UK Stewardship Code 2020

Date: 23 Nov 2020

UK Stewardship Code 2020

Effective from 1 January 2020, the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”) was updated to be applicable to a broader range of investment strategies, such as real estate and infrastructure. It also reflects the increasing importance of environmental factors, particularly climate change, as well as social and governance factors as material issues for asset managers to consider when making investment decisions.

In the 2020 version, the Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society”.

To view the full Stewardship Code Disclosure, please view here.

Contact

James Lloyd

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Sophie Carr

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Terms & conditions

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Information on this Site

The information on this website ("Information") is issued by Advent Capital Investments Ltd ("Advent Capital Investments Ltd"), a company incorporated in England and Wales, authorised and regulated by the Financial Conduct Authority ("FCA") and its registered office is at 55 Wells Street, London, W1T 3PT.

The Information is not directed at any person in any jurisdiction where it is illegal or unlawful to distribute, access and use such information or where such distribution, access or use would subject Advent Capital Investments Ltd to any registration requirements within such jurisdiction. Advent Capital Investments Ltd disclaims all responsibility if you access or download any Information in breach of any law or regulation of the country in which you reside.

The Information is not directed at any person in the United States and this site is not intended to be used by any person in the United States unless those persons are existing investors in funds managed by Advent Capital Investments Ltd and they have applicable US exemptions.

Accordingly, all persons who access this site are required to inform themselves of and to comply with all applicable sales restrictions in their home country.

No Liability

Whilst all reasonable steps have been taken to ensure the accuracy and completeness of the Information, no representation, warranty or undertaking is given as to the accuracy or completeness of the Information by Advent Capital Investments Ltd or any of its associated companies and no liability is accepted by such persons for the accuracy or completeness of such Information. In no event will Advent Capital Investments Ltd or any of its associated companies be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the Information, or on any other hyper-linked site, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment, or otherwise, even if Advent Capital Investments Ltd is expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that Advent Capital Investments Ltd has to its customers under the regulatory system in the United Kingdom.

You should be aware that the Internet is not a completely reliable transmission medium and access to and use of this website is at your own risk. Advent Capital Investments Ltd does not accept any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. Furthermore, we accept no liability in respect of losses or damages arising out of changes made to the content of the website by unauthorised third parties. This does not exclude or restrict any duty or liability that Advent Capital Investments Ltd has to its customers under the regulatory system in the United Kingdom.

Indemnity

You agree to indemnify, defend, and hold harmless Advent Capital Investments Ltd, its affiliates and licensors, and the directors, officers, employees, and agents of Advent Capital Investments Ltd and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information.

Risk Factors

The value of investments may go down as well as up, and investors may not get back all or any amount originally invested. Income or other returns from investments are subject to change and may be lower than estimated. Past performance is not a reliable indicator of future performance.

Advent Capital Investments Ltd manages funds which invest in real property and which may be subject to higher risk and volatility than other funds and may not be suitable for all investors. Further, the funds may be leveraged and their portfolios may lack diversification thereby increasing the risk of loss.

The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences.

Copyright, Trademarks and Other Rights

Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Advent Capital Investments Ltd, its licensors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The Information may not otherwise be reproduced, distributed, stored or transmitted without Advent Capital Investments Ltd's written consent. Nothing on this site should be considered as granting any licence or right under any trademark of Advent Capital Investments Ltd or any third party.

Accuracy of Information

The Information (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by Advent Capital Investments Ltd to be reliable, but is not guaranteed as to its accuracy or completeness and should not be relied upon. The Information is provided without obligation on the part of Advent Capital Investments Ltd and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at his own risk. The Information does not constitute an offer to buy or sell or an invitation to make an offer to buy or sell shares, units or interests in any investment fund referred to herein.

Information is current only as at the date it is first posted and may no longer be true or complete when viewed by you. All Information may be changed or amended without prior notice although Advent Capital Investments Ltd does not undertake to update this site regularly. Advent Capital Investments Ltd shall not be obliged to remove any outdated information from the website or to expressly mark it as being outdated.

No Advice

The Information is provided for information purposes only and on the basis that you make your own investment decisions and do not rely upon it. Advent Capital Investments Ltd is not soliciting any action based on it and it does not constitute a personal recommendation or investment advice. Should you have any queries about the investment funds referred to on this site, you should contact your financial adviser.

Internet e-mail

Messages sent over the Internet cannot be guaranteed to be completely secure. They could be intercepted, lost or possibly altered. Advent Capital Investments Ltd cannot and will not take responsibility for this, and will not be liable to you or anyone else for any damages or otherwise, in connection with any message sent, either by you to Advent Capital Investments Ltd, or by Advent Capital Investments Ltd to you, over the Internet.

Sales Restrictions

United Kingdom: the funds referred to on this site are not recognised collective investment schemes for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the "Act"). The promotion of such funds and the distribution of offering materials in relation to such funds in the United Kingdom is accordingly restricted by law.

