Legal & regulatory information
Tribe Impact Capital LLP is authorised and regulated by the Financial Conduct Authority (“FCA). Our FCA registration details are set out in the FCA Register under Firm Reference number 756411 (www.fca.org.uk). Tribe Impact Capital LLP is registered in England and Wales (registered number OC411984) and our registered office is 52 Jermyn street, London SW1Y 6LX.
The information contained in this website should not be regarded as advice or an offer, invitation or solicitation to enter into any financial obligation, activity or promotion of any kind as defined by the Financial Services and Markets Act 2000. The provision of any investment services and products, whether or not mentioned in this website, may not always be suitable for an investor, and we recommend that any potential investor consults a financial adviser before entering into any investment contract. Investors should be aware that past performance is not an indication of future performance, the value of investments and the income derived from them may fluctuate and you may not receive back the amount you originally invested.
Our Advisory and Discretionary Portfolio Management services are restricted to providing you with specialist expertise and advice on the management of investment portfolios. As a firm we are able to source our investment solutions from the whole of market, and we are not tied to any products or providers. However, we will not consider your wider financial planning and pension requirements, unless you wish us to do so, when we will refer you to either our Corporate Partner LGT Vestra or an alternative service provider.
You may use information on this website for your own personal reference only. All information and material on this website is copyrighted to Tribe Impact Capital LLP.
You are not permitted to publish, transmit, or otherwise reproduce this information, in whole or in part, in any format to any third party without the express written consent of Tribe. In addition, you are not permitted to alter, obscure, or remove any copyright, trademark or any other notices that are provided to you in connection with the information. The information on this website is provided in good faith and no representation, guarantee or warranty is made by us as to its accuracy. Tribe reserves the right, at any time and from time to time, in the interests of its own editorial discretion and business judgment to add, modify, or remove any of the information.
We shall not be liable for any loss or damage arising out of the use of or reliance on the information contained in our website. This does not affect our duty or liability to you which we have under the Financial Services and Markets Act 2000 or under the regulatory system. Tribe accepts no liability for information contained within websites provided by third parties that may have links to or from our website.
Tribe makes no warranty whatsoever to you, express or implied, regarding the security of the site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through this service.
As a result of high Internet traffic, transmission problems, systems capacity limitations, and other problems, you may, at times, experience difficulty accessing the Web site or communicating with Tribe through the Internet or other electronic and wireless services. Any computer system or other electronic device, whether, it is yours, an Internet service provider’s or Tribe’s can experience unanticipated outages or slowdowns, or have capacity limitations.
We take care to maintain high standards of service. If we are aware of client concerns or unease, we give high priority to resolving the matter as quickly as possible. To assist with this process we have prepared procedures to ensure that complaints are handled fairly and within reasonable timescales. The below is a summary of our complaint handling procedure. A copy of our full procedure is available on request.
How to make a complaint:
If you wish to make a complaint in relation to the services we provide to you, please contact our Managing Partner, James Lawson, at:
Mail: 52 Jermyn Street, London, SW1Y 6LX
Phone: 0203 745 5573
You can complain in writing, by telephone, or via email.
What happens after I have complained?
Upon receipt of a complaint, a senior person who, where possible is independent of the case, will investigate the complaint. You will be given the name and contact details of the person dealing with your complaint. We will aim to resolve the complaint as quickly as possible. The person investigating your complaint will:
- Initiate a record and file of your complaint; and
- Acknowledge your complaint as soon as is reasonably practical after the receipt of your complaint. This will generally be within 3 business days of receipt.
The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary.
Your complaint will be investigated using our files together with reports from other parties if relevant. We may also write to your if further information is required.
We will keep you informed of the progress of the complaint investigation. After 8 weeks, if a final response letter has not already been sent to you, you will receive a final response letter detailing our conclusions and resolution to the complaint. If we are not in a position to make a final response, we will give the reasons for the delay and will indicate when we expect to be able to provide a full response.
What if I am still not satisfied?
Within our final response letter to you, we will include details of the Financial Ombudsman Service (the “FOS”). Provided you are an eligible complainant, you have the right to refer a complaint to the FOS if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. You can contact the FOS at:
Mail: The Financial Ombudsman Service: Exchange Tower, London, E14 9SR
Phone: 0800 023 4567
Further information about the FOS and whether you are an eligible complainant can be found at www.financial-ombudsman.org.uk or by calling 0800 023 4567.
