Regulatory and Legal
Disclaimer
This website is intended for use by investment professionals only. The contents should not be distributed to, or relied on by, retail clients. This website and its content should not be taken as an offer, solicitation or recommendation to use or invest in the services and products mentioned throughout.
The investments and services mentioned in this website will not be suitable for all investors and TAM Asset Management Ltd does not give any guarantee as to the performance or suitability of an investment for a retail client.
Any opinions, expectations and projections within this website are those of TAM Asset Management Ltd, do not constitute investment advice or guaranteed returns.
Past performance is not a guide to future returns. The value of an investment and the income from it, may go down as well as up and may fall below the amount initially invested.
TAM Asset Management Ltd is authorised and regulated by the Financial Conduct Authority, No. 208243. Registered in England, No. 04077709. Registered Office: 10th Floor, City Tower, 40 Basinghall Street, London, EC2V 5DE. If you would like to access the Financial Conduct Authority's register please click here.
Our Custodian
The security of clients' investments is paramount, which is why TAM do not seek to hold client assets directly and instead investments are typically held on TAM's behalf with our custodian - Pershing Securities Limited. Pershing are part of The Bank of New York Mellon Corporation (BNY Mellon), one of the world’s largest and strongest financial institutions in the world, unparalleled in terms of their size, security and experience in custody and clearing services. Further information regarding Pershing and their services can be found at their website: www.pershing.co.uk.
Financial Services Compensation Scheme
As both TAM and Pershing are authorised and regulated by the FCA, clients' money is protected by the Financial Services Compensation Scheme (FSCS), which means in a worst case scenario, up to £85,000 per eligible person may be claimable. Further information regarding claim amounts and investor eligibility can be obtained from www.fscs.org.uk.
Data Protection, Privacy and Cookies
For further information regarding TAM's Privacy and Cookie Policy and how your data and personal details are protected, please click here. For your security we may record or randomly monitor all telephone calls.
Website Terms of Use
The material on this site is directed only at persons in the UK. It is not an offer or invitation to buy or sell the services to persons in any jurisdiction other than the UK. Any applications or requests for further information received from non-UK persons may be refused at TAM Asset Management's (TAM) discretion. All reasonable precautions have been taken to ensure the accuracy, security and confidentiality of information available through the site. The information may be amended at any time by TAM without notice. As far as it is permitted under the Financial Services and Markets Act (2000) TAM cannot be held liable for any loss or damage whether it is direct or consequential.
Opinions expressed whether in general or both on the performance of individual funds and in a wider economic context represent the views of the contributor at the time of preparation. They are subject to change and should not be interpreted as investment advice. If you are unsure of the suitability of any information contained in this website, please contact us or an Independent Financial Adviser.
Third Party Sites
This site may provide links to third party websites over which TAM has no control. These links are provided for your convenience and TAM accepts no responsibility for the content of such websites.
Social Media
The information contained on TAM Asset Management Ltd’s Twitter and LinkedIn pages that is provided by TAM is for informational purposes only and should not be considered as investment advice or a recommendation to invest in any particular security, strategy or investment product. TAM is not engaged in rendering any tax, legal or accounting advice. Please consult with a qualified professional for this type of advice.
TAM Asset Management Ltd is not affiliated with Twitter and LinkedIn and has no responsibility for its operations and services or for other Twitter and LinkedIn service sites. TAM Asset Management Ltd reserves the right to block any follower who posts content that is deemed inappropriate or offensive or constitutes a testimonial, advice, recommendation or advertisement for securities, products, or services or is promotional in nature. TAM Asset Management also reserve the right to block followers whose Twitter and LinkedIn page contains offensive or inappropriate content or serves as a promotional site.
TAM Asset Management is not responsible for content that third parties post, upload, distribute or otherwise transmit via Twitter and LinkedIn. Any reliance you place on information posted on Twitter and LinkedIn is at your own risk. Please do not include personal or account information in Tweets, Retweets or Direct Messages. TAM Asset Management is not responsible for the terms of use or privacy or security policies at this site. Use of this site is at your own risk.
