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Owner and Operator of this Website
This website is owned and operated by UCapital Asset Management (“we” or “us” or “our”), a registered trading name of Pairstech Capital Management LLP (“Pairstech” or “we” or “us” or “our”). It provides information about investment products and services provided by UCapital Asset Management.
The entire content of this website is protected by copyright laws and intellectual property rights. You may download and use information and material from our website for your personal use. However you may not copy, reproduce, distribute or modify the content of the Pairstech.com website for commercial or public use without prior written consent from UCapital Asset Management.
All products and services in the pages of the website are subject to their own specific terms and conditions, which may change from time to time. If you choose to buy any UCapital Asset Management product listed on this website, you should not rely solely on the information contained on the website. You should read carefully the terms and conditions relating to any product or service you intend to purchase. These may be obtained from us – contact details are to be found on the ‘contact us’ link on this website.
Jurisdiction and Local Laws
The information on this website is directed at investors in the UK and does not constitute an offer to sell or invitation to buy securities in any jurisdiction where such an offer or invitation is unlawful, or where the person making such an offer is not qualified or authorized to do so.
Information from this website must not be issued or promoted in any jurisdiction where prohibited by law and must not be used in any way that would be contrary to local law or regulation. Accordingly, the financial services detailed in the website do not constitute an offer to transact business in any jurisdiction where such an offer would be considered unlawful. The Information does not constitute an offer or solicitation to buy or sell any investment fund or other product, service or information to anyone in any jurisdiction in which an offer or solicitation is not authorized or cannot legally be made or to any person to whom it is unlawful to make an offer or solicitation. For information specific to your jurisdiction, please contact your financial advisor.
UCapital Asset Management does not give investment advice or investment recommendations in respect of its product range or services offered. Nothing on this site should be construed as the giving of investment advice or investment recommendations.
Legal and Regulatory Status
UCapital Asset Management is an authorized trading name of Pairstech Capital Management LLP. Pairstech Capital Management is a London-based Asset Management firm founded in 2007. The company is authorized and regulated by the Financial Conduct Authority (“FCA”), registered nr. 477155.
UCapital Asset Management offers expertise in a variety of asset classes and provides institutional investors with a range of products representing true diversification with the best available risk-reward profile.
Pairstech has the following FCA permissions:
Advising on Investments
Carrying on a regulated activity
Arranging deals in Investments
Dealing in Investment as an agent
Making arrangements with a view to making transactions in Investments
Link to FCA firm register: https://www.fsa.gov.uk/register
Pairstech permissions are authorized through the “Passport Mechanism” across many European Countries.
Information we may collect from you
We may collect and process the following data about you:
Information that you provide to us when you register with us or in relation to products or services we provide to you, whether over the phone or via this website.
Website usage information which is collected using cookies (see below our section on cookies).
We may keep a record of correspondence with you and we may use tracking technology on any emails which we send to you.
Although this policy tells you about types of data we collect from you and how these are used, at the point at which you provide us with any information about you, we will ask for your consent to use that information.
A “cookie” is a small piece of encoded information sent by a web server to be stored on your web browser (Internet Explorer, Firefox) so that it can remember something about you such as username, password, references at a later date. This process enables us to provide you with personalized information and simplify your user experience. UCapital Asset Management uses persistent cookies that do not expire at the end of a user session. Cookies have three functions: security, log in and responsibility discharge.
The cookie stored on your web browser does not contain any personal information. The cookie is encrypted and only the UCapital Asset Management web server can read it.
A cookie is installed to ensure that there is a unique identification when a user visits the UCapital Asset Management website. This cookie enables us to determine what page the user will see next time he/she visits the website.
Our system will issue cookies when you visit our website. If you do not wish to have a cookie stored on your computer, you should disable them in your browser’s security options.
Uses made of your personal information
The personal information that you provide to us will be used for a number of different purposes including:
to manage and administer your account;
to offer you investment products and services (except where you have asked us not to do so) and to help us develop new ones;
to contact you with details of changes to products you have bought;
for internal analysis and research;
to comply with legal or regulatory requirements; and
to identify you when you contact us.
We may use external third parties to process your personal information on our behalf in accordance with these purposes.
Sharing of your personal information with others
Where you have notified us of your adviser, the personal information provided may be shared with such adviser. You must notify us in writing if you no longer wish us to share your personal information with your adviser or of any change to your adviser. Your adviser should have its own arrangements with you about its use of your personal information.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
We may disclose your personal information to any member of our group, which means our subsidiaries, our holding company and its subsidiaries.
We may disclose your personal information to non-affiliated subcontractors that perform support services for us.
We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
We may disclose or share your personal information with any regulatory authority, or to any person legally empowered to require such information; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may transfer your personal information outside the EEA for the purposes set out above. Where we do so we shall ensure that they safeguard your personal information to the same standards that we employ to protect such information.
Where we store your personal information
You have the right to receive details of the personal information we maintain on you. The provision of such information by us to you is subject to a payment of a fee currently fixed at £10.00 and to you supplying us with appropriate evidence of your identity. Please contact us by post at the address below or email if you wish to do this.
You may instruct us not to process your personal data for marketing purposes. You can exercise this right at any time by contacting at the email or address immediately below.
Updating your personal information
Please let us know if the personal information which we hold about you needs to be corrected or updated.
Your data controller
For the purposes of the UK Data Protection Act 1998, the data controller in respect of any personal information provided is UCapital Asset Management.
UCapital Asset Management is not responsible for and will not be liable to you or anyone else for any damages whatsoever (including direct, indirect, incidental, special, consequential, exemplary or punitive damages) arising out of or in connection with your use of or inability to use the website or the information, or any action or decision made by you in reliance on the website or the information, or any unauthorised use or reproduction of the website or the information, even if the we have been advised of the possibility of these damages.
This website content is dated as at 10 March 2021. Before relying on any information here, you should check that this is the most recently published information.
Information on the investment firm and its services.
UCAPITAL ASSET MANAGEMENT, approved trading name of PAIRSTECH CAPITAL MANAGEMENT LLP
Community investment firm with registered office in UK, 1/1A Telegraph Street, London – England – EC2R 7AR, VAT number n. 927253419, registered under n. 477155 of the register of companies authorized to provide financial services kept by the Financial Conduct Authority.
