Trinity Street Funds - Reportable Income for the period ended 31 Dec 2017 Please find below the reportable income amounts relating to the following share classes of the Trinity Street Funds which are classified as "Reporting Funds" for UK tax purposes: - Global Equity A GBP Cap: LU473308400. Please note that there is no reportable income for the period.
List of available share classes and the effective management fee (as referred to in the prospectus, page 57)
The Sub-Fund may issue shares within the following classes:
Class A (USD) Class B (USD) Class D (USD) Class I (USD) Class X (USD)
Class A (EUR) Class B (EUR) Class D (EUR) Class I (EUR) Class X (EUR)
Class A (GBP) Class B (GBP) Class D (GBP) Class I (GBP) Class X (GBP)
Effective management fee:
USD A: 1.09%
USD I: 1.11%
EUR A: 1.12%
GBP A: 1.12%
Please note: The effective management fee details are as provided in the audited accounts of the Fund. Please note that this fee is subject to post balance sheet adjustment to reflect the fee cap arrangements detailed in the Fund Prospectus.
Trinity Street Asset Management LLP (“Trinity Street” or the “Firm”) is a London-based investment manager that is authorised and regulated by the UK Financial Conduct Authority (“FCA”) and a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Trinity Street is an independently-owned investment boutique founded in 2002 and focuses solely on managing Global and International Equity portfolios.
This document describes how Trinity Street has applied the seven principles of the UK Stewardship Code (the “Code”), which is overseen and published by the Financial Reporting Council. Below we disclose the nature of our commitment to the Code and where, if at all, we do not commit to the Code we state clearly our alternative investment strategy – the Code is applied on a “comply or explain” basis.
The Code aims to enhance the quality of engagement between institutional investors and companies with the aim of improving long-term shareholder returns and encouraging enhanced corporate governance at portfolio investment companies.
Code Disclosure 2019
The following sets forth the seven principles of the Code and outlines how Trinity Street believes it fulfils each of those principles:
Principle 1: Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
At the heart of Trinity Street’s investment processes are activities that are at the core of and consistent with stewardship; with our experienced Portfolio Managers engaging with investee companies and potential investee companies on strategy, performance, risk, capital structure and corporate governance.
In particular Trinity Street considers it to be of paramount importance when assessing proxy voting responsibilities on behalf of its funds and segregated accounts to recognise the fiduciary responsibility it assumes in acting as an investment manager. Trinity Street also recognises the need to exercise its proxy voting obligations with a view to enhancing our clients' long-term investment values.
Trinity Street has a documented Proxy Voting Policy in compliance with Rule 206(4)-6 of the Investment Advisers Act of 1940.
Principle 2: Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.
Trinity Street maintains a robust conflicts of interest policy to seek to identify and manage conflicts of interest that ensures our decisions are taken wholly in the interest of our clients. In compliance with both the FCA and SEC rules, Trinity Street takes a risk-based approach to identify areas of potential conflict of interest, to manage and avoid conflicts of interest in an appropriate manner, and to consider all conflicts when designing and implementing policies and procedures. A summary copy of Trinity Street’s Conflict of Interest Policy is available upon request from the Chief Compliance Officer.
Principle 3: Institutional investors should monitor their investee companies.
Comprehensive and continuous proprietary research and monitoring of investee companies is essential to and at the core of Trinity Street’s investment process. Trinity Street utilises various research and support tools to meet this principle.
Trinity Street may from time to time choose to become insiders. In such a case procedures are in place to restrict information and trading.
Principle 4: Institutional investors should establish clear guidelines on when and how they will escalate their stewardship.
Trinity Street takes an active approach to communicating its views to companies where it believes there are issues that will impact shareholder value. Trinity Street prefers to build effective relationships with the management and boards of these companies in private discussions. Should this approach not be successful Trinity Street would consider, in appropriate circumstances, other strategies (for example but not limited to expressing concerns through the company’s advisers, or meeting with the chairman or other board members).
Principle 5: Institutional investors should be willing to act collectively with other investors where appropriate.
Should occasion arise, Trinity Street may find it preferable to work with other shareholders of an investee company to effect change. Before entering into collaborative engagement initiatives, Trinity Street will take into account potential conflicts of interest and the regulatory implications of its actions.
Principle 6: Institutional investors should have a clear policy on voting and disclosure of voting activity.
As a registered investment adviser with the SEC, Trinity Street has a documented Proxy Voting Policy in compliance with Rule 206(4)-6 of the Investment Advisers Act of 1940. Trinity Street’s clients can request a copy of the Firm’s Proxy Voting Policy from the Chief Compliance Officer. Trinity Street does not disclose this information to non-clients.
