Conflicts of interest policy


CCLA has taken all appropriate steps to identify and to prevent or manage the conflicts (actual and potential) that it faces in its day-to-day business.  Conflicts of interest can take different forms such as:

  • favouring one client over another;
  • CCLA making a financial gain, or avoiding a financial loss, at the expense of the client;
  • a CCLA member of staff being favoured over a client;
  • CCLA providing to (or receiving from) a person other than the client, an inducement in relation to a service provided to the client, in the form of a financial interest; or
  • favouring CCLA shareholders over a client.

Conflict management

Conflicts are unavoidable and CCLA has established processes and procedures to ensure that all conflicts of interest identified are managed in a manner that seeks to ensure that CCLA or its staff members act in the best interests of its funds, its investors and/or potential investors.  Where other potential conflicts are identified, similarly, process and procedures will be established to manage them to ensure that we will be acting in the best interests of our funds, its investors and/or potential investors at all times.

Conflict monitoring

CCLA’s business is monitored through internal audit reviews, risk assessments and compliance monitoring reviews, all of which can identify new conflicts of interest.  Individual staff members are also expected to identify any conflicts of interest that may arise during their day to day business. Under SYSC 10.1.6 and Article 35.1 Level 2 implementation measures, details of conflicts on the Conflicts of Interest Register maintained by Compliance will be reported at the Monthly Executive Committee meeting and the quarterly Assurance Committee meeting.

Education and awareness

All staff members receive a copy of CCLA’s Compliance Manual which outlines their responsibilities with regard to identifying and managing conflicts of interest.  All staff members are required to certify that they have read and understood the compliance manual and associated policies, including personal account dealing and gifts, benefits and inducements.

Charity Donations

CCLA staff may make personal donations to charities who are also CCLA clients.


Conflicts inventory

Trading and Investment Conflicts

The Firm faces a variety of common trading and investment conflicts, which to a large degree are managed by existing regulatory requirements arising in the context of its conduct of business.


Issue Potential Conflict Management Arrangements
Allocation of transactions

Investment opportunities between Clients; or between the Firm, its Personnel and Clients; may Favour the interests of a UCITS, a Client or group of clients or of one AIF over another..

All trades across accounts are pre- allocated. Trades that are partially filled are allocated on a pro-rata basis except in those circumstances where a de-minimis amount would make an allocation uneconomic. Compliance monitoring is conducted to ensure compliance with the appropriate FCA rules.
Conflicting positions or trading strategies Having a conflicting position in securities or adopting conflicting trading strategies for different Clients such that dealing for one Client may potentially be detrimental to the other. The investment processes at CCLA is based on a team approach and effective communication between the relevant teams avoids any potential conflicts.
Management and performance fees

A failure to properly disclose the amount and basis of calculation of, the fees and commission charged on a particular fund, could give rise to a conflict of interest between the interests of the Firm, its Clients and those of Investors.

CCLA funds have the power to invest in other CCLA funds and a rebate of charges is made to ensure no double charging of the management fee.
Benchmarks A failure to ensure segregation of duties between the Investment and Support departments with regard to benchmark data submissions could result in a manipulation of the data. The benchmark providers (IPD for LAPF and COIF Property and ARC for COIF Ethical) have been instructed to only email the Oversight department for requests for data. Two members of Oversight submit the data; the Fund Operations Controller (preparation) and the Reporting Manager (submission). The independent BNP valuations go to Oversight at well as the Property team.

Pricing and Valuation Conflicts

The Firm is remunerated by reference to the total funds under management as well as to the performance of the Fund(s), which in turn is determined by the valuation of the assets in the Fund(s).

Issue Potential Conflict Management Arrangements
Valuation Policy Not implementing a valuation policy or deviating from the policy which may impact on the fair valuation of financial instruments. CCLA has a valuation policy in place.
Proxy Voting Not managing an effective strategy for determining how voting rights held in AIF portfolios are to be exercised, to the exclusive benefit of the AIF concerned and its investors. CCLA's general stewardship responsibilities and voting are undertaken in the best interests of all its clients.