Share capital subscribed and paid up: 654,201 GBP
Investment services authorized:
Advising on investments (except on Pension Transfers and Pension Opt Outs)
Advising on P2P agreements
Agreeing to carry on a regulated activity
Arranging (bringing about) deals in investments
Dealing in investments as agent
Making arrangements with a view to transactions in investments
Managing an unauthorised AIF
This firm cannot hold client money. It may be able to control client money if it has the necessary requirements.
Method of communication between the customer and the company
Any communications between the Company and the customer, to receive information and documentation, as required by the Intermediaries Regulation, may take place in English or Italian and mainly by e-mail at the addresses and addresses indicated above, or by ordinary mail, by telephone on customer request.
Investment services offered:
Information relating to the advisory service relating to investments in financial instruments.
Following the MIFID Directive 2004/39 / EC, investment advice is considered as an investment service that can only be provided by authorized intermediaries.
An essential element of the investment advisory activity is “personalization”: the “personalized recommendation” must be directed to a specific investor, it must be based on the specific characteristics of the person (need to evaluate the service provided in terms of “Adequacy”, based on knowledge and experience in the field of investment services and financial instruments, financial situation, investment objectives, risk appetite). The recommendation must relate to a specific investment transaction in financial instruments: buy, sell, subscribe, exchange, redeem, hold a specific financial instrument or take guarantees against the issuer with respect to this instrument, exercise or not exercise any right conferred from a given financial instrument to buy, sell, subscribe, exchange or redeem a financial instrument.
The methods of providing this service will be suitably specified in the individual investment contracts.
Information relating to the portfolio management service.
The individual portfolio management activity qualified as “portfolio management” means the management, on a discretionary and individualized basis, of investment portfolios that include one or more financial instruments and within the scope of a mandate conferred from customers.
The Company has decided to provide this service on a contractual basis to professional customers. The methods of delivery and the characteristics of this service will be suitably specified in the individual investment contracts (information on the method and frequency of assessment of the financial instruments, description of the reference parameter, types of financial instruments that can be included in the client’s portfolio, types of operations that can be carried out, including any limits, management objectives and level of risk). For the purposes of the aforementioned additional information, please refer to what is expressly indicated in the portfolio management contract and in the related annex relating to the characteristics of the management.
With regard to the details of any proxies, it should be noted that the Company does not delegate to third parties the execution of the assignment received from the customer.
Information on Financial Instruments
The information reported in this chapter does not describe all the risks and all the other significant aspects concerning investments in financial instruments and investment advisory services and portfolio management, but have the purpose of providing some basic information on the risks associated with such services.
Further information – on the nature and risks of the transactions – necessary to allow the client to make informed and informed investment decisions, will be provided at the client’s request to operate in financial instruments and products.
A) Financial instruments
By purchasing equity securities (the most common securities of this category are shares), you become a shareholder in the issuing company, participating in the economic risk of the same; those who invest in equity securities have the right to receive annually the dividend on the profits achieved in the reference period that the shareholders’ meeting will decide to distribute. The shareholders’ meeting may however decide not to distribute any dividends.
In particular, the shares attribute specific rights to the holder: administrative rights (voting rights, right of appeal of the shareholders’ resolutions, right of withdrawal, option rights) and economic and property rights (right to dividends, right of reimbursement).
The main special categories of shares, other than ordinary shares, are: shares backed in losses, which are characterized by the different incidence of the participation in the losses; preference shares in the distribution of profits, to which a greater share of profits is attributed than that pertaining to ordinary shares, or to which a temporal priority is attributed in the distribution of profits compared to ordinary shares; savings shares, which constitute shares without voting rights, endowed with particular capital privileges.
They are financial instruments representative of the faculty, recognized to shareholders and convertible bond holders, to underwrite a number of securities proportional to the shares already held at the time of the related shareholders’ resolution during the capital increase or issue of a new convertible bond loan. the new transaction or potentially held on the basis of the conversion ratio relating to the convertible bonds still outstanding.
By purchasing debt securities (the most common debt securities are bonds), you become a lender of the company or entities that issued them and you have the right to periodically receive the interest required by the issue regulation and, upon expiry, the repayment of the loaned capital. Debt securities differ from equity securities (including shares) because, while the latter guarantee their owner the right to participate in the management of the company and a dividend which is subject to the existence of profits, the former attribute to the owner only a credit right which must in any case be satisfied on the due date, regardless of the results of the business year.
Below is a description of the bonds, the main debt securities.
In traditional bonds, the subscriber of the security pays the issuer a sum of money that generates interest and, on a pre-established maturity, is returned. Interest can be paid periodically, during the life of the security, or at maturity (zero coupon) and the measure can be fixed (fixed rate bonds) or variable in relation to the trend of market rates (variable rate bonds). In any case, the criteria for their determination are established at the time of subscription and their application does not present elements of complexity. It is possible to classify the bonds according to the issuer, distinguishing between bonds issued by a commercial company governed by private law (corporate bonds), bonds issued by international institutions and entities (supranational bonds) and bonds issued by a government (government bonds).
Lastly, mention must be made of certificates of deposit, that is negotiable securities (similar to credit securities) representative of term deposits, which are issued by banks. The subscriber (depositor) lends to the bank a sum of money with a time limit (i.e. cannot request early repayment), receiving in exchange a title representative of the loan made. Certificates of deposit are usually issued with maturities that can vary from 6 to 18 months which are called short-term certificates; however, there are also certificates with maturities between 18 and 60 months, called medium-long term certificates.
Collective Investment Schemes (UCITS)
Collective savings investment schemes (collective investment undertakings) are mutual investment funds and variable capital investment companies (SICAVs).
UCITS are divided into harmonized UCITS and non-harmonized UCITS. Harmonized UCITS means mutual investment funds and variable capital investment companies (SICAVs) compliant with EU directive no. 85/611 / EEC and subsequent amendments. With the issue of the aforementioned community regulations, it was intended to provide a series of minimum requirements relating to the authorization procedures, control, structure, activities and information to which a UCITS must comply. Compliance with these minimum harmonization requirements allows, in fact, the SGR or the investment company with variable capital (SICAV) to offer in another EU member country respectively the units of its mutual funds and its shares under the free marketing, being subject to control by the supervisory authority of your country of origin.
