Regulatory Information

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Terms of Use

It is important that you read this information before proceeding.

This website has been issued by Kennox Asset Management Limited (“Kennox”), which is authorised and regulated by the Financial Conduct Authority (FRN: 475658). This is a financial promotion for Professional Clients and/or distributors only. It is being furnished for general informational and/or marketing purposes.

The law may restrict distribution of this material in certain jurisdictions, therefore, persons into whose possession this material comes should inform themselves about and observe any such restrictions.

In particular, this website is not intended for residents of the United States as we are not authorised to sell our products and services in the United States.

The material contained in this website is being furnished for general informational and/or marketing purposes only. The material does not constitute or undertake to give advice of any nature, including fiduciary investment advice, nor is it intended to serve as the primary basis for an investment decision. Prospective investors are recommended to seek independent legal, financial and tax advice before making any investment decision. The material does not constitute, or form part of, any offer to sell or issue, or any offer to purchase or subscribe for shares, nor any part of it or the fact of its distribution form the basis of or be relied on in connection with any contract. Interests in the S&W Kennox Strategic Value Fund (the “Fund”) will be offered and sold only pursuant to the prospectus relating to the Fund.

Whether an investment in the Fund is appropriate for you will depend on your own requirements and attitude to risk. The Fund is designed for investors of any category, including retail investors. Kennox has not taken any steps to ensure that the securities referred to are suitable for any particular investor and no assurance can be given that the stated investment objectives will be achieved.

The value of your investment, including the initial capital contributed, and any income anticipated therefrom, may fall as well as rise and you therefore may not get back the amount you invest. Transactions in securities of foreign currencies may be subject to fluctuations of exchange rates which may affect the value of an investment. The Kennox value approach carries the risk that the market will not recognise a security’s true worth for a long time, or that a security judged to be undervalued may actually be appropriately priced. There is no guarantee that any forecasts made will come to pass. Past performance is not a guide to the future.

The information contained in this website has been taken from sources considered by Kennox to be reliable but no representation, warranty or undertaking is given as to its accuracy or completeness. The views contained herein are as of the date noted and are subject to change without notice. Kennox may, to the extent permitted by law, act upon or use the information or opinions presented herein, or the research or analysis on which it is based before the material is published. Kennox and its personnel may have, or have had, investments in these securities.

Under no circumstances should this material, in whole or in part, be copied or redistributed without consent from Kennox.

Kennox will not be liable for any loss or damage arising out of or in connection with the use of this site.

Kennox Asset Management, 23 Melville Street, Edinburgh, EH3 7PE , Scotland, UK. Registered Number: SC302037

Privacy Notice & Cookies

Privacy Notice
The privacy of your data is important to us. Our Privacy Notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the data protection legislation (including but not limited to the General Data Protection Regulation (GDPR (Regulation (EEA) 2016/679) (the “GDPR”)). It applies to all clients, candidates, employees, workers, contractors, suppliers, referees and individuals utilising the services of Kennox Asset Management, including website users. We may update this policy from time to time and will make this available through our website. It is recommended that you regularly review our website so that you are aware of any updates made. To ensure we comply with our legal obligations we have detailed the following:

Information Collected and Processed Sharing Data Data outside of EU Data Retention Data Security Your Rights Making a Complaint and Contacting Us

Information Collected and Processed

Kennox Asset Management Ltd is a “Data Controller” and “Data Processor”. This means that we are accountable for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. We will comply with the data protection law.

As such, the personal information we hold about you must be:

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and kept up to date
  • Kept only as long as necessary for the purposes we have told you about
  • Kept securely

We collect the following data:

personal data for employees of Kennox Asset Management; for recipients of our regular Fund emails: name, email addresses, job title, profession and (where applicable) business addresses/contact details (incl. telephone numbers); technical data for visitors to our website (IP address, browser type, time and location, operating system, usage data including information about duration, referring host and number of pages visited) including that captured by cookies (further information on cookies can be found on our website); individuals submitting unsolicited CVs for employment/trainee/internships availability; personal data for job applicants.

We will only use your personal information in compliance with GDPR. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to perform the contract that we have entered with you
  • Where we need to comply with a legal obligation
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

We do not collect any sensitive personal data or special categories of personal data about any individual.

Sharing Data

We do not share your personal information with third parties. The only time when we would share your data would be in circumstances where we are lawfully required to do so (including for regulatory purposes) or where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so and where your rights are not affected.

Transferring Data Outside of the EEA

In order to perform our services to you, it may be required (although unlikely) to transfer your data outside of the EEA. Any data that is transferred out with the EEA we will take steps to ensure that the country is compliant with data protection legislation and there are appropriate means in place to safeguard your data.

Retention of Data

We keep data according to our retention procedures. Retention periods are determined by the nature of the information and are in line with good practice recommendations.

