation (GDPR) replaces the Data Protection Act 1998. GDPR lays out our obligations with regard to the data we collect, what we do with this information, whom we may share it with and your choices and rights regarding this information.

What information do we collect about you?
In order to provide services to you and to meet legal and regulatory requirements in the execution of these services we may need to collect the following data:-
Information about who you are – name, date of birth, NI number and contact details.
Information connected to the service of your account – bank details.
Information about your circumstances – your financial obligations and details, investment knowledge and objectives, other investments held, employment, retirement plans.
Information regarding when you contact us – meeting notes, file notes regarding phone calls, phone calls which may be recorded, e-mails and letters.
Information collected as sensitive personal information – details regarding your health, marital status, political exposure.
Information which you provide regarding other people – where it is a joint policy, beneficiaries, trustees, anyone given authority by you on your account.
Information on children or other dependants – name, date of birth and gender

How do we collect your data?
We will mostly collect this information from you directly which would include:-
Your original application form
Telephone conversations
E-mails or letters which you send to us
Face to face meetings

If you have a financial adviser then the information which we collect and use may have been provided by them on your behalf. We may also collect personal information from places such as directories or other publicly available sources to confirm information we already hold eg your address or to improve contact details.The data which you have provided may be shared with fraud prevention agencies to prevent fraud, money laundering and to verify your identity.

How do we use your personal information?
We will only ever collect and use your personal information where it is necessary, lawful or to meet our regulatory obligations. We will collect and use your information only where:-
You have signed our Investment Management Agreement (contract). This may include making data available to our agents for the purposes of executing orders, settlement of transactions and holding investments and money for you or any other related purposes such as printing your regular valuations or contract notes.
 Where It is necessary for us to meet our legal or regulatory obligations (Legal Obligation). This can include telling you about changes to our terms and conditions, preventing financial crime, details required by regulatory or government agencies.
Verifying your identity in order that we can comply with the regulations surrounding fraud, money laundering and terrorist financing.
Where It is in your interest (Legitimate Interest) to provide you with information or options about investments that may affect you or provide updates on policy changes that my impact you. This could include good governance, accounting and auditing reasons.
You have given your permission (Consent) to send you information about our products and services.
We will only use details on children to manage portfolios where they may be the beneficiary and will only collect and use the information to ensure the effective management of the portfolio. Where we collect sensitive personal data we will only use this where it is necessary to provide our services to you or to comply with our legal or regulatory obligations. Where providing data is optional we will ask for your consent. If you do not wish us to collect and use your data in these ways it may mean that we be unable to provide you with our services. If we change the way we collect, use or store your information we will provide you with an updated policy and details of the changes.

Marketing Preferences
We may use your name, address and e-mail address for marketing purposes if you have given your permission for us to do so. You may revoke this permission at any time.

With whom may we share your information?
We may share your information with third parties for the reasons stated above. Whenever we share your personal data we will do so in line with our obligations to keep your information safe and secure. This can include your financial adviser and companies we have chosen to support us in the delivery of services we supply to you.
All companies who process your data in relation to our services must undergo a due diligence process to ensure their integrity and commitment the agreed service and protection of data provided to them in this regard.
Our regulators, the Financial Conduct Authority (FCA) and the Information Commissioner’s Office for the UK (ICO) Law enforcement, credit and identify check agencies for the prevention and detection of crime. HM Revenue & Customs (HMRC) for the purpose of tax information for both UK tax requirements and/or other country obligations you may be liable for. We will never sell your details to someone else.

How do we protect your information?
We take your information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way whether on paper, online or any other media will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically.
Our security controls are aligned to industry standards and good practice. These provide a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

Where is your information processed?
Currently your information is processed in the UK and the European Economic Area (EEA).
If it should become necessary to process your data outside of the UK and EEA then we would take additional steps to ensure that your information is protected to at least an equivalent level as would be applied in the UK and EEA. Regular checks would be put in place to ensure that they met these obligations.

How long do we keep your information?
We will keep your personal information only where it is necessary to provide you with our products or services while you are a client.
We may also keep your information after this period but only where we are required to in order to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

What are your individual rights?
GDPR grants you rights in regard to how we use your information. These rights do not apply in all circumstances as we also have to comply with our legal and regulatory obligations.
Right to be informed – You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with.
Right of access – You have the right of access to your personal information. If you wish to receive a copy of the personal data we hold about you may make a data subject access request.
Right to request that your personal information be rectified – If your personal information is inaccurate or incomplete you can request that it is corrected. In order for us to provide you with our service it is important that you keep us updated on any changes to your data.
Right to request erasure – You can ask that your information be deleted or removed. We are, however, under legal or regulatory requirements to keep many details after you cease to be a client. This is required in order to meet our obligations to the regulator and/or government agencies. In some cases it may also be in your interest for us to continue to keep information so that we may assist you in queries or complaints about past services.
Right to request deletion of your data – We will look at each request on an individual case by case basis. We will delete any data that may no longer be required or not related to our outstanding obligations and where law and regulation allows us to.  Access to your information is restricted and protected within our systems at all times. Once you cease to be a client this information will not be processed but merely maintained. This will be the case for any information that we are unable to delete at your request.
Right to data portability – You can ask for a copy of your personal data for your own purposes to use across different services. In certain circumstances you may transfer some of the information we hold to another company in a safe and secure way if, for example, you were moving your portfolio to another provider.
Right to object – You can object to us processing your data for direct marketing, using it for research and statistics or if we notify you of changes to the way we process our use of your information. In some cases this may limit the service that we are able to provide.