Non-harmonized funds, on the other hand, are characterized by greater freedom of investment of the assets collected compared to harmonized funds. Indeed, the constraints and limitations provided for by Community law for harmonized funds are not applied to them. Speculative funds, by their nature, are non-harmonized funds falling within the scope of application of the AIFMD Directive 2011/61 / EU.
By mutual investment fund is meant the autonomous assets, divided into shares, pertaining to a plurality of participants, managed upstream. The fund assets, whether open or closed, may be collected through one or more issues. Mutual funds are set up and managed by asset management companies (asset management companies). The management activity is carried out through purchase and sale operations and any other administrative act that is deemed appropriate or useful to increase the value of the fund and possibly distribute the proceeds to the participants and which is not precluded by legislative provisions, by provisions issued by the supervisory bodies and the clauses of the fund regulations. Mutual funds can be open or closed, i.e. funds whose participants have the right to request the repayment of the units at any time or funds whose right to the repayment of the units is recognized to the participants only at predetermined deadlines. Each fund is characterized by having a predefined portfolio composition in terms of asset classes. In this respect, the funds are divided into transferable and real estate funds; the following categories of funds belong to the category of transferable funds: (i) equity, (ii) balanced, (iii) bonds; (iv) liquidity, (v) flexible.
Real estate funds are the mutual funds that invest in real estate.
Variable capital investment company
Variable capital investment companies (SICAVs) raise capital among savers and invest them in financial markets. They differ from mutual funds mainly in that the subscriber does not buy shares, but shares in the company. With the investment in the SICAV, in fact, you become a shareholder with the possibility of exercising your right to vote. In addition to the different legal nature of mutual investment funds, their peculiarity consists in the high specialization of individual sectors in different market areas and / or sectors capable of meeting all investment needs.
Exchange Traded Funds and Commodities
Exchange Traded Funds (ETF abbreviation, literally “listed index funds”) are a particular category of funds or Sicav which are characterized by having the same composition as a specific stock market index; the certificates representing the units are admitted to trading on a regulated market. In fact, ETFs passively replicate the composition of a market index (geographic, sectoral, equity or bond) and consequently also its return. ETFs can therefore be defined as open passively managed UCITS whose composition is tied to a reference benchmark, that is the basket of securities that make up a specific index.
Equivalent funds are the Exchange Traded Commodities, funds that replicate the trend of commodity price indices.
Bonds whose repayment and / or whose remuneration is indexed to the trend of prices / values of one of the following financial assets / financial parameters (also through the incorporation of derivative financial instruments in the title) are considered structured:
Structured bonds have as a common characteristic particular and innovative methods of calculating the coupon or redemption value, sometimes particularly complex.
Structured bonds can be admitted to official stock exchange listing.
However, it should be noted that not all structured bonds are listed on regulated markets and, if they are, the observed liquidity levels are not high. This circumstance may create difficulties in the event that the subscriber wishes to sell his security early, as the prices may not reflect the real value, also because the saver could find himself in the position of having to sell the bond to the same issuer in a single position. buyer on the market.
Illiquid products are those which determine for the investor obstacles or limitations on the sale within a reasonable period of time, at significant price conditions, that is, such as to reflect, directly or indirectly, a plurality of interests in the purchase and sale, or they are characterized by a liquidity and liquidity risk
B) The Risks of Investments in Financial Instruments
To appreciate the risk deriving from an investment in financial instruments, it is necessary to bear in mind the following elements:
The price of each financial instrument depends on numerous circumstances and can vary in a more or less accentuated way depending on its nature.
Equity and debt securities
First of all, a distinction must be made between equity securities (and in particular shares) and debt securities (including the bonds described above).
All other things being equal, a capital security is more risky than a debt security, since the remuneration due to its owner is more tied to the economic performance of the issuing company. The holder of debt securities, on the other hand, will risk not being remunerated only in the event of financial failure of the issuing company. Furthermore, in the event of the bankruptcy of the issuing company, the holders of debt securities will be able to participate, with the other creditors, in the subdivision which in any case usually takes place in very long times of the proceeds deriving from the realization of the company’s activities, while it is almost excluded that holders of equity securities may be repaid a portion of their investments.
Specific risk and generic risk
For both equity and debt securities, the risk can ideally be divided into two components: specific risk and generic (or systematic) risk. The specific risk depends on the specific characteristics of the issuer and can be substantially decreased by dividing its investment between securities issued by different issuers (portfolio diversification), while systematic risk represents that part of the price variability of each security which depends on the market fluctuations and cannot be eliminated through diversification. The systematic risk for equity securities dealt in on an organized market arises from changes in the market in general; changes that can be identified in the movements of the market index. The systematic risk of debt securities arises from fluctuations in market interest rates which affect the prices (and therefore returns) of the securities in a more accentuated way the longer their residual life is longer; the residual life of a security on a certain date is represented by the period of time that must elapse from that date at the time of its repayment.
The issuer risk
For investments in financial instruments it is essential to appreciate the capital solidity of the issuing companies and their economic prospects taking into account the characteristics of the sectors in which they operate.
It must be considered that the prices of equity securities reflect at all times an average of the expectations that market participants have regarding the earnings prospects of the issuing companies. With reference to debt securities, the risk that the issuing companies or financial institutions will not be able to pay interest or repay the loaned capital is reflected in the amount of interest that these obligations guarantee the investor. The higher the perceived risk of the issuer, the higher the interest rate that the issuer will have to pay to the investor. To evaluate the adequacy of the interest rate paid by a security, the interest rates paid by the issuers whose risk is considered lower, and in particular the yield offered by government bonds, with reference to issues with equal deadline.
