Terms & Conditions

Important legal and regulatory information

Terms of use:

Before using this website, you should read the following important information carefully. This information governs your use of this website and, by using this website, you indicate that you accept these terms of use and that you agree to be bound by them. If you do not agree, please do not use our website. The content of this website, including these terms, may be changed by us without notice, and you should check this page from time to time.

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 14 Cornhill, London EC3V 3NR.

Suitability:

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.

Services:

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.

Privacy Policy:

Your use of this website may be monitored by Tribe, and the resultant information may be used by Tribe for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organisation.

We are committed to protecting your privacy. Information we collect about you will be used to send you details of our products or services that you have requested. By using this website you agree to the use of your information as set out in this statement. We are registered, and process your data, in accordance with the Data Protection Act 1998 (“DPA”). You have certain rights under the DPA in respect of the information we hold about you. You are entitled to a copy of the information held about you. Your right of access can be exercised in accordance with the DPA and any access request may be subject to a fee.

Jurisdiction:

Tribes website is intended for persons in the United Kingdom only, and its content should not be regarded as an invitation or inducement to engage in investment activity, as defined by the Financial Services and Markets Act 2000 to persons in any other jurisdiction. These terms of use shall be governed by and construed in accordance with English law.

Copyright:

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.

Security:

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.

Systems:

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.

Complaint Procedure:

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 have a complaint about us and/or our services, you should direct this in the first instance to your investment manager. If you are uncomfortable doing so, your complaint can be directed to the Compliance Officer or the Chief Executive Officer. You can complain in writing, by telephone, or via e-mail. Our contact details can be found on the website www.tribeimpactcapital.com.

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 5 working 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 eight 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”) whom, provided you are an eligible complainant, you have the right to right to refer a complaint if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. Further information about the FOS and whether you are an eligible complainant can be found at http://www.financial-ombudsman.org.uk or by calling 0800 023 4567.

Pillar III Disclosures:

Given the industry that the LLP operates in it is subject to a number of risks including but not exclusively credit risk, market risk, operational risk, liquidity risk, interest rate risk and securitisation risk. Each risk category has a greater or lesser impact on the LLP but risk management in its entirety is considered a key component to the functioning of the LLP and will continue to be a focus of management. Each risk category has been identified and analysed to understand the impact it has on the LLP and then steps have been put in place to make sure all risks are mitigated as far as is reasonably possible.
Given the industry that the LLP operates in it is subject to a number of risks including but not exclusively credit risk, market risk, operational risk, liquidity risk, interest rate risk and securitisation risk. Each risk category has a greater or lesser impact on the LLP but risk management in its entirety is considered a key component to the functioning of the LLP and will continue to be a focus of management. Each risk category has been identified and analysed to understand the impact it has on the LLP and then steps have been put in place to make sure all risks are mitigated as far as is reasonably possible.

Credit Risk:

This is divided into counterparty risk and concentration risk but it is essentially the risk that losses will arise from counterparties and clients failing to make good their obligations. The main material risks result from amounts due from market and client counterparties however to mitigate these risks the LLP does the vast majority of trades on delivery versus payments i.e. free deliveries are not made. Also, the LLP will only use recognised stock exchanges or retail service providers (RSP). The vast majority of transactions are executed by the LLP as Agent but the LLP does have permission to act as Principal but this is limited to being a matched principal broker only. The concentration risk is mitigated by only using highly credit rated banks and institutions, and also exposure is spread over a number of counterparties.

Market Risk:

Market Risk is the risk that a firm may incur losses under normal market conditions on a trading book position or portfolio. The firm’s activities in relation to MiFID financial instruments are limited to fulfilling or executing a client order and gaining entrance to a clearing and settlement system or recognised exchange. The LLP is exposed to a small amount of foreign exchange risk through its foreign currency activity. Foreign exchange positions are monitored daily and are held for operational reasons.

Operational Risk:

This is the risk facing the LLP from a failure of or inappropriate internal processes, people and/or systems. The LLP does not consider it possible to eliminate operational risk in its entirety but it aims to reduce the risk with due regard to the cost of achieving this relative to the potential impact. The LLP’s approach for monitoring, recording and mitigating operational risk is appropriate to its size and complexities. Exception reports, such as transactional errors, large movements in prices etc, are produced daily for review by the heads of departments and management information is produced monthly. The LLP has ensured that appropriately qualified people are employed to manage operational risk and to ensure that any exposure is kept to a minimum. In addition the LLP has professional indemnity insurance in place.

Liquidity Risk:

This is the risk that the LLP may face when trying to liquidate assets at fair value should unexpected cash flows result in a liquidity problem. The LLP is predominately equity funded. Regulatory capital ratios are monitored and maintained and cash flow analysis is conducted monthly to ensure that the LLP is able to meet future demands. The LLP does not trade on its own account and therefore there is no exposure to illiquid securities. When acting as agent on behalf of a client wishing to deal in illiquid stocks prior approval must be granted and additional internal controls are applied to ensure receipt of funds prior to the passing of stock certificates.

Interest Rate Risk:

This is the risk arising from the effect of interest rate changes. The LLP has no exposure to interest rate risk as the clients are paid a rate that is linked to the Bank of England Base Rate and all interest rate fluctuations are born by the client. The LLP may make a margin on the interest rate however it is minimal compared to other income streams. This policy is set out in the client’s terms and conditions when joining the LLP.

Securitisation Risk:

The firm is not involved in the securitisation of assets. Should this situation change, Tribe will undertake a risk review and implement the appropriate policies and procedures.

Capital Adequacy – an ICAAP:

The LLP calculates its capital resources in accordance with the FCA rules and guidelines. An Internal Capital Adequacy Assessment Process (ICAAP) has been documented and lists all material risks together with the mitigations and controls in place to reduce their impact. The ICAAP document is reviewed once a year.

Capital Resources:

The regulatory capital resources of the LLP, calculated in accordance with the FCA regulation. These figures will be updated at the end of each accounting year. Tribe commenced trading upon receipt of authorisation by the FCA on 11 November 2016 and is in its first year of operating and therefore does not have an audited set of accounts. The Board will continue to review the capital requirements of the firm and add additional capital if so required. The capital of the firm at inception is as follows.

Common Equity Tier 1 Capital: £250,000

Capital Resource Requirement £50,000

Surplus: £200,000

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.

Cookie Policy:

This website uses cookies. Cookies are small amounts of information that are stored on your computer to enable our server to collect certain information from your web browser. Cookies in themselves do not identify the individual, just the computer used. Cookies and other similar technology make it easier for you to log on to and use the website during future visits. Our cookies are used to keep track of your online session, they are maintained throughout multiple sessions on the site.

Our cookies do not collect any personal identifying information or confidential information such as passwords or policy numbers. Most browsers are initially set to accept cookies, but you can alter this if you prefer. However, if you disable session cookies some parts of our website will not function as designed. Please visit http://www.allaboutcookies.org/manage-cookies.

This web site is issued or approved by Tribe Impact Capital LLP which is authorised and regulated by the Financial Conduct Authority and appears in the FCA’s Register (Registration No. 756411). Tribe Impact Capital LLP is subject to the rules and guidance of the FCA, details of which can be found on the FCA website at www.fca.org.uk. The FCA is located at 25 The North Colonnade, Canary Wharf, London E14 5HS.

Tribe Impact Capital LLP is registered in England and Wales: OC411984. Registered office is 14 Cornhill, London, EC3V 3NR.