Legal and Regulatory Information
Important regulatory information and risk warnings
Smith & Williamson is a diverse business. The following information is important and accords with Smith & Williamson's regulatory obligations.
Information on this site is published for private reference purposes only and is neither an offer to enter into a contract or agreement nor a solicitation to buy or sell any investment or service. The site is designed for UK residents and is not aimed at persons who are residents of any country, including the USA and South Africa or of countries in which the dissemination of information on funds/services on the Internet is forbidden.
This site is issued by the relevant UK and European regulated Smith & Williamson entity or entities. Smith & Williamson firms which are authorised and regulated by the Financial Conduct Authority are: NCL Investments Limited; Smith & Williamson Investment Management LLP; Smith & Williamson Investment Services Limited; Smith & Williamson Fund Administration Limited; Smith & Williamson Financial Services Limited and Smith & Williamson Corporate Finance Limited. Smith & Williamson Investment Management (Europe) Limited is regulated by the Central Bank of Ireland Smith & Williamson LLP is regulated by the Institute of Chartered Accountants in England and Wales for a range of investment business activities and is a member of Nexia International, a worldwide network of independent accounting firms. Nexia Smith & Williamson Audit Limited is registered to carry on audit work and regulated by the Institute of Chartered Accountants in England and Wales for a range of investment business activities and is a member of Nexia International, a worldwide network of independent accounting firms.
Smith & Williamson is not responsible for the accuracy of the information contained within the sites of other providers which have links to any pages of this site. Smith & Williamson does not endorse any information contained on other providers' sites. The contents of this site are based upon sources of information believed to be reliable. However, (1) no guarantee, warranty or representation, express or implied, is given as to the accuracy or completeness of such information; and (2) no Smith & Williamson company nor any of its officers, directors or employees accepts any liability or responsibility in respect of the information expressed herein which, moreover, is subject to change without notice.
The performance information contained on the site contains information which accords with UK performance standards. Past performance is not a guide to future performance. The value of investments may go down as well as up and you may not get back the amount you originally invested. Investors should note that changes in rates of exchange may have an adverse effect on the value, price or income of investments. There are additional risks associated with investing in emerging or developing markets. Investments in higher yielding bonds issued by borrowers with lower credit ratings may result in greater risk of default and have a negative impact on income and capital value. Tax rates and reliefs may change and the value of tax reliefs depends on individual circumstances. Local laws may have an impact on your investments.
Smith & Williamson and its affiliated companies and their directors and employees may, as principal or as agent, make purchases, sales and offers to purchase or sell in the open market or otherwise and may have positions/options in investment(s).
Revised Shareholder Rights Directive (SRD II)
Smith & Williamson Fund Administration Ltd
The FCA issued a policy statement PS19/13: Improving shareholder engagement and increasing transparency around stewardship, which sets out its proposed new rules to implement the Shareholder Rights Directive (SRD II) in the UK. SRD II is an EU legislation was transposed into the national law of the UK on 10 June 2019. The new requirements are aimed at promoting effective stewardship and long term investment decision making. It sets requirements in several areas, including transparency of engagement policies and investment strategies across the institutional investment community.
SRD II sets certain transparency obligations for European institutional investors – i.e. pension funds and regulated life insurers and on European Asset Managers, such as investment management firms, UCITS Management Companies and AIFM’s, to the extent investments in EU equity instruments are made on regulated markets. Smith and Williamson Fund Administration Ltd (“SWFAL”), as both a UCITS Management Company and Alternative Investment Fund Manager (AIFM), has published an engagement policy available here, detailing its position on the application of the SRD II transparency obligations to its firm’s activities.
In summary, since SWFAL does not carry out investment management for its funds, does not invest in shares of companies traded on a regulated market and since such activities are delegated to third party authorised and regulated investment managers, SWFAL is out of scope of the SRD Rules and has therefore chosen not to comply with the requirements. Although SWFAL delegates the investment management activity of its funds to third party investment managers, it does not delegate the overall responsibility for the fund’s adherence with the applicable regulations and legislations and SWFAL maintains robust oversight over the activities of its funds and its delegate invested managers. SWFAL will monitor its delegate investment managers adherence to the requirements in article 3g (1)(a) of the Shareholder Rights Directive II and COBS 2.2B.6R of the FCA Handbook and will oversee the implementation of the SRD rules by its delegate investment managers, which involves the publication of an annual disclosure on how they have implemented and met the objectives of their Engagement Policies.
Smith & Williamson Investment Management LLP
The revised Shareholder Rights Directive (SRD II) takes effect in the UK on 10 June 2019. Firms that provide investment management services to certain types of institutional investors are required to publish a shareholder engagement policy explaining how they engage with the companies in which they invest, and annual information about how the policy has been implemented. The revised Shareholder Rights Directive (SRD II) took effect in the UK on 10 June 2019. Firms that provide investment management services to certain types of institutional investors are required to publish a shareholder engagement policy explaining how they engage with the companies in which they invest, and annual information about how the policy has been implemented. Smith & Williamson Investment Management LLP’s engagement policy can be found here.
If you have any questions, please do not hesitate to contact your relationship manager.
The UK Stewardship Code
A full copy of Smith & Williamson Investment Management LLP’s statement on The UK Stewardship Code is available to view and download here.
Order Execution Policy
Smith & Williamson Investment Management LLP and Smith & Williamson Investment Services Limited maintain order execution policies as required under FCA rules (Order Execution Policy). The main execution venues currently used can be found here.
Top 5 Execution Venues – Annual Report
The Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) requires investment firms who execute client orders to summarise and make public on an annual basis, for each class of financial instruments, the top five execution venues in terms of trading volumes where they executed client orders in the preceding year and information on the quality of execution obtained.
Anti-Bribery and Corruption Policy
You can view the Smith & Williamson Holdings Limited Anti-Bribery and Corruption Policy here.
Legal Entity Identifiers
Smith & Williamson Investment Services Limited
NCL Investments Limited
Smith & Williamson International Limited
Smith & Williamson Investment Management (Europe) Limited
Group tax strategy
The Group tax strategy can be downloaded as a PDF here
Additional FCA governance disclosure
Download as a PDF here
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