The risk of interest
With reference to debt securities, the investor must keep in mind that the effective measure of interest continuously adjusts to market conditions through changes in the price of the securities themselves. The yield on a debt security will approach that embedded in the security at the time of purchase only in the event that the security itself was held by the investor until maturity. If the investor needs to disinvest the investment before the maturity of the security, the actual return may turn out to be different from that guaranteed by the security at the time of its purchase. In particular, for securities that provide for the payment of interest in a predefined and non-modifiable manner during the term of the loan (fixed rate securities), the longer the residual life the greater the variability of the price of the security itself with respect to changes in the market interest rates. For example, consider a zero coupon fixed rate security that provides for the payment of interest in a single solution at the end of the period with a residual life of 10 years and a yield of 10% per year; the increase of one percentage point of the market rates determines, for the aforementioned security, a price decrease of 8.6%.
It is therefore important for the investor to verify within what time frame he may need to disinvest the investment.
The effect of diversifying investments. Collective investment schemes
As mentioned, the specific risk of a particular financial instrument can be eliminated through diversification, i.e. by dividing the investment between multiple financial instruments. However, diversification can be costly and difficult for an investor with limited assets to implement. The investor can achieve a high degree of diversification at low costs by investing his assets in units or shares of collective investment schemes (mutual funds and SICAV variable capital investment companies). These bodies invest the funds paid by savers among the different types of securities envisaged by the regulations or investment programs adopted.
With reference to open-end mutual funds, for example, savers can enter or exit the investment by buying or selling the units of the fund on the basis of the theoretical value (increased or decreased of the expected commissions) of the share; value that is obtained by dividing the value of the entire managed portfolio of the fund, calculated at market prices, by the number of units in circulation.
It should be emphasized that investments in these types of financial instruments can still be risky due to the characteristics of the financial instruments in which they plan to invest (for example, funds that invest only in securities issued by companies operating in a particular sector or in securities issued by companies based in certain states) or due to insufficient investment diversification.
Liquidity and liquidity
The liquidity of a financial instrument consists in its aptitude to quickly transform itself into money without loss of value.
It depends primarily on the characteristics of the market in which the security is traded. In general, other things being equal, the securities traded on organized markets are more liquid than the securities not traded on said markets. This is because the supply and demand of securities is mainly channeled to these markets and therefore the prices recorded therein are more reliable as indicators of the effective value of the financial instruments.
However, it should be considered that the disposal of securities traded in organized markets that are difficult to access, because based in distant countries or for other reasons, may in any case entail for the investor difficulties in liquidating its investments and the need to incur additional costs by configuring therefore a limit to the liquidity of the securities themselves.
The liquidity condition, presumed but not ensured by law by the listing of the security on regulated markets or in MTF, could also be guaranteed by the commitment of the same intermediary to repurchase according to pre-established criteria and mechanisms consistent with those that led to the pricing of the product in the primary market.
By way of example, but not limited to, reference will be made below to bank bonds, insurance policies and derivatives negotiated over the counter, which for legal or factual reasons are characterized as products with specific “liquidity risk”, determined from legal impossibility or factual limitation to divestment.
If a financial instrument is denominated in a currency other than the reference currency for the investor, in order to assess the overall risk of the investment, the volatility of the exchange ratio between the reference currency (Euro) and the foreign currency in which the investment is denominated.
The investor must consider that the exchange ratios with the currencies of many countries, especially those in the developing world, are highly volatile and that in any case the trend in exchange rates can significantly affect the overall investment result.
The other factors causing general risks
a) Transactions that can be carried out in markets located in other jurisdictions.
Transactions performed on markets based abroad, including transactions involving financial instruments also dealt in national markets, could expose the investor to additional risks. These markets could be regulated to offer reduced guarantees and protections to investors. Before carrying out any operation on these markets, the investor should inquire about the rules that concern such operations. It must also consider that, in such cases, the supervisory authority will be unable to ensure compliance with the rules in force in the jurisdictions where the operations are performed. The investor should therefore inquire about the rules in force on these markets and any actions that can be taken with reference to these transactions.
b) Transactions that can be carried out outside organized markets
Intermediaries may carry out transactions outside organized markets. The intermediary to which the investor is addressed may also place himself in direct counterpart of the customer (that is, act on his own account). For transactions carried out outside organized markets, it may be difficult or impossible to liquidate a financial instrument or appreciate its effective value and assess the actual risk exposure, in particular if the financial instrument is not traded on any organized market.
For these reasons, these operations involve taking higher risks.
Before carrying out these types of operations, the investor must take all the relevant information on them, the applicable rules and the consequent risks.
c) Responsibilities, Risks and Charges
The investment advisory service allows you to take advantage of the knowledge and experience of professionals in the sector in choosing the financial instruments to invest in.
The service provided by the Company consists exclusively of providing personalized advice and recommendations useful for carrying out investment and divestment operations. It is therefore understood that the customer remains free to follow or not follow the advice and recommendations received, as well as to choose the intermediary to be used. Any investment or divestment decision is therefore the exclusive responsibility of the customer.
The Company will not be responsible for any damage and losses suffered by the customer due to the adoption of recommendations suggested to the customer. The obligation of the company is an obligation of means and not of results. the Company does not guarantee any specific results related to the consultancy activity provided.
The investor must inquire fully with the intermediary about the characteristics of the service and the degree of risk deriving from the use of the suggestions and must conclude the contract only if he is reasonably sure that he has understood the nature of the service and the degree of risk exposure that counseling it entails.
The portfolio management service allows you to take advantage of the knowledge and experience of professionals in the sector in choosing the financial instruments to invest in and in carrying out the related operations. The customer, with pre-agreed methods, can intervene directly during the performance of the management service by issuing instructions binding on the Company.
The riskiness of the management is expressed by the variability of the economic results achieved by the manager. The customer can direct the riskiness of the management service by contractually defining the limits within which the management choices must be made. These limits, taken as a whole, define the characteristics of the management. The actual riskiness of the management, however, depends on the choices made by the Company which, although they must remain within the contractual limits, are usually characterized by wide margins of discretion regarding the securities to be bought or sold and the moment in which to carry out the operations. The customer must obtain detailed information from the Company on the characteristics and the degree of risk of the management and must conclude the contract only if he is reasonably sure that he has understood the nature of the management and the degree of exposure to the risk that it entails. Before concluding the contract, once the degree of risk of the chosen management has been appreciated, the client and the Company must assess whether the investment is adequate for the client, with particular reference to the balance sheet and investment objectives. The portfolio management service does not imply any guarantee of keeping the value of the assets entrusted under management and conferred both initially and during the management relationship unchanged.