Information Distribution and Disclosure Conflicts

The Firm may disclose different levels of information to Investors in AIFs they manage; or may hold information that is not permitted to be used for other Clients.

Issue Potential Conflict Management Arrangements
Handling sensitive and confidential information Inappropriate handling of sensitive or confidential information (whether inside information or not) or using such information to trade inappropriately to the detriment of other Clients, AIFs or their investors. CCLA has controls in place to help minimise the risk of insider trading occurring. An Investment Director and Compliance are notified when an individual comes into receipt of inside information. Securities on which CCLA is ‘inside’ are added to the Restricted List and cannot be traded until the inside information has been released to the market.

Personnel Conflicts

The Firm aims to employ experienced and professional Personnel. However, the actions of a member of Personnel may be influenced, or create an influence over the activities of the Firm.

Issue Potential Conflict Management Arrangements
Personal transactions Personnel may place personal trades using inside or other confidential information to the detriment of AIFs or their investors. CCLA has controls in place to help minimise the risk of insider trading occurring. An Investment Director and Compliance are notified when an individual comes into receipt of inside information. Securities on which CCLA is ‘inside’ are added to the Restricted List and cannot be traded until the inside information has been released to the market.
Inducements and entertainment Personnel may be influenced in making investment or trading decisions or outsourcing selections when entertainment or other forms of inducement are provided. CCLA’s Gifts & Inducements Policy imposes a limit of £150 for both gifts and hospitality, an amount in excess of this must be signed off by an Executive Director. CCLA staff base the costs of gifts and entertainment on an estimated value.
Influence of outside business interests or activities Personnel who have outside commitments (i.e. directorships, business interests) may be influenced to act in a manner that conflicts with the interests of the Firm or its Clients. These are disclosed as part of vetting process at CCLA, and any potential conflicts of interest would be handled on a case-by- case basis.
Remuneration and other incentive structures

Staff remuneration arrangements, sales targets or otherwise that could provide incentive to staff recommending a particular financial instrument to a retail client when the firm could offer a different financial instrument which would better meet that client’s needs.

Specifically, the Policy provides that:

  • Remuneration and similar incentives must not be solely/predominantly based on quantitative commercial criteria. They must take into account appropriate qualitative criteria reflecting compliance with the applicable regulations, the fair treatment of clients and the quality of services provided to clients.
  • A balance between fixed and variable components of remuneration must be maintained at all times, so that the remuneration structure does not favour the interests of the firm or relevant persons over any client.

Relationship Conflicts

The Firm needs to identify, manage and, where appropriate, separate external relationships.

Issue Potential Conflict Management Arrangements
Investor relationships Where the Firm has large or otherwise influential Investors they may be provided with greater fund transparency or provided with better fund liquidity. CCLA’s Investment Management Procedures reflect that trades must be allocated fairly between clients i.e. on a pro rata basis unless the allocation would be uneconomic.
Local Authorities Market Relations Service CCLA pay Arlingclose for marketing services with regard Local Authorities. Arlingclose has adopted a Code of Conduct and Anti-Bribery and Corruption Policy, which confirm the below points:
  • Advisors will only accept commission from third parties resulting from a client transaction with the client’s permission;
  • Arlingclose receives no financial payments from third parties in relation to the treasury management activities of its Local Authority clients;
  • Advisors must place the interests of their clients first, and must have procedure in place to manage potential conflicts of interest;
  • Arlingclose will inform CCLA immediately should it become aware of any improper payments in connection with the Agreement and will investigate any such allegations and remedy any violations;
  • Arlingclose will keep accurate books and records and that all payments to persons connected with the Agreement shall be supported by written, detailed invoices;
  • Arlingclose will exercise due diligence in selecting employees, agents or subcontractors in connection with the Agreement, will provide appropriate training for them and will monitor their activities;
  • Advisors will make it clear to clients and prospective clients the areas in which they will provide specific advice, general advice and information.