The information contained on this site is directed only at persons to whom unregulated funds may lawfully be promoted by a person authorised under the Act (an "authorised person"), by virtue of Section 238(5) or (6) of the Act. Promotion of these schemes will only therefore be made to recipients who have been assessed by the firm to fall into an applicable provision of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes)(Exemptions) Order 2001 or a category within Chapter 4.12 of the FCA Conduct of Business Sourcebook (COBS). Information must not be relied or acted upon by any other persons.

The funds referred to on this site are not regulated under the UK's financial services regulations and investors in those funds will not benefit from the rules and regulations made under the Act for the protection of investors as would apply to authorised schemes, or from the Financial Services Compensation Scheme.

An application for shares, units or interests in any of the funds referred to on this site should only be made having read fully the relevant prospectus and other fund documents.

Material Interests

Advent Capital Investments Ltd and its directors, officers and/or employees may have holdings in the funds referred to on this site and may otherwise be interested in transactions that you effect in those funds.

Linked Websites

This site may be linked to third party websites or contain information provided by third parties. These links are provided only as a convenience. Advent Capital Investments Ltd does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information. You acknowledge and agree that, as you have chosen to enter the linked website, use made of such websites or information is at your own risk. Advent Capital Investments Ltd does not accept any liability arising out of the information contained on any linked website or information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Advent Capital Investments Ltd has to its customers under the regulatory system in the United Kingdom. You should also be aware that the terms and conditions of such website and the website's statement relating to the collection and use of your personal information may be different from those applicable to your use of this website

Governing Law

You agree that your use of this site and any dispute arising from the use of this site is subject to English law and you submit to the jurisdiction of the English courts.

Privacy policy

This policy is issued by Advent Capital Investments Ltd ("Advent Capital Investments Ltd"), a company incorporated in England and Wales, authorised and regulated by the Financial Conduct Authority ("FCA") and its registered office is at 55 Wells Street, London, W1T 3PT.

This policy summarises how Advent Capital Investments Ltd use, share and store the data collected from you when you visit Advent Capital Investments Ltd's website or associated fund website, when you become an investor in a fund managed by Advent Capital Investments Ltd, when you become a tenant in a property owned by one of our funds or when you apply for a job with Advent Capital Investments Ltd. This privacy policy applies to Advent Capital Investments Ltd's site and all products and services offered by Advent Capital Investments Ltd and by entering our site you are agreeing to the policies described herein.

Advent Capital Investments Ltd is committed to safeguarding the personal information which you may provide to us and to the extent that Advent Capital Investments Ltd collects any personal information, Advent Capital Investments Ltd will hold it in confidence in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (EU) 2016/679 which came into force on 25 May 2018.

Information you share with us

You may be asked to voluntarily provide certain personal information details about you such as your name, address, telephone number, email address and other information in connection with Advent Capital Investments Ltd's customer or tenant registration procedures and job application process. Advent Capital Investments Ltd will use this information for the administration and servicing of your investments, performing its obligations under lease contracts, evaluating job applications and other related activities and to ensure compliance with its obligations under the UK regulatory regime. Advent Capital Investments Ltd may disclose the information to its agents and service providers.

Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You agree that Advent Capital Investments Ltd has the right to use and store such data on its internal systems and to transfer it to its associated companies and third- party agents and service providers where applicable, whether inside or outside the European Union to countries having an adequate level of data protection.

Information we collect from you

The Advent Capital Investments Ltd site collects both behavioural data (information about how you use our site); and technical data (information about the device you use to access our site). Advent Capital Investments Ltd uses the Google Analytics service provided by Google Inc. (“Google”) to collect this data.

Examples of behavioural data collected:

Terms entered via our search facility
Pages visited
Length of time spent on each page
The referring site from which you visited

Examples of technical data collected:

Your web browser type and version
Your device type and operating system

The site does not collect any data that makes you personally identifiable. The information obtained via Google Analytics is anonymised and cannot be attributed to any one individual. Google Analytics is set to retain data for a duration of 38 months.

Google provides a method to opt out of their Google Analytics service completely. Opting out will prevent Google Analytics from collecting your data from any site that uses their service.

Why we collect this information

This information provides us with a better understanding of how our site is being used. This understanding informs any improvements we undertake and ensures that the site and its content continue to best serve the needs of our visitors.

How we keep data safe

Advent Capital Investments Ltd adheres to the following practices to help keep the data that we process safe:

We encrypt and protect the transmission of information using Secure Sockets Layer (SSL).
We host our site and its contents with Amazon Web Services (AWS) on a secure server within the European Economic Area (EEA).
We limit server access by Internet Protocol (IP) address to only those that require it.
We have a server firewall in place that permits only standard inbound internet traffic – HTTP, HTTPS & SSH (restricted by IP).
We control and regulate access to our Advent Capital Investments Ltd data files and email accounts.
We enforce strong passwords and 2 factor authentication (2FA) wherever possible.

Cookies

We use cookies and similar technologies to offer you a better browsing experience, analyse site traffic and personalise content. Continuing to use our site will imply that you consent to our use of cookies. Please refer to our cookie policy for further information.

Provision of Information to Third Parties

A Data Processor is a third party with which we are required to share personal detail in the provision of investment and property management services. Advent Capital Investments Ltd will only share personal information in the following circumstances:

where the transfer is necessary to fulfil the requirements of the contract or operation for which the information was provided, and the third party is a Data Processor;
as required by a court order or any other legal or regulatory requirement.