Commissions and other charges
Before concluding the investment or portfolio management consultancy contract, the investor must obtain detailed information regarding all the commissions and the methods of calculating them, the costs and other charges due to the intermediary. However, this information must be reported in the relevant contract.
The fees and charges due to the intermediary for the investment advisory service are customized according to the intervention methods requested by the Customer. The variables that determine the overall cost of the service refer to the number of personal meetings with analysts, the amount of assets declared and the complexity of the instruments.
The minimum amount is indicated in the contract form for the provision of the consultancy service and is available, at the Company’s headquarters, to every potential customer.
The actual amount is agreed in pre-contractual phase with the customer and reported in the consultancy contract subsequently stipulated and signed by the customer.
The fees due to the intermediary for the portfolio management service are determined in a minimum and maximum percentage based on the amount of assets under management.
The percentages and charges applied are indicated in the contract form for the provision of the management service available to each potential customer at the Company’s headquarters.
The actual amount is agreed in pre-contractual phase with the customer and reported in the management contract subsequently stipulated and signed by the customer.
Information on client classification and summary of the main rules of conduct pursuant to the Mifid directive
In the context of the rules provided by the MIFID Directive regarding investor protection, the Company must communicate to customers their classification according to three specific categories of retail client, professional client and qualified counterparty. In providing investment services, the Company is required to observe distinct rules of conduct according to the specificities of each of the three categories, with a higher customer protection regime with reference to the category of retail clients and progressively less stringent for the category of professional clients and qualified counterparties.
The current provisions regarding the classification of customers allow intermediaries to distinguish the following categories:
Retail customers are a residual category, being defined as all those who are neither professional customers nor qualified counterparties.
The professional client can be private or public.
The private professional client is a client who possesses the experience, knowledge and skills necessary to consciously make his / her investment decisions and to correctly assess the risks it takes. Professional clients are divided into:
In particular, the following fall into the category of professional clients in law:
(1) the subjects who are required to be authorized or regulated to operate in the financial markets, be they Italian or foreign such as: a) banks; b) investment firms; c) other authorized or regulated financial institutions; d) insurance companies; e) collective investment undertakings and management companies of such bodies; f) pension funds and management companies of these funds; g) commodity dealers and commodity derivatives; h) entities that carry out trading on their own account on financial instrument markets and indirectly adhere to the settlement service, as well as to the clearing and guarantee system (locals); i) other institutional investors; l) stockbrokers;
(2) large companies that have at least two of the following dimensional requirements at individual company level: – balance sheet total: 20,000,000 EURO, – net turnover: 40,000,000 EURO, – own funds: 2,000,000 EURO.
(3) institutional investors whose main activity is to invest in financial instruments, including entities dedicated to the securitization of assets or other financial transactions.
The category of “on demand” professional customers identifies customers, other than those listed above, who possess the knowledge, experience and skills necessary to make investment decisions and correctly assess the risks they assume. A customer can fall into this category as long as he expressly requests it and as long as certain criteria and procedures are respected. In assessing this request, the Company cannot resort to any presumption and must adequately verify the customer’s competence and market experience.
In order to be classified in this category, it is therefore necessary to follow a special procedure which provides:
(a) written request for up-grading by the customer (both natural and legal person) with which the customer communicates that he wants to be treated as a professional customer;
(b) written notice of the Company to the customer regarding the protections and rights that could be lost if the up-grading request is accepted;
(c) written declaration by the customer that he is aware of the consequences of losing these protections and rights;
(d) assessment by the Company of the client’s ability to consciously adopt its investment decisions and understand the related risks assumed. The assessment relates to the customer’s competence, experience and knowledge. For the purposes of the assessment, the Company may refer to the “proficiency test” applied to the managers and directors of the subjects authorized pursuant to the directives in the financial sector. During the aforementioned assessment, at least two of the following requirements must be met:
In the case of legal persons, the above assessment is conducted with regard to the person authorized to carry out transactions on their behalf and / or to the legal person itself;
(e) verification by the Company, on the basis of the reasonable measures adopted for this purpose, that the client who requests to be treated as a professional client meets the requirements referred to in letter d) above;
(f) acceptance or otherwise of the up-grading request by the Company.
The qualified counterparties are professional clients by right in which the intermediary who provides the services for the execution of orders on behalf of third parties, negotiation on own account and / or receiving / transmitting orders, is not required, unless otherwise agreed with the customer , compliance with certain obligations under the reference legislation.
If, however, services other than those indicated above are provided for the aforementioned subjects, the qualified counterparties will be treated as “professional clients” and therefore, in the provision of investment advisory services and portfolio management as well as placement, the intermediary will be required to observe the same rules of conduct applicable to professional investors as identified in the following paragraph relating to professional customers.
Pursuant to the regulations, the customer classified as “qualified counterparty” has the right to request, in general or for each individual transaction, to be classified differently, as a professional customer or, expressly, as a retail customer, with the consequent application of a different level of protection than the current one. The request is subject to the intermediary’s consent.
Conflicts of Interest
The Company has adopted a conflict of interest management policy aimed at preventing such conflicts from affecting customers in the context of the provision of investment and ancillary services. The management policy allows the identification of the circumstances that generate or could generate a conflict and, secondly, defines the procedures and measures to be followed to prevent, manage and monitor conflicts.
Clients must be given a precise description of this policy for managing situations of conflict of interest.
As explained, the Company has adopted a conflict of interest management policy which which is delivered to the customer together with this information.
The conflict of interest management policy is in any case available to the customer at the Company’s headquarters, which is available to provide the customer with clarifications at any time regarding its policy on conflicts of interest.
In relation to the provision of investment advisory and portfolio management services, the Company will not be able to pay or receive fees or commissions or provide or receive non-monetary services except within the limits and according to the conditions set by the reference legislation.
To this end, the Company makes the customer a description in the appropriate document which is delivered to the customer together with this information.