PILLAR 3 DISCLOSURE:
The Capital Requirements Directive (‘the Directive’) of the European Union is the regulatory capital framework used across Europe governing how much capital financial services firms must retain. In the United Kingdom, this is supervised by the Financial Conduct Authority (‘FCA’) using rules and guidance as outlined within the General Prudential Sourcebook (‘GENPRU’) and the Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’) of the FCA’s Handbook. The FCA framework consists of three ‘Pillars’:
Pillar 1 – sets out the minimum capital requirements that firms are required to meet for credit, market and operational risk;
Pillar 2 – requires firms to take a view on whether additional capital should be held against any risks not covered by Pillar 1; and
Pillar 3 – requires firms to publish certain details of its risks, capital and risk management process.
This document contains the Pillar 3 disclosure for Tribe. This Pillar 3 Disclosure has been subject to internal review procedures. The information has not been audited by the Tribe’s external auditors.
The rules in BIPRU 11 provide that Tribe may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where Tribe considers a disclosure to be immaterial, this will be stated in the relevant section.
Tribe is also permitted to omit one or more of the required disclosures where it believes that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine the Tribe’s competitive position. Information is considered to be confidential where there are obligations binding Tribe to confidentiality with its clients, suppliers and counterparties.
Where Tribe has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.
Unless stated as otherwise, all figures contained in this disclosure are based on Tribe’s unaudited annual reports for the year ending 30th April 2021.
These Pillar 3 Disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of the Tribe’s Internal Capital Adequacy Assessment Process (ICAAP) and the publication of its annual reports.
Tribe’s Pillar 3 Disclosure reports are published on the website.
Scope and application of directive requirements
The disclosures in this document are made in respect of Tribe Impact Capital LLP which provides financial advice and discretionary investment management services. Tribe is authorised and regulated by the Financial Conduct Authority and is classified by the FCA as a Limited Licence Firm.
Risk management objectives and policies
Tribe’s risk management framework reflects the FCA requirement that it must manage a number of different categories of risk. Our framework involves an annual programme of risk identification which involves all of the business, as well as monthly board reviews of our risks, their likelihood and impact. These include liquidity risk, operational risk, credit risk, reputational risk, business risk, market risk, investment risk, interest rate risk and concentration risk.
Tribe faces two types of liquidity risk. As a business Tribe generates cash from its operations and holds sufficient cash reserves to meet the continued operating needs of the business. This is supported by a robust budgeting and forecasting process which has the full involvement of the management team. Secondly, where appropriate, our clients’ portfolios may include investments that are less liquid. We manage this risk by careful monitoring of these securities, as well as our clients’ portfolios and broader objectives.
Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems. Whilst Tribe does not handle client money or assets, and we use third party, FCA-regulated custodians, this is still a risk that is closely monitored by our operations team and the management team. The focus is on both the services provided to us by our third-party providers (including trading, custody, and reporting) as well as our own internal operational processes.
Tribe does not undertake any lending activity with clients. The main credit risk for Tribe relates to the deduction of fees due from its clients. However, the investment mandate authorises a deduction of Tribe’s management fees from the client monies held at their custodian and provides for assets to be sold in the event that there is insufficient cash to meet the fees due.
Tribe is potentially exposed to reputational risk in the event that clients’ funds are invested in unsuitable investments. All investments are reviewed by Tribe’s investment and impact teams and any recommendations or securities in our clients’ portfolios must come from the Approved List.
Tribe’s Pillar 2 business risk principally takes the form of a fall in assets under management either due to a market downturn or a loss of clients through reputational risk that leads to a significant reduction in revenue. To mitigate business risk, the Finance team regularly analyses various different economic scenarios to model the impact of economic downturns on our financial position. The exposure to business risk is hedged, to a degree, by clients’ portfolios having significant exposure to both bonds and equities.
Tribe does not have any foreign exchange exposures nor does it have permission to engage in proprietary trading book activities and are therefore not directly exposed to market risk. Clients’ portfolios are linked to the markets and these are addressed within investment risk. Company revenues are linked to market movements and these have been addressed within business risk.
As an investment management firm we recognise that the investment and impact performance of our clients’ portfolios is a risk which must be actively managed and monitored. We have a number of internal processes for this purpose, which involve multiple internal teams.
Interest rate risk
Tribe has no borrowings and no direct exposure to interest rate risk. We have an indirect exposure through our clients’ portfolios, which is covered by our business risk.
Tribe has a wide client base and diverse revenue streams and is not reliant on the income generated by a single client or single revenue stream.
Tribe’s capital requirement under GENPRU has been determined as the Fixed Overhead Requirement (FOR). Our Pillar 1 requirement is based on expenses for the year ended 30th April 2021.
The Pillar 1 requirement was £332,000. This is the FOR which currently exceeds Tribe’s credit risk and operational risk requirements. As at 30th April 2021 Tribe had total Tier 1 regulatory capital after deductions of £1,602,000, representing a surplus of £1,270,000.
The annual Internal Capital Adequacy Assessment Process identifies business risk and operational risk capital requirements and will determine future capital requirements.