March 2018

Terms and conditions

Website terms of use policy

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for the CCLA Funds; and
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions (Terms of Use or Terms) on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them.  Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these Terms you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time by updating this page.  We therefore recommend that you check this page periodically to ensure that you understand the Terms which will apply from time to time.

1. About us (CCLA)

1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281.

1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707.

1.4 CCLA FM is a wholly owned subsidiary of CCLA IM. The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing

1.5 These Terms apply to the websites for the CCLA Funds. The CCLA Funds are the CBF Funds, the COIF Funds and the Local Authority Funds.

2. The CBF Funds

2.1 The CBF Funds are:

  • CBF Church of England Deposit Fund.

  • CBF Church of England Fixed Interest Securities Fund;

  • CBF Church of England Global Equity Income Fund;

  • CBF Church of England Investment Fund;

  • CBF Church of England Property Fund and;

  • CBF Church of England UK Equity Fund;

2.2 The CBF Funds are established under the Church Funds Investment Measure 1958 and the Trustee Act 2000.The CBF Funds are neither a collective investment scheme (CIS) nor an unregulated CIS for the purposes of FSMA.

2.3 The trustee and operator of the CBF Funds is CBF Funds Trustee Limited (CBFFT), a company limited by guarantee registered in England and Wales with company number 5957490.CBFFT is a charity registered with the Charity Commission of England and Wales under charity number 1116932.

2.4 CBFFT has delegated the investment management, administration, registrar and secretarial functions of the CBF Funds to CCLA IM.

2.5 CBFFT has appointed HSBC Bank plc to oversees its activities in relation to the management and administration of the CBF Funds and to act as custodian in respect of the CBF Funds. HSBC Bank plc is a company incorporated in England and Wales with company number 14259.

The COIF Funds

3.1 The COIF Funds are:

  • COIF Charities Deposit Fund.

  • COIF Charities Ethical Investment Fund;

  • COIF Charities Fixed Interest Fund;

  • COIF Charities Global Equity Income Fund;

  • COIF Charities Investment Fund and;

  • COIF Charities Property Fund;

3.2 The COIF Funds are established under the Charities Act 1993 (now Charities Act 2011).Each COIF Fund is an unregulated CIS for the purposes of FSMA and an alternative investment fund (AIF) for the purposes of the Alternative Investment Fund Managers Directive (Directive 2011/61/EU) (AIFMD).The COIF Funds are also charities registered with the Charity Commission of England and Wales.

3.3 The Manager of the COIF Funds is CCLA FM.CCLA FM has delegated the investment management of the COIF Funds to the Investment Manager, CCLA IM.

3.4 The corporate trustee of the COIF Funds is HSBC Bank plc (company number 14259), which also acts as custodian. HSBC Bank plc is the depositary for the purposes of AIFMD.

4. The Local Authority Funds

4.1 The Local Authority Funds are:

  • The Diversified Income Fund (DIF).

  • The Local Authorities' Property Fund (LAPF and);

  • The Public Sector Deposit Fund (PSDF);

4.2 DIF is a sub-fund of the CCLA Authorised Contractual Scheme, an umbrella non-UCITS retail scheme and authorised contractual scheme (ACS) entered on the Financial Services Register under product reference number 757825. The ACS Manager is CCLA FM which has delegated the investment management function to CCLA IM. The depositary and custodian is HSBC Bank plc (company number 14259).

4.3 LAPF is established under the Trustee Investments Act 1961, and is an unregulated CIS and an AIF for the purposes of AIFMD. The Manager of the LAPF is CCLA FM, which has delegated the investment management function to CCLA IM. The trustee of LAPF is The Local Authorities' Mutual Investment Trust (company number 700132). Investment in the Fund is for Eligible Local Authorities who are Professional Investors only.