Data Security

At Kennox we have taken appropriate steps to secure the personal data it collects and stores. We will use reasonable endeavours to protect the data from unauthorised access (and/or disclosure). Kennox cannot guarantee the security of any data it collects and stores. Any personal data breaches will be handled according to our data protection and cyber security policies. If legally required, Kennox will notify you and any applicable regulator of a data breach.

Your Rights

Changes in Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a ” subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Please contact Data Protection Manager at compliance@kennox.co.uk

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Opting out of electronic communications. We may use the information we’ve collected about you to send you news and monthly updates about our Fund via email channels. We won’t sell or otherwise provide your personal information to other organisations for marketing purposes. If you prefer not to receive any future marketing communications, you can remove your consent at any time by selecting unsubscribe from the marketing emails issued frequently by Peter Boyle or sending an email to operations@kennox.co.uk

Withdrawing consent. In the limited and unlikely circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact operations@kennox.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so by law.

Contact us to exercise your rights. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, please contact:

Data Protection Manager
compliance@kennox.co.uk
23 Melville Street, Edinburgh, EH3 7PE

Making A Complaint

You have the right to make a complaint about anything regarding the processing, storage, retention of your data. We would hope to resolve any complaint internally and if you would like to lodge a complaint with us in the first instance please contact our Data Protection Manager at compliance@kennox.co.uk

However, you also have the right to lodge a complaint at any time to the Information Commissioner (ICO) in respect of our processing of your personal data. Information can be found at www.ico.org.uk. If you have any queries regarding this policy please email our Data Protection Manager at compliance@kennox.co.uk or write to: Data Protection Manager Kennox Asset Management 23 Melville Street, Edinburgh, EH3 7PE

Kennox Asset Management is authorised and regulated by the Financial Conduct Authority (FRN: 475658).

Company Number: SC302037.

Use of Cookies

When someone visits this site we collect standard internet log information and details of visitor behaviour patterns. For statistical purposes we collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site) through the use of ‘cookies’. This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. A ‘cookie’ is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer. When you use our website, we send your computer a cookie that gives you a unique identification number. A different identification number is sent each time you use our website. The cookie does not identify individual users, although it does identify a user’s browser type and your Internet Service Provider (ISP). Cookies assigned by this site expire 31 days after use. This means it no longer exists on your computer and therefore it cannot be used for further identification or access to your computer. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the “Help” menu of your browser to learn about how to change your cookie preferences.

Remuneration Policy Statement

Kennox has adopted policies in relation to the Firm’s remuneration arrangements which address potential conflicts of interest and preclude reward for taking excessive levels of risk.

Kennox pays all staff base salaries and a discretionary bonus that depends on individual performance and the profitability of the business. The overall scale of bonus awards will consider Kennox’s capital requirements to ensure that variable pay will never impact the viability of the business.

Kennox is satisfied that the policies in place are appropriate to its size, internal organization and the nature, scope and complexity of its activities.

For the year ended 31 June 2021, remuneration for Code Staff stood at £0.8m.

Our ICARA document and Remuneration Policy Statement are updated on an annual basis.

Legal Entity Identifier

Kennox Asset Management Legal Entity Identifier (LEI): 213800DV6P431UKN8P51

Treating Customers Fairly & Complaints

We are committed to delivering the highest level of client service and, as a core part of this commitment, Kennox fully embraces the Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) guidelines. In all our dealings, we strive to ensure that:

  • Clients receive a prompt and courteous service, provided by fully competent and professional staff members
  • Clients receive a clear description of our investment approach, our sole product (the Kennox Strategic Value Fund) and our performance objectives
  • Our fees and charges are transparent and fairly described and disclosed in Fund sales and marketing literature
  • All client questions are dealt with fairly and honestly

Fundamental to this commitment are our robust compliance and risk monitoring procedures carried out by our well qualified operation team who work closely with the industry specialists we have appointed. For information on how to make a complaint, please refer to our Complaints policy which includes information on how to contact the Financial Ombudsman

Best Execution - Broker Review & RTS 28 C

Kennox Asset Management Limited “Kennox”

Kennox executes orders only for publically traded equities on regulated markets.

In accordance with our obligations to our clients, Kennox seeks to ensure that the best possible result is achieved when executing orders for its clients. Kennox will take all necessary steps to achieve the best possible result.

Broker selection

Kennox will use a number of brokers to access markets, seeking to use their specific expertise in so far as they may improve the terms on which we can trade in each market.

New broker relationships are only entered following a full broker review process. The number of brokers on our list is limited, to ensure that we can appropriately manage the relationships and the service they provide to us.

At the present time we use the following brokers:

  • Credit-Suisse
  • CLSA
  • Merrill Lynch

Broker Commission

All brokers provide execution only services. Kennox does not access research or other services through broker relations. Commissions charged are solely for execution.

