Whether you complain during a telephone conversation or meeting, or in a letter, email or other communication, we will record your concerns and pass the details to our Compliance Officer for investigation. You will receive an acknowledgement from the Compliance Officer within five business days, giving you the name of the person who will handle your complaint.
Investigation and Resolution
The Compliance Officer will investigate your complaint and attempt to resolve it as quickly as possible. You may be asked to provide additional information to assist in this process.
Within four weeks of making the complaint you will receive either a final response or a holding response indicating when you may expect a final response from us.
Within eight weeks of making the complaint you will receive either a final response or a letter explaining why we are still not in a position to make a final response and when this can be expected. We only have dealings with Professional Clients and Eligible Market Counterparties so we are exempt from the right to use the Financial Ombudsman Service which applies only to “eligible complainants”. We aim always to resolve complaints within eight weeks; it should only take longer than this if we have to request further information from you or from a third party to establish all the facts.
The final response will set out the facts that have been established during the investigation.
PCA prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement:
to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company
by any individual partner, employee, consultant, agent or other person or body acting on PCA’s behalf
in order to gain any commercial, contractual or regulatory advantage for PCA in a way which is unethical
or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
PCA recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another.
This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with the recipient, and which is intended to influence them to take action which may not be solely in the interests of the Partnership or of the person or body employing or contracting with the recipient or represented by the recipient.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:
normal and appropriate hospitality; and
the giving of a gift for a corporate reason or at another special time, as long as this is reported in the proper manner within the firm on the Gifts Register maintained by the Compliance Officer.
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the Managing Partner of PCA before proceeding. If necessary, guidance should also be sought from the Compliance Officer.
Partners, consultants and principles responsibility within PCA
The prevention, detection and reporting of bribery is the responsibility of all partners, employees and consultants throughout the partnership. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.
Kundeninformationen nach § 12 der Verordnung über die Finanzanlagenvermittlung
1. Name und Anschrift
Pemberton Asset Management GmbH
Geschäftsführer: Jürgen Breuer
60313 Frankfurt am Main
Tel.: 069 9760 998 10
Fax: 069 9760 998 29
Gemeldet bei der IHK Frankfurt am Main als Finanzanlagenvermittler mit einer Erlaubnis nach § 34f Abs. 1 S. 1 Nr. 1, Nr. 2 der Gewerbeordnung (GewO).
3. Gemeinsame Registrierstelle nach § 11a Abs.1 GewO und Eintragung in das Vermittlerregister
Deutscher Industrie- und Handelskammertag (DIHK) e.V.
Breite Straße 29
Telefon: 0180 600 58 50
(Festnetzpreis 0,20 €/Anruf; Mobilfunkpreise maximal 0,60 €/Anruf)
Die Eintragung im Vermittlerregister (www.vermittlerregister.info) kann unter folgenden Registrierungsnummern abgerufen werden:
Under COBS 2.2.3 of the Financial Conduct Authority (FCA) Handbook, Pemberton Capital Advisors LLP (“PCA”) is required to make a public disclosure in relation to the nature of our commitment to the UK Stewardship Code (the “Code”).
The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “comply or explain” basis.
The Financial Reporting Council (“FRC”) recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with UK listed companies, depending on their investment strategy, and in such cases firms are required to explain why it not appropriate to comply with a particular principle.
Whilst PCA supports the objectives of the Code, it does not currently “manage investments” as specified in article 37 of the Regulated Activities Order (Managing investments) and, as such, the provisions of the Code are not relevant to the type of activities currently undertaken by PCA.
Should this position change, PCA will review its commitment to the Code at that time and make the appropriate disclosure.