Conflicts of Interest
A conflict of interest arises in a situation in which someone in a position of trust has a competing professional or personal interest. Where a firm acts for more than one client, there is the possibility of a conflict of interest, either between clients, or between the firm and its clients. Principle 8 of the FCA’s Principles for Business states that, “A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client”. TAM seeks to identify, with reference to our services, the circumstances that may give rise to a conflict of interest resulting in the risk of damage to the interests of one or more clients. This summary explains how we manage those risks.
Our staff are required to act so as to deliver good outcomes for clients, to act in the best interests of each individual client and not to have regard to the interests of one client over the interests of any other. They are required to comply with a policy of independence and disregard any interests other than those of the client when carrying out a transaction on the client’s behalf.
TAM maintains a Conflicts of Interest Policy, and this is summarised below. Full details are available on request.
Staff Personal Account Dealing
TAM has in place a Personal Account Dealing Policy that confirms pre-trade approval is required for any personal or related person’s trades. TAM is a Discretionary Fund Manager (DFM) trading primarily in collectives and, as such, TAM staff are highly unlikely to be made “insiders” with regards to inside information. However, TAM maintains a Market Abuse Policy that outlines the procedures to be followed should this occur.
Gifts and Hospitality
TAM maintains a Gifts and Hospitality Policy which confirms reasonable and proportionate gifts and hospitality are permitted but inducements, given or received, which could conflict with our obligations to our clients are strictly prohibited.
Remuneration
TAM staff are not remunerated on individual business targets.
Research
TAM is a model B category firm which outsources clearing, custody and settlement to Pershing Securities Limited (PSL). It does not itself execute orders and has no direct control over the execution process. As a result, TAM cannot and does not utilise any dealing commission it may generate from clients’ transactions to pay for any goods and services provided by external brokers, either through bundling or soft payments. TAM’s only service offering is discretionary fund management, and we are prohibited from accepting and retaining fees, commissions, or any other monetary or non-monetary benefit paid for or provided by any third party in relation to the portfolio management services we provide to our clients.
Order Execution
TAM’s only offering is its DFM service so there are no orders originating from clients. As noted above, TAM does not execute the orders generated from its DFM business, they are transmitted to PSL for execution. TAM does not have a proprietary trading desk but it is responsible for orderly deal execution and ensuring that order allocation and best execution do not result in the prejudice of one client over another.
TAM is aware of the potential conflict between providing investment management services and offering an in-house Global Fund. The primary mitigating factors for this potential conflict are that there are no incentives for the investment management team or the distribution team if clients invest in TAM’s Global Fund and TAM does not “recommend” clients to buy this fund. As a DFM, the decision as to which of TAM’s products to invest in is made by the adviser and/or client. TAM launched its Global Fund because it can offer clients with smaller portfolios significant cost benefits while providing exposure to a wider range of underlying investments.
External Business Interests
Staff must seek approval from management prior to accepting any employment or business interest outside of TAM. Staff are required to disclose any outside business interests on joining the company and annually, via annual attestations.
Segregation of Duties and Information Flow
TAM has internal arrangements which are designed to prevent or control the exchange of information within the firm. Such an arrangement is known as a Chinese Wall and reduces or helps to eliminate conflicts of interest and enables confidential information to be kept within a defined area to avoid possible breaches of the law, regulations, and market abuse.
Client Categorisation
A potential conflict could exist if TAM were, to its own benefit, to categorise clients as Professional rather than Retail, reducing the level of regulatory protection afforded to them. TAM categorises all clients as Retail, so they are afforded the maximum level of protection.