For a number of accounts managed by Trinity Street, third party vendor electronic voting services are used (such as Broadridge Proxy Edge). Trinity Street does not carry out stock lending on the accounts it manages.
Principle 7: Institutional investors should report periodically on their stewardship and voting activities.
Due to underlying client confidentiality and investment or engagement strategy reasons, it may not always be appropriate to disclose voting actions at a detailed level.
Trinity Street’s clients can request information about proxies voted and issues raised at meetings of investee companies. Trinity Street does not disclose this information to non-clients.
For further information on Trinity Street’s application of the Code please contact our Chief Compliance Officer, Steve Hicks, at firstname.lastname@example.org.
This statement of compliance with the Code was last reviewed in April 2019, and will be reviewed no less frequently than annually.
4 April 2019
Trinity Street Asset Management LLP (the “Firm”) is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is a UK domiciled discretionary investment manager to professional clients and both regulated and unregulated collective investment schemes. The Firm is a full scope BIPRU investment firm, a full scope Alternative Investment Fund Manager ("AIFM") and is categorised as a collective portfolio management investment firm by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s Pillar 3 disclosure fulfils the Firm’s obligation to disclose to market participants’ key pieces of information on a firm’s capital, risk exposures and risk assessment processes.
We are permitted to omit required disclosures if we believe that the information is immaterial such that omission would be likely to change or influence the decision of a reader relying on that information. In addition, we may omit required disclosures where we believe that the information is regarded as proprietary or confidential. In our view, proprietary information is that which, if it were shared, would undermine our competitive position. Information is considered to be confidential where there are obligations binding us to confidentiality with our customers, suppliers and counterparties.
We have made no omissions on the grounds that it is immaterial, proprietary or confidential.
The Firm's Management Board determine its business strategy and the level of risk acceptable to the Firm. In conjunction with the Risk Officer, they have designed and implemented a risk management framework that recognises the risks that the business faces and how those risks may be monitored and mitigated and assess on an ongoing basis. The Firm has in place controls and procedures necessary to manage those risks. The Risk Officer will convey information on risks and risk management to the Compliance Officer.
The Firm considers the following as key risks to its business:
Operational risk – This risk covers a range of exposures including security breaches, risk of clerical errors, a breach of the fund’s investment objectives, and the loss of key personnel. Operational risks and how they can be mitigated are assessed as part of the Internal Capital Adequacy Assessment Process (”ICAAP”).
Business Risk – This risk includes a fall in assets under management due to market movements or internal factors such as poor investment decisions and a loss of reputation, resulting in a reduction in fee income earned by the Firm and hindering its ability to finance its operations and reimburse its expenses. Business risks are assessed and mitigated as part of the ICAAP.
Market risk - The risk is the exposure to foreign exchange fluctuations due to investment management and performance fees being denominated in currencies other than sterling. The Firm operates currency bank accounts permitting it to receive/pay currency directly.
Credit risk – This risk relates to the exposure to the Funds for non-payment of management and performance fees and counterparty exposure relating to the Firm’s bank balances and any other debtors. This is monitored by the Firm’s Chief Financial Officer.
The Firm is a Limited Liability Partnership, and its capital arrangements are established in its Partnership deed. Its capital contains only members’ capital contributions.
The Firm has a simple operational infrastructure. Its market risk is limited to foreign exchange risk on its accounts receivable in foreign currency, and credit risk from management and performance fees receivable from the funds under its management.
Pillar 1 capital is the higher of:
1. the base capital requirement of €125,000;
2. the sum of market and credit risk requirements; and
3. the Fixed Overhead Requirement
In addition, the Firm, on account of its classification as a full-scope AIFM, is subject to a parallel "own funds" requirement as follows:
The higher of:
1. the funds under management requirement, subject to a minimum of €125,000; and
2. the own funds based on fixed overheads requirement;
Plus whichever is applicable of:
a. the professional negligence capital requirement; or
b. the PII capital requirement.
Pillar 2 capital is calculated by the Firm as representing any additional capital to be maintained against any risks not adequately covered under the requirement in Pillar 1 as part of its ICAAP. When making this calculation, the Firm also takes into account the own funds requirement detailed above, in particular where the own funds exceeds Pillar 1 capital (and the extent to which the Firm is able to use capital instruments to fulfil both requirements).
It is the Firm’s experience that its Pillar 1 capital requirement normally consists of the Fixed Overhead Requirement, although market and credit risks are reviewed monthly. The Firm applies a standardised approach to credit risk, applying 8% to the Firm risk-weighted exposure amounts, consisting mainly of investment management and performance fees due but not paid, and bank balances. Having performed the ICAAP, the Firm has concluded that no additional capital is required in excess of its Pillar 1 capital requirement.
