Legal & Compliance
Conflicts of Interest Policy
DB Investment Partners Limited conducts its business according to the principle that it must manage conflicts of interest fairly, both between itself and its clients and between one client and another.
The Conflicts of Interest Policy, which you can download from this website, explains the fundamentals of how DB Investment Partners Limited identifies and manages conflicts of interest.
Order Execution Policy
This page sets out DB Investment Partners Limited Order Execution Policy, which accounts for the implementation of the second Markets in Financial Instruments Directive (Directive 2014/65/EU ”MiFID II”) and applicable rules of the UK Financial Conduct Authority relating to Best Execution.
Inducements
DB Investment Partners Limited may from time to time receive acceptable minor non-monetary benefits permitted under applicable law and regulation as set out in COBS 2.3A.19 of the FCA Handbook, including;
- information or documentation relating to financial instruments or investment services;
- issuer-commissioned research coverage;
- participation in conferences, seminars or training events on the benefits and features of specific financial instruments or investment services;
- hospitality of a de minimis value during meetings or those events specified;
- connected research on an issuer in the context of an issuer capital raising;
- research provided for a trial period, openly and publicly available, or relating to fixed income, currency or commodity instruments (with the exclusion of macro-economic research); and
- such other services and/or benefits that can be considered minor non-monetary benefits under Applicable Law from time to time.
UK Stewardship Code
The UK Stewardship Code 2020 (the “Code”), consists of, inter alia, 12 stewardship principles for asset managers and asset owners. 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”. The Code is voluntary and applies on an ‘apply or explain’ basis.
DBIP’s Approach
DBIP manages investments globally across a range of asset classes and follows several diversified strategies.
DBIP determines its approach to stewardship on a case-by-case basis, taking into account the actions that will lead to the most favourable outcome for the value of our investments. Having considered the Code and while supporting the general objectives of the Code, DBIP believes that the principles set out therein are not applicable to its investment activities at this time and therefore DBIP has not applied to be a signatory to the Code. Should DBIP’s approach or investment strategy change in the future, DBIP will review its commitment to the Code and update the firm’s website disclosure accordingly.
Notwithstanding DBIP‘s decision with respect to becoming a signatory to the Code, the firm, in principle, supports the Code’s underlying objectives.
SRD II Disclosure
The revised Shareholder Rights Directive (SRD II) aims to strengthen shareholder engagement and increase transparency for asset managers and owners; and also to promote effective stewardship and long-term investment decision making. SRD II sets requirements in several areas, including transparency of engagement policies and investment strategies across the institutional investment community.
Under FCA rules, DBIP is required to develop and publicly disclose a shareholder engagement policy and publicly disclose on an annual basis how that policy has been implemented. Where DBIP does not comply with such requirements, it must disclose why it has chosen not to do so.
While we support the objectives of SRD II, our investment strategies do not significantly involve investing in equity holdings in publicly listed companies, and such equities form only a small component of our overall assets under management. In general, we would expect shares in relevant investee companies only to be held as an investment ancillary to, or as a result of, a credit investment. In cases where we do have exposure to publicly listed equities, and consequently the voting rights associated with them, we will exercise such voting rights as agreed with our clients.
Accordingly, we do not consider it appropriate to adopt a shareholder engagement policy as described by SRD II at this time. If our investment strategies change so that the provisions of SRD II become relevant, we will update this disclosure accordingly.
Complaints
If you have a complaint, please write to:
DB Investment Partners Limited
21 Moorfields
London
EC2Y 9DB
United Kingdom
Or by email to:
dbip-complaints@list.db.com
DB Investment Partners Limited will send a prompt written acknowledgement that the firm has received the complaint and is dealing with it.
This document is issued by DB Investment Partners Limited (FRN: 966618), at 21 Moorfields, London EC2Y 9DB, United Kingdom. Authorised and regulated by the Financial Conduct Authority.
Telephone and communications recording
Provided for the purposes of compliance with rule 10A.1.11 of the Senior Management Arrangements, System and Controls (“SYSC”) Sourcebook of the UK Financial Conduct Authority Handbook.
General
Telephone conversations between DB Investment Partners Limited, a Client and/or third parties may be recorded without the use of a warning tone and used as evidence in the event of a dispute or investigation.
DB Investment Partners Limited may retain records of all communications with a Client for, in principle, a period of five years and, where requested by the competent authority, for a period of up to seven years. A copy of the recording of such records will be available on request from a Client during the applicable period.
Conversation notes
DB Investment Partners Limited is required, in the case of personal conversations with clients relating to investment services, to record in a durable medium notes of the conversation which include at least the following:
- Date and time of the meeting,
- Location of the meeting,
- Identity of the attendees,
- Initiator of the meeting, and
- Relevant information about the order including the price, volume, type of order and when it shall be transmitted or executed.