At the customer’s request, the Company will fulfill its disclosure obligations by sending more analytical communications relating to the agreements concerning the aforementioned fees, benefits or benefits, as required by the reference legislation.
Information on the strategy of transmission and execution of orders
The Company has adopted the strategy for the transmission and execution of orders as described in the specific document which is delivered to the customer together with this information.
Information Document on the handling of customer complaints
For any complaints, the customer can contact the Compliance function of UCapital Asset Management by email or post.
Complaints are processed by the Compliance UCapital Asset Management function which has adopted appropriate procedures to ensure the prompt handling of complaints submitted by customers.
The process of handling complaints relating to the provision of investment and ancillary services involves processing them within a maximum of 30 days from the receipt of the complaint.
The response to the complaint is sent, in the terms indicated above, by post or email to the address indicated by the customer.
For more info about complains, read the tab below.
Regulated activities that this firm has permissions for may be covered by the Financial Ombudsman Service (FOS). If you have complained to us and we haven’t responded satisfactorily, you can contact the Financial Ombudsman for help.
Regulated activities that this firm has permissions for may be covered by the Financial Services Compensation Scheme. If this firm has failed, you can contact the Financial Services Compensation Scheme for help.
Privacy, Terms and Conditions
UCapital Asset Management is an authorized trading name of Pairstech Capital Management LLP. Pairstech Capital Management LLP is authorised and regulated by the Financial Conduct Authority (FRN: 477155).
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Data Controller and Owner
UCapital Asset Management, authorized trading name of Pairstech Capital Management LLP – 1/1A Telegraph Street – EC2R 7AR London – United Kingdom
Definitions and legal references
Personal Data (or Data)
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Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
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The legal or natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
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The hardware or software tool by which the Personal Data of the User is collected.
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Scope of the Best Execution Obligation
UCapital Asset Management (the Firm) must take all sufficient steps to obtain the best possible result when executing, placing or transmitting client orders on behalf of a client [or when dealing on a request for quote basis (“RFQ”)], taking into account the execution factors (as defined below) (“best execution”).
The regulatory duty to provide best execution extends to Professional Clients only when their order or RFQ relates to a MiFID II financial instrument and the Firm is executing on behalf of such clients.
The Firm will not owe best execution where it has correctly categorised a client as an Eligible Counterparty (generally or for a particular type of product or transaction). The Firm is not permitted to deal with Retail Clients and therefore its best execution arrangements are not applicable to such persons.
The Firm will apply best execution in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of MiFID II financial instruments.
The Firm will provide best execution where it determines that the client is relying on the Firm to protect its best interests in relation to the pricing or other aspects of an order placed with the Firm (“legitimate reliance”). The Firm will assess legitimate reliance having regard to factors such as which party initiates the transaction, questions of market practice and the existence of a convention to “shop around”, the relative levels of price transparency within a market and the information provided by the Firm and any agreement reached. If the Firm determines that the client is not legitimately relying on the Firm then best execution will not apply.
In so far as the Firm receives specific instructions from a client as to how to execute a transaction, best execution will not apply as the Firm will instead follow those instructions to the extent possible. In such circumstances, the Firm will be deemed to have satisfied its best execution obligation, but only in respect of that part or aspect of the order to which the client instructions relate. To the extent that there are other parts or aspects of the order for which the Firm has not received specific instructions from the client, the Firm will apply its best execution arrangements as detailed in this Summary.
The Firm’s commitment to obtain the best possible result for its clients does not mean that it owes any fiduciary or other responsibilities over and above the specific regulatory obligations placed upon the Firm or as may be otherwise contracted between the Firm and its clients through terms of business or otherwise.
In complying with its regulatory obligation to obtain the best possible result when executing, placing or transmitting client orders on behalf of a client, the Firm will take into account the following factors when determining its execution arrangements (the “execution factors”):
The variety of execution factors that are taken into account and their order of relative priority will be determined by the Firm on a transaction by transaction basis.
It is the general policy of the Firm that the most important execution factor for its Professional Clients is the price at which the relevant financial instrument is executed. However, there may be circumstances where the primary execution factors vary and another factor, such as the likelihood of execution and settlement or the time it takes to execute a client order, becomes the most important execution factor and is given precedence over price.
When executing a client order, the Firm will take into account the following criteria for determining the relative importance of the execution factors (the “execution criteria”):
The Firm will apply the execution factors and criteria in a number of different ways, depending on the type of instrument involved, its liquidity and the role played by the Firm.
For fixed income instruments that are considered liquid, the Firm will seek best price on the market and will execute the trade with the client at the best price. In relation to fixed income instruments that are considered to be less liquid the firm may consider an OTC transaction to be the most appropriate form of execution or may also look to source niche counterparties. [In all cases, if the firm considers that after due enquiry it is able to offer a better price than is available at the relevant time on the market, it may execute the trade with the client.]
Having regard to the execution factors and criteria, the Firm may use one or more of the following venue types when executing client orders:
The Firm will not discriminate between execution venues when choosing an execution venue on behalf of a client. However, it is the general policy of the Firm that it will seek to execute orders directly with regulated markets through direct market arrangements. A list of Direct Market Access providers that may be used by the Firm is set out towards the end of this Summary.
Notwithstanding the above, and taking into account the execution factors and criteria, the Firm may use other execution venues when executing client orders.
Execution outside of a trading venue
The Firm may execute all or part of a client order outside of a trading venue. The Firm is required to obtain its clients’ consent in order to do so, which consent has been outlined in the terms of business.
The FCA’s rules require that where you have given the Firm a limit order for shares admitted to trading on a regulated market or MTF that is not immediately executed under prevailing market conditions, the Firm must make that unfulfilled limit order public immediately unless you expressly instruct us otherwise. We have framed our terms of business such that our clients are presumed to have instructed us not to make their unfulfilled limit orders public unless they tell us otherwise, as we believe the Firm’s ability to exercise discretion as to when and how unfulfilled limit orders are made public helps it to achieve the best possible result for its clients.
