Background

Kintbury Capital LLP (’Kintbury Capital’ or the ‘Firm’) is authorised and regulated by the Financial Conduct Authority (the ‘FCA’). The Firm is a full scope Alternative Investment Fund Manager (‘AIFM’) and is categorised by the FCA, for capital purposes, as a Collective Portfolio Management Investment (“CPMI”) firm. The Firm is not required to prepare consolidated reporting for prudential purposes.

Materiality & Confidentiality

The Firm regards information as material in disclosures, if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions. The Firm regards information as proprietary/confidential if sharing that information with the public would undermine its competitive position.

Risk Management Objectives and Policies

The Firm’s Executive Committee are ultimately responsible for ensuring compliance with all regulatory requirements and comprehensively reviewing all risk issues at the Firm. The Firm's CEO is responsible for Portfolio Risk Management oversight and for reporting to the Executive Committee.  The Firm’s COO is responsible for systems and controls and for reporting of various operational and business risk management matters. The CEO and COO are functionally separated from the investment management team.

Kintbury Capital has clearly documented policies and procedures (these are contained in the Firm’s Compliance Policies and Procedures Manual), which are designed to minimise risks to the Firm and all staff are required to confirm that they have read and understood them.