Legal and Regulatory Information

Legal notice

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 Fund Administration Limited; Smith & Williamson Financial Services Limited and Smith & Williamson Corporate Finance Limited. Smith & Williamson Investment Services Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. 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

The FCA recently issued its Policy Statement (PS19/13) which sets out its proposed new rules to implement the Shareholder Rights Directive (SRD II) in the UK. SRD II is an EU legislation and is required to be transposed into the national law of all EU members states on the 10th of June 2019. SRD II sets certain requirements on delegated Investment Managers, UCITS Management Companies and AIFM’s (referred to as ‘asset managers’ by SRD II).

In line with SRD II, asset managers must develop and publicly disclose a monitoring and engagement policy on a “comply or explain” basis by the 10th June 2019. As a result, Smith & Williamson Fund Administration Limited (SWFAL) can confirm that it is currently in the process of assessing the application of the SRD II, corresponding FCA rules and the requirement to publish an engagement policy. SWFAL is in the process of reviewing the requirements of SRD II’s engagement policy where SWFAL believes that the engagement policy, or elements of the engagement policy will not be appropriate for the firm in line with its business operations, it will provide an explanation for these decisions.

For your information, SRD II’s requirements for the engagement policy include information on how the firm engages with its shareholders, information on how the firm engages in dialogue with companies it invests in, exercises voting rights and other rights attached to shares, cooperates with other shareholders, communicates with relevant stakeholders of companies it invests in and how it manages actual and potential conflicts of interest from its engagement. It will also explain how it monitors investee companies on relevant matters such as strategy, financial and non-financial performance and risk, capital structure social and environmental impact, and corporate governance. It is intended that the engagement policy will cover SRD II requirements on a ‘comply or explain’ basis.

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. Smith & Williamson Investment Management LLP is currently developing such an engagement policy.

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/PRA governance disclosure

Download as a PDF here

Smith & Williamson may record telephone calls.

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