Order Handling and Aggregation
When carrying out client orders, the Firm is required to:
Aggregation and allocation of client orders
The Firm may carry out a client order (i.e. execute an order on behalf of a client or transmit client orders to other entities for execution) or a transaction for own account in aggregation with another client order (i.e. combine a client order or transaction for own account with another client order) provided it is satisfied that:
Where the Firm aggregates a client order with a transaction for own account and the aggregated order is partially executed, it will allocate the related trades to the client in priority to the firm, (COBS 11.3.10AEU).
Most corporate finance activity, such as underwriting and advisory services, does not involve the Firm executing, placing or transmitting client orders on behalf of a client, in which best execution does not apply.
However, depending upon the nature of the engagement, the Firm may execute, place or transmit client orders on behalf of a client in a corporate finance context, for example where the Firm is engaged to:
in which case best execution will apply.
Execution factors in a corporate finance context
Most corporate finance transactions are unique. The means that the Firm’s general policy of identifying price as the most important execution factor is less likely to apply and other execution factors, such as likelihood of execution and settlement and speed of execution are likely to be the most important execution factors, depending on the particular characteristics and context of each transaction.
Execution venues in a corporate finance context
Corporate finance transactions tend to involve the acquisition or sale of larger blocks of shares and often involve additional complexities which limit the choice of execution venues available to the Firm, such as the need for secrecy, the requirements of the market abuse regime (or other appropriate standards of market conduct) in the particular circumstances and, where/if relevant, compliance with the Takeover Code or similar rules. Moreover, there is no formalized market or settlement infrastructure for OTC transactions. The Firm’s choice of execution venue may therefore be further limited where there is only one venue where it can execute a transaction.
When selling shares or debt, the general policy of the Firm is to choose to build a book or negotiate a private placement with identified investors (or the client may expressly instruct the Firm to do so). In these circumstances, the third party investment firms involved (trading proprietary or agency positions) will constitute the execution venue. Alternatively, the Firm may choose to use the block trade facility of an investment exchange.
The Firm’s clients will be deemed to have provided implied consent to the content outlined in this Summary when they instruct the Firm to act on their behalf in relation to an order.
Monitoring and Review
At least annually, the Firm will review its best execution arrangements and policy to ensure their ongoing effectiveness. The review will include consideration of whether the Firm could obtain better results for its clients if it was to:
The Firm will also review its execution arrangements and policy whenever a material change occurs that could affect its ability to obtain the best possible result, on a consistent basis, for its clients (for example, a significant market event or material change to the Firm’s business model that could impact the parameters of the Firm’s best execution arrangements such as the execution factors specified above). Clients will be notified of any material changes to the Firm’s order execution arrangements or policy through publication of an updated version of this Summary [on the Firm’s website].
Annual Publication of Top 5 Execution Venues and Brokers
Each year the Firm will publish [on its website] data on its top execution venues and brokers used to obtain the best result for its clients, in respect of each class of financial instruments. Such data will include:
the top five execution venues in terms of trading volumes (the number of financial instruments traded times price for each transaction, cumulated for the year), where the Firm executed client orders in the preceding year, together with information on the quality of execution obtained; and
the top five brokers in terms of trading volumes to which the Firm transmitted or placed client orders for execution in the preceding year, and information on the quality of execution obtained.
As part of the European Commission’s Action Plan on financing sustainable growth of March 2018 (the “Action Plan”), Regulation (EU) 2019/2088 on sustainable Finance Disclosure regulation (SFDR) aims to provide greater transparency on the degree of sustainability of financial products to actually channel private investment towards sustainable investments while preventing green washing. Its phase-in implementation will start from 10 March 2021. Some of the EU taxonomy requirements will also help to achieve this purpose by requiring those financial products to disclose to what extent they invest in environmentally sustainable economic activities.
The SFDR defines and introduces transparency requirements on financial products’ characteristics that can be used and compared to assess their degree of sustainability:
Consideration of sustainability risks that are risks of loss of value of underlying assets due to environmental or social events
Sustainable investments in economic activities that contribute to environmental or social objectives. They include investments in EU-taxonomy eligible economic activities;
Consideration of Principal Adverse Impacts (PAI) on sustainability factors which are the negative effects on environmental, social and employee matters as well as respect for human rights, anti-corruption and anti-bribery resulting from an investment decision.
The regulation applies to financial products listed below and extends to their product manufacturers and their financial advisers who are located in the EU:
Portfolio managed by investment firms
Alternative investment funds (AIFs) and UCITs
Insurance-based investment products (IBIPs)
Pension products, Workplace pensions products regulated under the IORP directive and PEPP
From 10 March 2021, all in-scope financial product will have to disclose in pre-contractual documents information on whether and how they consider sustainability risks. Their product manufacturers and advisers will have to disclose information on the integration of sustainability risks in the investment decision-making process or the investment advice process, as well as information on how remuneration policies are consistent with the integration of sustainability risks.
Financial products “promoting ESG characteristics” or “investing in sustainable investments” will have to disclose in pre-contractual documents and periodic reports information to detail those characteristics or investment objectives and how they have been attained.
Large product manufacturers will have to disclose, at entity level, their due diligences and engagement policies on consideration of PAI on sustainability factor and, from 1 January 2023, for each product they manage.
29 December 2019 – Entry into force
31 January 2021 – Finalisation of ESAs RTS on PAI indicators to be disclosed by product manufacturers with + 500 employees and pre-contractual and periodic information to be disclosed by financial products promoting ESG factors or investing in sustainable investments
10 March 2021 – First application date – pre-contractual disclosures on the degree of sustainability of financial products
30 June 2021 – Disclosure by product manufacturers (500+ employees) of their policies on consideration of PAI on sustainability factors
1 January 2022 – Disclosure in periodic documents by financial products on the attainment of their ESG characteristics or objectives in sustainable investments
1 January 2023 – Disclosure of consideration of adverse sustainability impacts financial products
Pairstech is firmly convinced that the value creation for its stakeholders and in general the development of a sustainable long term strategy for its portfolio companies require the introduction of environmental, social and corporate governance (“ESG”) guidelines into all the phases of its activity (investment, management and divestment stages).
Pairstech believes that the incorporation of the principles of sustainability into its ESG policy will lead to a more balanced risk-return profile for its investments and a long term path of growth.
