MIFIDPRU Public Disclosure Document

For the period 1 April 2023 – 31 March 2024

Overview and summary

Broad Reach Investment Management, LLP (“Broad Reach”) is regulated by the Financial Conduct Authority (“FCA”) as a Collective Portfolio Management Investment Firm (“CPMI”) and therefore subject to both the Alternative Investment Fund Managers Directive (“AIFMD”) and the Markets in Financial Instruments Directive (“MiFID”). The Firm is also therefore subject to the rules and requirements of the FCA’s Prudential Sourcebook for MiFID Investments Firms (“MIFIDPRU”) handbook.

For the purposes of MIFIDPRU, the Firm has been classified as a small non-interconnected (“SNI”) firm.

The Firm has produced this Public Disclosure Document in line with the rules and requirements of MIFIDPRU 8, as applicable to SNI firms.

This Public Disclosure Document has been prepared based on the audited financials, covering the financial period 1 April 2023 – 31 March 2024.

The Firm’s main business activity is asset management and the team operates a global macro investment programme focused on the extraordinarily diverse opportunity set in emerging markets. The Fund employs both quantitative and fundamental discretionary investment processes designed to target specific alpha streams within EM. The Firm focuses on securities and related derivatives across the complete universe of FX, rates, credit, and equity as well as commodities.

Remuneration arrangements

The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).

In accordance with MIFIDPRU 8.6.2 the Firm makes the following qualitative remuneration disclosures:

• The Firm’s remuneration policies and practices are reviewed annually to ensure they are appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the firm.
• The Governing Body, as the Remuneration Committee, is directly responsible for the overall remuneration policy.
• The Firm ensures that its remuneration structure promotes effective risk management and balances the fixed and variable remuneration components for all Staff.
• Variable remuneration is adjusted in line with capital and liquidity requirements as well as the firm’s performance.

Broad Reach does not benefit from exceptional government intervention.

Broad Reach’s Remuneration Policy sets out the criteria for setting fixed and variable remuneration. All remuneration paid to staff members is clearly categories as either fixed or variable remuneration.

Fixed remuneration is based upon a staff member’s professional experience and organisational responsibility. It is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.

Variable remuneration is based upon staff members performance or, in exceptional cases, other conditions.

Performance reflects the long-term performance of the staff member as well as performance in relation to the staff member’s job description and terms of employment, and

• includes discretionary pension benefits; and
• includes any carried interest, as referred to in SYSC 19G.1.27R.

Total remuneration is based on balancing both financial and non-financial indicators together with the performance of the Firm and the staff member’s business unit.

The Firm ensures that fixed and variable components of the total remuneration are appropriately balanced; and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.

The Firm monitors fixed to variable compensation to ensure SYSC 19G is adhered to with respect to Total Remuneration.

Quantitative Remuneration

All firms are required to publicly disclose certain quantitative information in relation to the levels of remuneration awarded.

As an SNI firm and in accordance with MIFIDPRU 8.6.8, Broad Reach is required to disclose the total amount of remuneration awarded to all staff, split into fixed and variable remuneration.

For the performance year ending 31 December 2023:
Total fixed remuneration awarded £1,906,810
Total variable remuneration awarded £2,561,844
Total remuneration awarded £4,468,654

Complaints Handling Procedure

Objective And General Policy

We aim to ensure that we treat our customers fairly at all times. Any complaints will be investigated competently, diligently and impartially, assessed fairly and promptly with respect to the subject matter of the complaint, and whether the complaint should be upheld and what remedial action or redress may be appropriate.

The FCA’s Dispute Resolution (“DISP”) handbook sets out the rules relating to the handling of complaints from eligible complainants and MiFID clients.

In the limited circumstances in which the FCA requirements with respect to eligible complainants apply to us, we expect such complaints will only relate to certain investors in our AIF(s) who can be categorised as a ‘consumer’ in relation to our regulated activities as the AIFM. The FCA has defined ‘consumer’ as a natural person acting for purposes outside their trade, business or profession (e.g. a high net worth individual could fall within this definition).