As at the 31st March 2019 the Firm’s regulatory capital position was:
Tier 1 capital: £12,358,000
Total capital resources, net of deductions: £10,259,000
The Firm’s ICAAP assesses the adequacy of its internal capital to support current and future activities. This process includes an assessment of the specific risks to the Firm, the internal controls in place to mitigate those risks and an assessment of whether additional capital mitigates those risks. The Firm also considers a wind down scenario to assess the capital required to cease regulated activities.
We have not identified credit risk exposure classes or the minimum capital requirements for market risk as we believe that they are immaterial. Concerning Pillar 1, it is the Firm’s experience that the Fixed Overhead Requirement establishes its capital requirements and hence market and credit risks are considered not to be material. Furthermore, the market and credit risks component excludes such risks related to the management of alternative investment funds.
Our capital requirements are currently £1,057,000 (the higher of the minimum capital calculated in accordance with either ‘Pillar 1’ or ‘own funds’) which is well within the level of regulatory capital held.
We consider this amount to be sufficient regulatory capital to support the business and have not identified any areas that give rise to a requirement to hold additional risk-based capital.
The Firm’s ICAAP is formally reviewed by the Management Committee annually, but will be revised should there be any material changes to the Firm’s business or risk profile.
Given the nature and small number of staff, remuneration is set by the Management Board. There is a formal review process of staff performance and based thereon determines each staff members overall level of remuneration and the split of that between base salary and bonus for employees and profit share for members in compliance with the FCA Rules on remuneration.
Given that the Firm has only one business area, investment management, all remuneration disclosed in our audited financial statements is from this business area.
The firm has defined “Code Staff” to be the Portfolio managers, Risk officer and Compliance officer. The aggregate level of remuneration earned by “code staff” for the financial year ended 31st March 2019 was approximately £21,500,000.
As the firm currently has no Alternative Investment Funds which is either domiciled in the European Economic Area ("EEA") or marketed in the EEA there is no requirement for a remuneration statement to form part of the annual report of any Alternative Investment Fund.
There is also a requirement for a remuneration statement to form part of the annual report of any Alternative Investment Fund ("AIF") to which the Firm acts as AIFM and which is either domiciled in the European Economic Area ("EEA") or marketed in the EEA.
The Firm is subject to the AIFMD Remuneration Code ("the Code"), has applied proportionality and, pursuant to this application and where relevant, has disapplied various provisions of the Code.
RTS 28 supplements MiFID Directive 2014/65/EU with regulatory technical standards for the annual publication by investment firms of information on the identity of execution venues.
RTS 28 - Summary
Summary of the analysis and conclusions Trinity Street Asset Management LLP (“TSAM”) has drawn from the detailed monitoring of the quality of execution obtained on the execution venues where TSAM has executed all client orders in the calendar year 2018 (“the Report Period”).
As part of the MiFID II best execution requirements, investment firms must publish, on an annual basis, reports summarising specific information on the quality of execution obtained for each financial instrument traded during the preceding year. MiFID II provides 22 sub-classes of financial instruments and investment firms are required to disclose their trading volumes with different counterparties expressed as a percentage of the firm’s total execution volume and a percentage of the number of executed orders, in that particular sub-class of financial instrument. In addition, investment firms must also provide a qualitative report summarising the conclusions drawn from its monitoring of the quality of execution.
Explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution.
The relative importance given to the execution factors was in line with TSAM’s best execution policy and consistent with TSAM’s processes in respect of these sub-classes of financial instruments.
Description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.
TSAM has no close links, conflicts of interest or common ownership with respect to the execution venues that it used to execute orders.
Description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.
TSAM has no specific arrangements to report.
Explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurs.
During the Report Period a small number of additional brokers/execution venues were added. These additions were made to enhance liquidity capabilities.
Explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements.
There has been no differentiation across client categories during the Report Period. All of TSAM’s clients are professional clients. TSAM is not authorised to conduct investment business with retail investors.
Explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client.
Not relevant to TSAM’s operations; TSAM does not have retail clients.
Explanation of how the investment firm has used the information acquired under RTS 27.
Execution quality and overall achievement of best execution are monitored through a number of tools and processes. This includes an independent TCA provider.
Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of MiFID II.
TSAM has not used output from consolidated tape providers in respect of the Review Period.
