Retirement and Death Benefits Plan

Statement of Investment Principles

Introduction

This Statement of Investment Principles (“the Statement”) has been prepared by the Trustee of the Martin Currie Retirement and Death Benefits Plan (“the Plan”) in accordance with Section 35 of the Pensions Act 1995, as amended, and its attendant Regulations.

The Statement outlines the principles governing the investment policy of the Plan and the activities undertaken by the Trustee to ensure the effective implementation of these principles.

In preparing the Statement, the Trustee has:

• obtained and considered written advice from a suitably qualified individual, employed by their investment consultants, Mercer Limited, whom it believes to have a degree of knowledge and experience that is appropriate for the management of their investments; and
• consulted with the Sponsoring Employer, although they affirm that no aspect of their strategy is restricted by any requirement to obtain the consent of the Sponsoring Employer.

The advice and the consultation process considered the suitability of the Trustee’s investment policy for the Plan.

The Trustee will review the Statement formally at least every three years to coincide with the triennial Actuarial Valuation or other actuarial advice relating to the statutory funding requirements.  Furthermore, the Trustee will review the Statement without delay after any significant change in investment policy.  Any changes made to the Statement will be based on written advice from a suitably qualified individual and will follow consultation with the Sponsoring Employer.

Download Statement of Investment Principles

Download Martin Currie Retirement and Death Benefits Plan - Investment Accounting Disclosures’

Regulatory Disclosures

Introduction

As a global investment management firm, Martin Currie is subject to a wide range of regulation. We are based in the UK and as such are authorised and regulated by the Financial Conduct Authority. In the EU, we are subject to (amongst other things) the Markets in Financial Instruments Directive, the Capital Requirement Directive. Martin Currie also operates in the United States and, as such, is registered with the US Securities and Exchange Commission. As part of our global compliance obligations, we are required to make certain disclosures to our investors and potential investors, and also to make certain information publicly available.

Legal entity identifiers

All firms that are subject to MiFID II transaction reporting obligations must have a unique legal entity identifier (‘LEI’), enabling that firm to be identified in any financial transaction across the EEA. Our legal entities have been allocated the following LEIs:

Best execution

We are required to achieve best execution for our clients.  This means that, where Martin Currie executes orders on behalf of our clients, we are under a duty to take all sufficient steps to obtain the best possible results for them, taking into account certain execution factors. Our order execution policy sets out how we comply with this obligation.

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Conflicts of interest

Martin Currie is committed to acting in our clients’ best interests and to treating our clients fairly. The following conflicts of interest management policy provides detail on the procedures and controls that we have in place to identify, and prevent or manage, conflicts of interest between Martin Currie and our clients, and between our clients themselves.

Download Conflicts of Interest Policy

Pillar 3

The EU Capital Requirement Directive came into effect in 2014 and established a regulatory capital framework in the EU governing the amount and nature of capital that investment firms must retain within their business. The framework is structured around three pillars, the third of which requires investment firms to make certain disclosures around risk. We have prepared these disclosures in the following document:

Download Pillar 3 Disclosure statement

Tax strategy

Martin Currie is required under the Finance Act 2016, as a large company, to publish our tax strategy on our website. Franklin Resources, Inc. is our ultimate parent company and as such we publish their tax strategy, which is reviewed and updated on an annual basis:

Franklin Templeton UK Tax Strategy

Securities and Exchange Commission

Martin Currie Investment Management Limited and Martin Currie Inc. are both registered with the Securities and Exchange Commission ("SEC") as an investment adviser.

Download Martin Currie Investment Management ADV Part 2A Brochure

Download Martin Currie Inc ADV Part 2A Brochure

Download Martin Currie Inc Customer Relationship Summary (Form CRS)

Complaints

Martin Currie takes all complaints seriously and we are subject to the complaints handling rules set out in the FCA handbook of rules and guidance. Whilst Martin Currie endeavours to resolve any complaints swiftly and in a satisfactory manner, we are required to remind you that, if you are an eligible complainant, you may be entitled to raise a claim with the Financial Ombudsman Service should any complaint not be resolved to your satisfaction.