Regulatory Information and Disclaimer

Oakham Wealth Management Ltd is authorised and regulated in the UK by the Financial Conduct Authority (FCA No. 431206).  It is a limited liability company registered in England and Wales with number 05281855.  The firm’s registered offices are at Berkeley Square House, London W1J 6BD, UK.

The value of your investments and the income derived from them may go down as well as up.  You may not receive back your original investment.

Complaints

As a regulated entity, and as part of our commitment to maintain market integrity, we believe in prioritising the interests of our clients.  We endeavour to resolve complaints fairly, courteously, and as quickly as possible.  This is in accordance with our complaints procedures and policies.   Copies of the firm’s complaints procedures are available via the link below.

If you have a Complaint

If you have a complaint regarding the service you have or have not received from us, please contact us.  You should email us at directors@oakhamwealth.com.  Alternatively, please click on the link below for our complaints procedure.  This includes details of how to contact us in writing and who to contact in the event that your complaint is not resolved satisfactorily.

complaints procedure ›

Best Execution Monitoring Report

For the period 01/01/2018 to 31/12/2018, direct client trades were executed via Credo Capital Ltd. Their LEI is 213800NP668Y18LISX10.  Details of their Execution Policy and RTS28 Report can be found by following the link:

http://www.credogroup.com/legal

As part of our ongoing due diligence we regularly monitor the quality of execution provided by Credo Capital.
In selecting Credo Capital as our outsource partner the following factors were considered in relation to best execution:
– Access to multiple venues and markets
– Systems capabilities to facilitate speed of execution
– Expertise in order execution
– Proven track record in provision of best execution

Voting Rights Policy

UK Stewardship Code

June 2019

Policy Statement
This policy statement is designed to ensure that Oakham Wealth Management Ltd (‘Oakham’ and the ‘Investment Manager’) complies with all regulatory requirements relating to the exercise of voting rights and the appropriate recording and communication where these voting rights have been exercised.

Procedures
COLL 6.6A.6R requires any investment manager of a UCITS scheme to have documented procedures for exercising voting rights of the assets held in the scheme.

This includes:
• identifying and responding to corporate events (e.g. rights issues in shares);
• deciding how and when voting rights should be exercised;
• ensuring that it is in accordance with the investment objectives and policy of the fund; and
• preventing or managing any conflicts of interest arising from the exercise of voting rights and acting in the exclusive interest of the fund and its investors.

Voting Strategy

Client trades are executed via Credo Capital, and their Stewardship Code can be found here:

http://www.credogroup.com/legal

Oakham also manages four UCITS compliant fund of fund OEICs as follows:

FP SCDavies Global Equity Fund
FP SCDavies Global Alternatives Fund
FP SCDavies Global Fixed Income Fund (Inc)
FP SCDavies Global Fixed Income Fund (Acc)

Given the nature of a fund of funds, it is rare for Oakham to be invited to vote. The vast majority of the investments are made via managed funds rather than direct into companies. Clearly the only occasions when Oakham are able to vote are when investments are made directly into the shares of a company, and this is rare.

However, on the occasion when Oakham does have the ability to vote, the investment managers may choose not to vote. If the managers did choose to vote, they would do so as they see fit – in line with general corporate governance and voting policy. If a vote is cast, appropriate records will always be retained showing, for each vote, the nature of the vote and how it was exercised with appropriate explanation.

Ownership
Oakham, through its investment managers, owns the exercise of voting rights and it is the responsibility of the CEO to ensure that the Voting Rights Policy is maintained and updated if required.

The Authorised Corporate Director (‘ACD’) will be responsible for any updates that are required with respect to:
• the Prospectus;
• the Investment Management Agreement; and
• the Simplified Investor Document / Key Investor Information Document.

Periodic Review / Governance
Oakham is responsible for ensuring that the Voting Rights Policy and any voting instructions applied are reviewed at least annually and more frequently depending on regulatory changes or changes in business activity.

Management Reporting and Monitoring
Oakham, through its investment managers, is responsible for:
• monitoring relevant corporate events;
• ensuring that the exercise of voting rights is in accordance with the investment objectives and policy of the relevant UCITS; and
• preventing and managing any conflicts of interest arising in the exercise of voting rights (see also the Oakham’s Conflicts of Interest Policy).

Monitoring of these reports and resulting actions will be undertaken periodically during the year by The Authorised Corporate Director (‘ACD’).

The monitoring approach will be to:
• confirm that the Investment Manager do have an appropriate policy and that this is regularly reviewed and updated;
• confirm what internal governance and reviews are done to ensure that the Investment Manager follows the policy; and
• ensure that the Investment Manager maintains retrospective records of the results of the voting policy for review by The Authorised Corporate Director (‘ACD’).

Escalation Route
In the event of any problems arising from the implementation or practice of the Voting Rights Policy, the ACD will be contacted immediately.

Availability
This document will be made available to investors on request. Details of any actions taken as a result of this policy should also be made available, free of charge, to any investor requesting them. It is the responsibility of the Compliance Officer at Oakham to provide such information.

Products Covered by this Policy
The Voting Rights Policy covers all regulated collective investment schemes (UCITS) managed or advised by Oakham.