In order to pursue a responsible investing strategy, Pairstech’s Board of Directors is going to approve and implement an ESG policy for its activity and will also promote ESG policies in all its portfolio companies, funds and portfolio managed.
The responsible investing principles, through the adoption of an ESG policy by Pairstech will lead to the introduction of policies, procedures and practices for Pairstech as an asset manager.
To testify its commitment, Pairstech is going to adhere to the Principles for Responsible Investment (www.unpri.org) initiative.
Pairstech understands that its activity and the activities performed have a footprint on the environment and through its ESG policy has the target to minimize this impact. Pairstech is committed to foster an environmentally responsible behaviour promoting these efforts also in its portfolio companies.
Pairstech has identified its environmental goals and intends to achieve the target of minimize its environmental impact, so Pairstech will:
All these actions will be implemented at Pairstech and will be promoted by Pairstech in all the companies of the UCapital Asset Management Group.
Pairstech will assess environmental related aspects during the pre-investment due diligence analysis and will encourage parented companies to respect ESG criterias.
Pairstech considers that social aspects are crucial in the investment activity. Taking this into account, Pairstech will:
Pairstech considers that principles as transparency, fairness and meritocracy should inspire its activity and shall be promoted also among its parented companies; all managers and employees are asked to promote the respect of these principles not only for what concerns its human resources (recruitment, training, development and rewards) but also for what concerns the management of the businesses.
Pairstech understands that governance issues are crucial for an efficient management of a business; taking this into account, Pairstech:
Pursuant EU Regulations 2019/2088 and 2020/852, please find the following disclosures:
Voluntary slavery and human trafficking statement
Pairstech Capital Management LLP is making a voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015.
We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.
We are a financial services firm providing various products and services in the investment sector.
Our annual turnover is under £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains.
Our commitment to ethical trading
Our Anti-slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due diligence and risk assessment
To help identify and monitor the risk of slavery and human trafficking in our supply chain we vet suppliers and sub-contractors to ensure that they are committed to ethical labour practices.
We only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies).
Effectiveness in combating slavery and human trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 31 December 2020. It was approved by the board on 21 December 2020.
UCapital Asset Management is firmly convinced that the value creation for its stakeholders and in general the development of a sustainable long term strategy for its portfolio companies require the introduction of environmental, social and corporate governance (“ESG”) guidelines into all the phases of its activity (investment, management and divestment stages). UCapital Asset Management believes that the incorporation of the principles of sustainability into its ESG policy will lead to a more balanced risk-return profile for its investments and a long term path of growth. In order to pursue a responsible investing strategy, UCapital Asset Management’s Board of Directors is going to approve and implement an ESG policy for its activity and will also promote ESG policies in all its portfolio companies, funds and portfolio managed. The responsible investing principles, through the adoption of an ESG policy by UCapital Asset Management will lead to the introduction of policies, procedures and practices for UCapital Asset Management as an asset manager. To testify its commitment, UCapital Asset Management has requested to adhere to the Principles for Responsible Investment (www.unpri.org) initiative.
UCapital Asset Management’s voting policy is in line with its vision as a Responsible Investor. Right from when it was created, UCapital Asset Management considered this dimension of responsibility as one of its founding pillars. Furthermore, it meets the demand of a growing number of our clients who expect us to deliver long-term performance and to ensure the environmental and social quality of their investments.
Issues of social responsibility and sustainable development, such as those of governance, are essential in the assessment of a company. Only a global vision of the company, going beyond the purely financial aspect and integrating all risks and opportunities, in particular for ESG criteria (Environment, Social, Governance), allows an assessment of its intrinsic value and long-term economic performance.
The social acceptance of a company’s practices contributes to its image, and therefore indirectly to its development and profitability for its shareholders.
Our voting policy is in line with this approach and is therefore directly based on our analysis of a company in all these aspects.
The situation and practices of a company must be assessed over time. UCapital Asset Management wishes to take into account, in its analysis, the evolution of these practices and the commitments made by the company with a view to their improvement.
We exercise our responsibility as an investor in the following three areas:
In July 2010, the Financial Reporting Council (FRC) published its UK Stewardship Code (the “Code”) for institutional investors.
The FRC is the UK’s independent regulator responsible for promoting high quality corporate governance and reporting to foster investment. It sets standards for corporate reporting, actuarial practice, accounting and auditing.
The Code is designed to promote better dialogue between shareholders of UK listed stocks and company boards, and more transparency about the way in which investors oversee the companies they own. It sets out good practice on engagement with investee companies to which institutional investors should aspire.
UCapital Asset Management (“UCapital Asset Management”) is authorised and regulated by the Financial Conduct Authority.
UCapital Asset Management supports the Code’s principles as best practice and the details shown below are a general overview of the processes and policies currently in place.
Institutional investors should:
(1) Publicly disclose their policy on how they will discharge their stewardship responsibilities
UCapital Asset Management believes that proxy voting is the principal fundamental measure for communication with corporate management. Therefore, we have set out clear voting policies and standards by which we discharge our stewardship responsibilities.
(2) Have a robust policy on managing conflicts of interest in relation to stewardship and this should be publicly disclosed
UCapital Asset Management acknowledges that conflicts of interest may arise in the context of stewardship responsibilities. Therefore, we have established a robust policy for managing conflicts of interest with regard to proxy voting, which we consider to be our primary channel through which we discharge our stewardship responsibilities. Please refer to Proxy Voting Policy mentioned above.
(3) Monitor their investee companies
UCapital Asset Management portfolio managers, and corporate governance specialists regularly monitor and eventually maintain contacts with the companies into which they invest on behalf of clients. These allow us to evaluate key factors determining our investment decisions, such as the development of companies’ business operations, capital structures and financial standings, and strategic plans; as well as to monitor essential elements concerning a company’s sustainability, such as corporate governance and corporate social responsibility activities.
(4) Have a clear policy on voting and disclosure of voting activity
UCapital Asset Management makes proxy voting judgments based on our Proxy Voting Policy which applies to all offices. Portfolio managers and specialists act on behalf of their clients in a manner consistent with the corporate governance principles, proxy voting policy and standards stated above.