Retirement and Death Benefits Plan
Statement of Investment Principles
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.
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 and the Alternative Investment Fund Managers 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:
|Martin Currie Investment Management Limited||549300BZQ6CXNOPQ8E95|
|Martin Currie Fund Management Limited||549300SI0IEHLID7XT09|
|Martin Currie Inc||549300ZAKP3NG77F3O35|
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.
Top 5 execution venues
We are also required to summarise and make public, on an annual basis, for each class of financial instruments, the top five brokers we have used (in terms of trading volumes) for the transmission or placement of client orders in the preceding year. We are also required to publish information on the quality of execution we have obtained. These reports can be found here.
|Martin Currie RTS 28 Best Execution Report||2019||2020|
|Martin Currie Article 65 Best Execution Report||2019||2020|
Conflicts of interest
Martin Currie is committed to acting in our clients’ best interests and to treating our clients fairly. The following disclosure statement 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.
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:
Capital requirements directive
The Capital Requirements Directive (country-by-country) Reporting Regulations 2013 requires Martin Currie Investment Management Limited to disclose annually, specifying, by each country in which it has an establishment, certain information on a consolidated basis for the financial year. This information is set out in the following document:
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:
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.
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.