How can you access the data we hold about you?
You have the right to request the personal information that we hold about you and to obtain a copy of this information. Should you wish to do so you should write to the following address:-

The Data Protection Officer
Charteris Treasury Portfolio Managers Ltd
8/9 Lovat Lane
London EC3R 8DW

We will provide the information to you or a date when it will be available within 30 days of your request.

The Information Commissioner's Office is the UK's Independent authority set up to uphold information rights in the public interest promoting openness by public bodies and data privacy for individuals. They can be contacted via their website https://ico.org.ukas well as by telephone on 0303 123 1113, by e-mail dataprotectionfee@ico.org.uk or at the following address:-

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Pillar 3 Disclosures Document

Introduction:
CTPM is a Discretionary Portfolio Management Company (with a small Number, of legacy advisory clients). It is also the adviser, to a number of funds. CTPM is a BIPRU Limited Licence £125k company.

The following relates to CTPM but not to its client nominee Company, Charteris Treasury Nominees Ltd, nor to its parent Company, Charteris Holdings Ltd.

Risk Management:
The Company’s risk management strategic approach is set by the Board – with day to day management being the responsibility of the Compliance Officer. Objectives and policies are dealt with, collectively, as below.

CTPM is audited annually and this is supplemented by our internal systems and controls. This conforms to the requirements of the Authorisers and Regulators of the Company (the Financial Conduct Authority – the "FCA".

Annual Reports are prepared for the Board and updates are issued throughout the year where necessary. The Company has prepared an ICAAP (Internal Capital Adequacy Assessment Process) as is required by the FCA.

Credit Risk:
CTPM mainly deals with the following counterparties: Retails Clients, Market Counterparties, Banks & Custodians.

The assets of our Private clients (Discretionary & Advisory) are held in specially segregated accounts by our custodians James Brearley & Sons Ltd and Julius Baer. No credit is permitted. As a result, Private Client accounts are not allowed to borrow. No leverage is permitted by the funds of which CTPM are the adviser.

CTPM use the DVP (Delivery Versus Payment) system within the James Brearley ICON system, when dealing with Market Counterparties for Private Clients. Transactions in the funds, of which CTPM are the adviser, occur between third parties.

When dealing with our Bank and Custodians, we do not allow credit against our holdings. Both daily, and monthly, reconciliations of assets are made by James Brearley & Sons Ltd and Julius Baer as required by the FCA.

For BIPRU 3 reporting purposes, the standardised approach is adopted, but using the simplified option where applicable.

Market Risk:
Apart from standard risks in the market, applicable to private clients and the funds (of which CTPM is the adviser). CTPM as an entity is not exposed, directly to market risk. This is because CTPM does not hold principal positions. The impact to the company of changes in market conditions is covered below under the heading "Business Risk and Testing".

Liquidity Risk:
CTPM currently has an agreed overdraft in place with our bankers. The Company currently has cash above its Capital Resource Requirement.

Operational Risk:
The Firm has standard risks, as applicable to most operational contexts. It operates segregation of duties with dealing and settlement handled by the back office and our external custodians whereas Investment Management and Marketing are handled by the front office on a sole instruction basis.

Insurance Risk:
The Company maintains PII (Professional Indemnity Insurance) – as required by the FCA. In addition has Office Insurance including Employer Liability and public liability. This is complimented by cash reserves, to cover applicable short term contingencies.

Concentration Risk:
The Company has diversified to act as the Adviser on a number of Funds (which are themselves diversified across a number of Asset classes and sectors), to compliment the Private Client element of the business.

Residual Risk:
The Company does not lend money. Most debtors, as applicable, are trade debtors

Securitisation Risk:
This is not applicable to CTPM.

Business Risk and Stress Testing:
Risks to the Company, from its business activities, relate to the impact of significant falls in the equity and/or gilt and/or gold markets, lack of appropriate conditions for trading activity, changes of advisers to Fund investment managers, changes to the wealth management sector and the UK/global economy in general. It also relates to issues which would cause damage to the Company’s reputation. The Company has prepared an ICAAP, as required by the FCA.

Interest Rate Risk:
As the Company holds some client assets in cash, these assets (and the resultant Annual Management Charge to the company) should benefit/ decrease with rises/ falls in the base rate, as they are impacted. Naturally, stock & securities would be directly or indirectly affected by changes to the interest rate. As no credit is provided to clients (see above), this element would not be impacted by interest rate risks. Any borrowings/overdraft held by the Company would be impacted by changes to the interest rate.

Pension Obligation Risk:
Due to recent legislation, the Company will be obliged to provide a pension for those between 22 and retirement age between August 2015 and April 2017.

Equity/ collective investment schemes (CIS) Risk:
Equities and CIS are used within Funds (of which we are the adviser to the investment managers) and portfolios that CTPM advises on/manages. These are standard risks in the market.

Option Risk:
Options (Covered Calls) are used within the Funds (of which we are the adviser). There are standard risks in the market.

Commodity and foreign currency Risk:
Investments in Commodity based investments and via foreign currencies are made within Funds (of which we are the adviser) & portfolios that CTPM advises and/or manages. There are standard risks in the market.

Trading Book Risk:
This is not applicable to the Firm. CTPM does not run its own trading book.

People Risk:
As identified in the ICAAP, People Risk (Key Person Risk) is particularly weighted in a relatively smaller size Company. As a result, we have invested in key man insurance and have in place a system of cross training and cover to address these issues. These risks have been identified in the annual reports.

Processes & Systems Risks:
These risks have also been identified in the annual reports.

External events Risks:
The risks here have been identified in the annual reports. Exogenous (i.e. external) events – including theft, fire, flooding, terrorist attacks, etc – can be mostly addressed through our BCP [Business Continuity Plan]. This is tested annually.

Renumeration Committee
The renumeration committee is comprised of the Board or the Senior Management Committee as appropriate

August 2017