Complaints Handling Procedure

We define complaints as follows with respect to the two categories of complainants:

Eligible complaint – defined by the FCA as meaning ‘any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service which (a) alleges that the complainant has suffered (or may suffer) financial loss, material distress of material inconvenience; and (b) relates to an activity of that respondent, or any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service (“FOS”).

MiFID complaint – defined as ‘any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination which alleges that the complainant has suffered or may suffer financial loss, material distress or material inconvenience’. This does not come under the jurisdiction of FOS.

Upon receipt of a Complaint, as defined above, the Compliance Officer will ensure that complainants are provided a copy of this document, which constitutes our complaints handling policy, when acknowledging a complaint.

We will endeavour to communicate with you clearly and in plain language that is easy to understand and reply to your complaint without undue delay. As soon as we have made the relevant enquiries and reviewed your complaint, we will write to you. If we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in your complaint, we may promptly forward the complaint, or the relevant part of it, in writing to that other respondent. We will inform you promptly in a final response of the reason for forwarding the complaint, including the other respondent’s contact details. Where jointly responsible for the fault alleged in the complaint, we will comply with own obligations under the DISP rules in respect of that part of the complaint we have not forwarded.

We will endeavour to write to you within eight weeks.

All complainants should contact the Compliance Officer

Contact: Stuart McKay

Address: 50 Great Marlborough Street, London W1F 7JS, UK

Telephone: 020 7531 2460

Email: sm@broadreachllp.com

ESG

Broad Reach has adopted a comprehensive ESG policy at the company level, while we are actively engaged in considering how similar principles might best be integrated into current and future products. While this conversation is well advanced for corporate securities, there is so far little consensus on how ESG might or should be applied to macro instruments such as currencies, interest rates, and indices – particularly in emerging markets. We are excited to be involved in this nascent conversation and in the meantime are committed to playing our part in looking after the environment and our communities at the corporate level.

For these reasons, with regard to SFDR, Broad Reach does not currently consider the adverse impacts of investment decisions on sustainability factors; nor does Broad Reach currently include the adverse impacts of investment decisions on sustainability factors in its remuneration policy. Broad Reach intends to review this position annually.

Privacy Policy

Your privacy is very important to us. This notice (“Privacy Notice”) is provided by the Broad Reach Group (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

How we collect information about you

We may collect personal data about you through:

• information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
• information that we obtain in relation to any transactions between you and us;
• recording and monitoring of telephone conversations and electronic communications with you as described below; or
• the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

Why we collect information about you

We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we or a third party determine that is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

What are the consequences of failing to provide your personal information?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

The types of personal data we may collect and use

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, as well as special categories of data, such as biometric or genetic data, information about a person’s ethnic origin, religious beliefs, health, or other sensitive information.

Do we use automated decision-making processes?

No.

Do we share your personal information with third parties?

We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

• our affiliates or other entities that are part of our group or with our clients;
• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
• our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
• service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
• credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
• any person, as directed by you; or
• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

Transfers of personal information to countries outside of the European Economic Area (EEA)

Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation and other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

For how long do we keep your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

What are your rights?

You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

• to request access to your information;
• to request rectification of inaccurate or incomplete information;
• to request erasure of your information (a “right to be forgotten”);
• to restrict the processing of your information in certain circumstances;
• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
• where relevant, to request the portability of your information;
• where you have given consent to the processing of your data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority.

How to contact us

If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact the Chief Operating Officer by email at info@broadreachllp.com or by writing to 8 Hanover Street, London W1S 1YQ, United Kingdom.

Complaining to ICO

You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.

Use of cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

Recording and monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of:

• ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;
• ensuring compliance with our regulatory obligations; or
• detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.

Terms & Conditions

UK Stewardship Code

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Broad Reach Investment Management LLP (the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers.

The Firm provides investment management services to funds that pursue investment strategies that involve discretionary macro investments in most asset classes and instruments across both emerging markets and developed markets. The Firm does not generally trade single equities, meaning the Code is relevant at most to a very limited aspect of the Firm’s activities

While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The approach of the Firm in relation to engagement with issuers and their management is determined globally. The Firm takes a consistent approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

For further information on the Firm’s approach, please contact info@broadreachllp.com.