Execution factors

In order to achieve best execution, we take into account the following factors:

  • price
  • liquidity of the market
  • size of transaction
  • overall cost of transaction
  • speed of execution
  • counterparty risk
  • nature of transaction
  • relationship retention

To determine the relative importance, we will place on these execution factors we will taking into account:

  • our experience and understanding of the market in question
  • the characteristics of the execution venues to which the order is to be directed

 

Relevance of execution factors

Relevant Factors Ratings/Notes (Ratings between 1 (good) and 5 (poor))
Idea Generation
Idea Generation n/a (execution service only)
Sales Service n/a (execution service only)
Market knowledge 1 (for trading)
Trade Implementation
Price 1-2
Cost 1-2
Speed 1
Likelihood of Execution & Settlement 1-2
Size of Order 1
Nature of Order 1

 

Dealing process

At Kennox, investment decisions are controlled by the investment team, and ultimately the Investment Directors. When selecting which of the approved brokers to use, Kennox considers the factors referred to above.

Once the appropriate broker has been determined, the order is recorded in an order management system, and then placed. Once the order has been filled, details of the trade are matched with broker confirmations and then sent on to all parties that need to be informed for accounting and settlement purposes. Dealing records are held for a minimum period of 5 years from the transaction date.

Allocation and aggregation policy

Kennox will in all cases aggregate client orders when concurrent in the market to avoid competing trades causing a pricing disadvantage.

Kennox will “block trade” for the portfolios, whereby we will place one large order with a broker which is then allocated across multiple portfolios. This block trading approach avoids having competing trades in the market at any one time. The final quantity executed is then appropriately allocated across the portfolios.

Whole lots are allocated across the portfolios in proportion to order size, with any odd lots allocated in order of portfolio size (to the largest first). If, for any reason, there is a deviation from this allocation policy (for example to fill a very small order and to avoid unnecessary transaction costs), it will be recorded.

The aggregation and allocation policy regarding trades should allow for prompt, fair and expeditious execution of orders.

We will do our best to avoid aggregating orders on behalf of clients if it is likely to be significantly disadvantageous to a client. Clients should be aware that it is possible that aggregating orders could be possibly disadvantageous to their interests despite our efforts.

Review procedure and reporting

We will review the execution policy and the quality of the brokers identified within it on an annual basis and whenever a material change occurs that affects our ability to continue to obtain the best possible result for our clients. The compliance officer will carry out the following:

  1. Circulate findings, along with remedies required
  2. Circulate abbreviated policy annually with findings to ensure accountability
  3. Twice annually (normally Q2 & Q4) conduct a best execution review meeting with investment team and operations

Broker Review - Overview

Credit Suisse

Relevant Factors Ratings/Notes (Ratings between 1 (good) and 5 (poor))
Idea Generation
Idea Generation n/a (execution service only)
Sales Service n/a (execution service only)
Market knowledge 1 (for trading)
Trade Implementation
Price 1-2
Cost 1-2
Speed 1
Likelihood of Execution & Settlement 1-2
Size of Order 1
Nature of Order 1

 

CLSA

Relevant Factors Ratings/Notes (Ratings between 1 (good) and 5 (poor))
Idea Generation
Idea Generation n/a (execution service only)
Sales Service n/a (execution service only)
Market knowledge 1 (for trading)
Trade Implementation
Price 1-2
Cost 1
Speed 1
Likelihood of Execution & Settlement 1-2
Size of Order 1
Nature of Order 1

 

Merrill Lynch

Relevant Factors Ratings/Notes (Ratings between 1 (good) and 5 (poor))
Idea Generation
Idea Generation n/a (execution service only)
Sales Service n/a (execution service only)
Market knowledge 1 (for trading)
Trade Implementation
Price 1
Cost 3 for high touch / 1 for algo
Speed 1
Likelihood of Execution & Settlement 1-2
Size of Order 1
Nature of Order 1

RTS 28 C*

 

Period Covered 01 January 2021  31 December 2021
Class of Instrument Equities  
Notification if <1 average trade per business day in the previous year Y  
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as percentage of total in that class
Credit Suisse LEI: DL6FFRRLF74S01HE2M14 68% 73%
CLSA LEI: 213800VZMAGVIU2IJA72 32% 27%
Merrill Lynch LEI: GGDZP1UYGU9STUHRDP48 0% 0%

RTS 28 C Table available to download here *An investment firm receiving and transmitting orders or passing orders onto others for execution as part of discretionary investment management services is required to provide information that is “consistent” with RTS 28. Therefore, whilst RTS 28 doesn’t directly apply to these firms Article 65(6) of the Delegated Regulation creates a link by stating “The information shall be consistent with the information published in accordance with the technical standards developed under Article 27(10)(b) of Directive 2014/65/EU”.

Authorised and regulated by the Financial Conduct Authority (FRN: 475658)
© Copyright 2022 Kennox Asset Management
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