2017 Summary download ¦
RTS 28 - Analysis of Execution 2018
Equities (Shares and Depositary Receipts) 01.01.18-31.12.18
RTS 28 - Analysis of Execution 2017
Data tables in PDF and CSV formats
Equities (Shares and Depositary Receipts) 01.01.17-31.12.17 download ¦
Exchange Traded Products (Exchange Traded Commodities) 01.01.17-31.12.17 download ¦
Warrants and Certificate Derivatives 01.01.17-31.12.17 download ¦
Currency Derivatives (Swaps, Forwards and Other Currency Derivatives) 01.01.17-31.12.17 download ¦
Trinity Street Asset Management LLP ("TSAM"), takes the privacy of customers (“you”) seriously and aims to protect that privacy as far as possible. TSAM is a “data controller” in respect of any personal information we hold about you as our customer.
TSAM will amend this privacy notice from time to time. This privacy notice was last updated in May 2018.
If you have any questions about this privacy notice or our privacy related practices, you can contact us:
How we obtain your information:
In the course of providing services to you, or receiving services from you, we collect information that personally identifies you. The information we collect about you (or your staff) comes from:
The information we collect
If you are our customer, we collect information that helps us to identify you and to manage your accounts. We also collect financial information about you, information about your transactions with us and information required for us to carry out money laundering and other checks and to comply with our legal obligations.
Where you are our customer, information that we collect can include:
In limited cases, we also collect what is known as “special categories” of information. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes result in us obtaining information about actual or alleged criminal convictions and offences.
You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.
Our use of your information
Where you are our customer, we collect, use, share and store information about you to process transactions and to improve the quality of the service that we provide to you.
When processing your information, we do so in our legitimate interests (as set out in the bullet points below), because of legal obligations that we are subject to or because the information is required either in order to provide our products or services to you or to receive products and services from you in accordance with a contract.
Where we process “special categories” of information about you, we do so either because you have given us your explicit consent, we are required by law to do so or the processing is necessary for the establishment, exercise or defence of a legal claim.
We use your information for the purposes of the following legitimate interests:
How we share your information
We share certain information within TSAM with our third party partners, business associates and subcontractors, and with other third parties for the purposes set out in this policy.
We disclose personal information to third parties, subcontractors, agents and any person (“Third Parties”) who provides professional, legal, accounting advice or other services to TSAM or the TSAM sponsored funds, who will use such information in the course of providing advice or other services to you and for the purposes that we specify. Such third parties may, for example, process data:
All such companies are required to maintain the confidentiality of such information to the extent they receive it.
We also disclose your personal information or any portions thereof (a) as required by, or to comply with, applicable law, regulation, court process or other statutory requirement; and (b) at the request of any regulatory, supervisory or governmental authorities.
How we transfer your information
We use cloud-based technologies and do business in a global marketplace. This means that we may share your information outside the European Economic Area (“EEA”). Where we do so, we put in place safeguards to protect it. Some of these countries may have lower standards of data protection than in your home country, and not all countries outside of the EEA have data protection laws that are similar to those in the EEA, so they may not be regarded by the European Commission as providing an adequate level of data protection. Where we transfer your information outside of the EEA, we will seek to ensure that the transfer is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards.
Retention of information
We will hold your personal information on our systems for the longest of the following periods:
Data protection laws may provide you with rights to object to marketing.
They may also provide you with rights including rights to access data, as well as rights for data to be erased, corrected, used for only limited purposes, not used at all, or transferred to you or a third party. You can seek to exercise any of these rights by contacting us at the details set out in the “Contact Us” section above. You may have the following rights under data protection laws:
Right of subject access: The right to make a written request for details of information about you held by TSAM and a copy of that information.
Right to rectification: The right to have inaccurate information about you rectified.
Right to erasure ('right to be forgotten'): The right to have certain information about you erased.
Right to restriction of processing: The right to request that your information is only used for restricted purposes.
Right to object: The right to object to the use of your information, including the right to object to marketing.
Right to data portability: The right, in certain circumstances, to ask for information you have made available to us to be transferred to you or a third party in machine-readable formats.
Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your information. If you withdraw your consent, this will not affect the lawfulness of TSAM’s use of your information prior to the withdrawal of your consent.
Please note that these rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
If you are unhappy with the way we have handled your information you have a right to complain to the data protection regulator in the EU Member State where you live or work, or where you think a breach of your personal information has taken place.
In the UK, your local regulator is the Information Commissioner. The website is available at https://ico.org.uk
TSAM takes the protection of your personal information seriously, and has security measures and policies in place to address this. All TSAM staff are made aware of their information security responsibilities.
Trinity Street Asset Management LLP is currently assessing the impact of new rules driven by SRD II and, in particular, whether it is appropriate to develop, and publish, a shareholder engagement policy for the listed companies covered by SRD II.