Disclosure
As a result of our organisational and administrative arrangements, TAM has no general conflicts of interest that are not appropriately prevented or managed. However, it is possible that a situation could arise where a specific conflict in respect of products/services provided to clients cannot be appropriately prevented or managed. Where mitigating efforts are reasonably assessed to present a low or moderate risk of damage to the client’s interests, TAM will disclose the general nature and the sources of conflict, the specific description of the conflict of interest and the risks that arise as a result. This will be provided in a durable medium before any business is undertaken for the client, to enable the client to make an informed decision with respect to the service in the context of which the conflict arises. Where the mitigation is considered to be unsuccessful and a material risk to the client remains, TAM will decline to act for the client.
Pillar 3
For TAM's Pillar 3 Disclosure please click here.
Stewardship Code
The UK Stewardship Code aims to enhance the quality of engagement between investors and companies to help improve long-term risk-adjusted returns to shareholders. TAM accesses asset classes for its clients through collective investments. There is little scope for direct engagement with underlying investee companies held by a collective fund. However, our investment management team seeks evidence of good quality management and their adherence to the Stewardship Code and the Principles for Responsible Investment when they meet with the fund managers. This normally occurs at least twice yearly.
ESG Principles of Investing
TAM Asset Management have offered a portfolio range dedicated to socially responsible investing since 2013. Therefore, we are firmly aware of the opportunities, both financial and sustainable, associated with investing in this way. The investable universe, for those looking to invest through a lens of sustainability, has developed strongly over the last decade as the climate crisis has intensified alongside critical social issues garnering mainstream attention. In TAM’s bid to provide access to positive environmental and social outcomes alongside financial returns, within our sustainable world portfolio range, we have built on the following pillars: Firstly, our ethical investing framework (avoiding companies with undesirable revenue streams above a certain threshold) and ESG integration (assessing environmental, social and governance risks and impacts). Positive sustainable outcomes are hen targeted through revenue alignment to the UN’s sustainable development goals and proprietary impact frameworks, from the chosen fund house.
TAM is therefore cognisant to capture and appreciates the value of long term sustainable oriented global themes. The framework used in sustainable world is not extended into TAM’s core portfolio options explicitly. However, the resultant knowledge is embedded into TAM’s remaining asset base in varying guises. TAM’s investment philosophy and strategic asset allocation, across our whole asset base, is built with acknowledgement of environmental, social and governance risks and impact. These considerations are factored into TAM’s long term strategic asset allocation, due to their pertinence as an investment risk on global economies and markets.
There is an acknowledgement that there are opportunities to deliver growth from these long-term structural themes, and an understanding that ESG & sustainable minded funds in broader portfolios can increase the diversification within TAM’s active and enhanced passive portfolios. Thus, whilst not committing to following a holistic ESG investment mandate, TAM retains the ability to invest into funds with specific sustainable credentials (Funds classified as Article 8 or 9 under European SFDR legislation, or equivalent). However, we are cognisant of the risks involved with shrinking the investable universe beyond our investment mandate requires which could have an effect on short term performance.
Even if not explicitly targeted by TAM, we are seeing a growing focus on environmental, social and governance factors often found embedded into the processes of the funds we invest in all our portfolio ranges. We welcome this movement as it pushes investable companies to increase their environmental and social footprint as well as the governance of the company.
Treating Customers Fairly
The Treating Customers Fairly (TCF) principle, outlined by the FCA and implemented in 2007, aims to raise standards in the way firms carry out their business by introducing changes that will benefit consumers and increase their confidence in the financial services industry.
At TAM, our ethos has always been to put the customer first and we pride ourselves on the service we provide. With the FCA's call for the industry to focus on consumer outcomes and TCF, this has been cemented into our daily operations.
We believe that by making TCF a core element of our business culture, it will add protection to our clients and instil a peace of mind that is vital in sustaining a successful working relationship. We therefore welcome any and all feedback as it allows us to see the business from another perspective and tailor our operations in a manner that will benefit our customers.
If you would like to comment on any aspect of your dealings with TAM, please email us at: compliance@tamassetmanagement.com.