REMUNERATION CODE DISCLOSURE:
Tribe is subject to the BIPRU remuneration code. This section provides further information on our remuneration policy.
BIPRU remuneration code staff
We have identified, and maintain a record of, ‘BIPRU Remuneration Code Staff’ – i.e. staff to whom the BIPRU Remuneration Code applies. This includes senior management and members of staff whose actions may have a material impact on a firm’s risk profile. All of our Code Staff fall into the “senior management” category of Code Staff (rather than the “risk taker” category) for the purposes of the BIPRU Remuneration Code. Due to the size and nature of Tribe’s business, Tribe (as allowed by the FCA rules) has chosen to disapply certain rules relating to deferral and allocation of shares.
Decision making/remuneration committee
Tribe is not required to maintain a separate Remuneration Code Committee under CRD III. The Partners in conjunction with the Management Committee are responsible for our remuneration policy.
In determining remuneration arrangements, the Partners will give due regard to best practice and any relevant legal or regulatory requirements including the BIPRU Remuneration Code as well as key risks to Tribe’s business model.
Link between pay & performance
Competitive salaries form the basis of our firm’s remuneration package. In addition there is an element of variable pay for all staff which is based on firm wide and individual performance. Whilst most of the variable reward components are awarded to employees across the firm, the structure, balance and amounts may differ. Variable remuneration is considerably reduced where subdued or negative financial performance of the firm occurs. When assessing individual performance we use a performance review process, with reviews including qualitative criteria and, in the case of wealth and investment managers, long-term investment results are a factor in the assessment process. The Tribe Partners have reviewed and considered the requirements of the FCA Remuneration Code and have determined that the firm’s remuneration policy is compliant with the Remuneration Code. There are various proportionality exemptions within the rules and these have been used where appropriate to do so. Tribe has six Code Staff, all Partners of Tribe. The remuneration of Code Staff is compliant with the Remuneration Code.
TRIBE AND THE UK STEWARDSHIP CODE:
Tribe complies with the UK Stewardship Code (the “Code”) which was issued by the Financial Reporting Council in July 2010 and amended in September 2012 in respect of our activities for professional clients. “Stewardship” means the way in which we look after our clients’ best interests and manage their investments by actively monitoring the companies in which we invest on their behalf.
Although Tribe primarily manages the assets of natural persons who are classified as retail investors, this policy statement focuses instead on our professional clients and summarises how we apply the seven principles of the Code.
- Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
Tribe manages client assets on a bespoke basis, seeking to maximise investment returns for each client. It is central to our investment process to consider each company’s ability to create, sustain and protect value. Therefore, we continually assess the performance of the management of companies in which we have invested on behalf of our clients and whether or not our client’s interests are being best served. Effective monitoring of investee companies is fundamental to fulfilling our responsibility of our clients. An investment is unlikely to be made if we have significant concerns about either management or matters of corporate governance.
From time to time where deemed appropriate, discretionary proxy voting decisions may be taken internally. This is done with our client’s best interests in mind at all times.
- Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.
Tribe maintains a robust policy on managing conflicts of interest which is designed to ensure its decisions are taken wholly in the interest of its clients. Tribe aims to ensure that all potential and actual conflicts are identified, recorded, evaluated, managed and monitored.
A summary of Tribe’s conflicts of interest policy is available to clients upon request.
- Institutional investors should monitor their investee companies.
Comprehensive and continuous research and monitoring of investee companies is fundamental to Tribe’s investment process as our investment strategy typically looks to long term investment rather than continual turnover of clients’ portfolio holdings. Monitoring typically occurs though financial reporting, general meetings, in connection with news and announcements and research Tribe may conduct when looking into investment ideas or reviewing our approved lists of securities.
- Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.
Where we have concerns about the performance or strategy of an investee company or where we have reason to believe that our client’s rights as shareholders are being compromised in any way, we will escalate our engagement with the investee company’s management and take any trading decisions accordingly.
- Institutional investors should be willing to act collectively with other investors where appropriate.
Tribe’s long term investment strategy and research process mean that it will rarely be necessary for such collective action to taken. However, if such collective action is deemed to be in the best interests of our clients, it will be carefully considered and may be taken accordingly.
- Institutional investors should have a clear policy on voting and disclosure of voting activity.
Where we take voting decisions on behalf of our clients, we will always act in a manner consistent with our client’s best interests. Where necessary or appropriate, we endeavour to engage with investee companies. Records of our votes on behalf of particular clients are available to those clients upon request.
We do not let stock or use proxy voting services.
- Institutional investors should report periodically on their stewardship and voting activities.
We regularly report investment activity to our clients, and where it is considered relevant to the client, we will report details of our stewardship and voting activities.