Advent Capital Investments Ltd does not collect or compile personal data or information obtained through the Website for dissemination or sale to outside parties.

We may share your personal information with third party organisations:

Professional firms, agents and advisers who we use to help run your accounts and services, collect what you owe, administer funds, manage properties and explore new ways of doing business;
HM Revenue & Customs, regulators and other authorities;
Third parties as required through Advent Capital Investments Ltd’s regulatory requirements arising from the provision of investment services;
Fraud prevention agencies;
Companies we have a joint venture or agreement to co-operate with;
Companies within the Advent Group group
Organisations that introduce you to us;
Independent Financial Advisors, or other regulated entities or parties involved in the management of your relationship with Advent Capital Investments Ltd; or
Companies you ask us to share your data with.

We require all third parties with whom we share your personal information to respect the security of your data and to treat it in accordance with the law. We do not allow such third parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your Rights and Your Personal Data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of your personal data which Advent Capital Investments Ltd holds about you;
The right to request that Advent Capital Investments Ltd corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for Advent Capital Investments Ltd to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that Advent Capital Investments Ltd provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data;
The right to lodge a complaint with the Information Commissioners Office.

How long we keep your Data

We are required under the Markets in Financial Instruments Directive II (MIFID II) rules to retain all client related information for up to 7 years, after which time it will be destroyed. Personal information that we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. After you stop being a client, we may keep your data for up to 7 years for one of these reasons:

To respond to any questions or complaints;
To show that we treated you fairly; or
To maintain records according to rules that apply to us.

CVs in respect of unsuccessful applicants are deleted promptly following completion of the job application process.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask us to stop sending you marketing messages by contacting us at any time. If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact us on the details below to have the matter investigated.

Privacy policy changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For clarity, we shall include the date of the most recent revision at the bottom of the page. The amended privacy policy shall be effective as from that date. We therefore recommend that you refer back to this periodically.

Your rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Data controller

For the purpose of the Data Protection Act (1998) and the General Data Protection Regulations (GDPR) (EU) 2016/679 the Data Controller is Advent Capital Investments Ltd.

Last updated: 3 July 2019

Cookie policy

Advent Capital Investments Ltd use cookies and other similar technologies to improve your experience of our site. This policy refers to cookies used by sites utilising the adventcapitalinvestmentsltd.com domain name. For example, www.adventcapitalinvestmentsltd.com, pitch.adventcapitalinvestmentsltd.com.

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit our site. Cookies are sent back from your browser to our site on each subsequent visit, or to another site that recognises that cookie. Cookies allow us to recognise and distinguish between the different users and devices that visit our site.

Cookies perform many different tasks, such as letting you navigate between pages efficiently, remembering your preferences or improving the browsing experience.

For more information about cookies please visit:

Types of cookies used

We use the following cookies on our site:

Analytics cookies

Analytics cookies collect information about how visitors use our site, for instance which pages they access most often or the frequency of their visits. This information provides us with a better understanding of how our site is being used.

Our site uses the Google Analytics service provided by Google Inc. (“Google”). The information obtained via Google Analytics is anonymised and cannot be attributed to any one individual. Google provides further information on how Google Analytics uses cookies and also provides a method to opt out of Google Analytics completely.

Functionality cookies

Functionality cookies allow us to remember your saved preferences and therefore provide enhanced, more personal features. The information these cookies collect is anonymised and cannot track your browsing activity on other sites.

First party cookies

First party cookies are set by our adventcapitalinvestmentsltd.com domain rather than the domain of a third party. This allows us to closely control the data they collect.

Third party cookies

Third party cookies are set by a domain other than adventcapitalinvestmentsltd.com. For example, we use Google Maps to display the location of our office on our contact page. On visiting the page Google sets a third party cookie on your device so that it can determine if you are an authenticated Google account holder. If so, Google will customise the map accordingly.

Persistent cookies

Persistent cookies are those which remain on your computer or device for a predetermined duration and are activated each time you visit our site.

Privacy

We have carefully chosen the cookies used on our site and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

We may include links on our site to external sites (through our News articles for example). Please note that we cannot be responsible or liable for how these sites use cookies and process your personal data. We would recommend looking at the privacy & cookie policies of these sites for further information.

For more details of the personal data that we collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our privacy policy.

How can I change my cookie settings?

Most internet browsers are set to allow cookies by default though it is possible to change this setting and also remove any unwanted cookies via your browser preferences. Please note that some elements of our site may not work as expected should you disable cookies prior to visiting or remove any existing cookies once set.

The links below provide instructions on how to control Cookies in all the major browsers:

Please refer to your device’s documentation for manufacturers’ own browsers.

Changes to this cookie policy

We may amend this Cookie Policy at any time. Any changes to this policy will apply on your first visit to our site after the change has been made. You are therefore advised to check this page periodically. In the event of any conflict between the current version of this policy and any previous version – the current version has precedence unless it is expressly stated otherwise.

Last updated: 3 July 2019