4.4 PSDF is a sub-fund of the CCLA Public Sector Investment Fund (PSIF), an umbrella UCITS fund incorporated under the Open-Ended Investment Company Regulations 2001 (SI 2001/1228) in England and Wales and registered with company number IC000839. PSIF is entered on the Financial Services Register under product reference number 527266.PSIF is an umbrella type investment company and a qualifying money market fund (QMMF) (see Term 7.3 below).The authorised corporate director of PSIF is CCLA IM and the depositary is HSBC Bank plc (company number 14259).

5. Who may use this website

5.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors).

  • Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland.

  • Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003.

5.2 Please ensure that you understand whether or not you are an eligible investor in respect of the Funds, investments and investment services referred to on this website.

6. The purpose of this website

6.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice.

6.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

6.3 In using this website you may navigate between different pages which relate to different Funds. Each webpage will clearly identify the Fund to which it relates and bespoke information presented on each webpage will relate to the identified Fund.

7. Risk warning

7.1 The value of the Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

7.2 Please refer to the Funds’ individual scheme particulars or prospectus for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

7.3 In particular, investors and potential investors should be aware that PSDF is a QMMF.PSDF only invests with high quality issuers at a high level of diversification while maintaining a low weight average maturity. These factors mean that PSDF maintains a low level of overall risk. However, a purchase of shares in the PSDF is not the same as making a deposit with a bank or other deposit taking body. The value of the share is not insured or guaranteed and there can be no assurance that a stable net asset value per share is guaranteed. Please refer to the PSIF prospectus for full risk warnings.

7.4 Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision.

8. Complaints and compensation

8.1 We are covered by the Financial Ombudsman Service (FOS) which is an independent service for settling disputes between financial services firms and their clients. The FOS is available to consider complaints from most clients if they cannot be settled through our own complaints procedures. There are certain rules as to eligibility and timing requirements laid down by the FOS which must be complied with.

8.2 PSDF and DIF are authorised funds as set out at Term 4 above. Investments and deposits in PSDF and DIF are therefore covered by the Financial Services Compensation Scheme (FSCS).There are limits on who can claim and the amount of compensation available. Further information about FSCS is available at

8.3 The COIF Funds, the CBF Funds and LAPF are not authorised funds and therefore investments and deposits in these Funds are not covered by FSCS. However, unitholders and/or shareholders may be eligible for compensation under the FSCS if CCLA cannot meet its obligations. There are limits on who can claim and the amount of compensation available. Further information about FSCS is available at

9. CCLA's liability

9.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA.

9.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

9.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access and we will do our best to protect your information (including personal data). However, we accept no liability in the unlikely event of a breach of our secure computer servers.

9.4 We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website. We will not be liable for any viruses, code, files or programs designed to interrupt, restrict, destroy or otherwise compromise the integrity of the website or any hardware on which it is hosted. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

10. Third party websites

10.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. You will be responsible for complying with the terms and conditions of use for any linked website.

11. Copyright and trade marks

11.1 CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

11.2 You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

11.3 No use of CCLA's name, logos and/or other trademarks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

12. Data protection

12.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes.

12.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you (you may inform CCLA at any time if you do not want to receive such communications); and (vii) as otherwise agreed by you. Failure to provide the personal data requested (or to agree to the above or below uses) may mean that CCLA is unable to provide the services requested.

12.3 CCLA may pass your personal data to any other firm within CCLA but will not pass on any personal data to any other third party except: (i) where, in relation to the performance of its services to you, CCLA sub-contracts part of the services or any support services; (ii) as agreed by you; or (iii) where required to do so for regulatory purposes as set out above.

12.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK and EEA in countries that do not provide the same level of data protection as the UK. In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner.

12.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years.

12.6 By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

12.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request.

13. Cookies

13.1 This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

13.2 When you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

13.3 You can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

13.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit

14. General

14.1 Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

14.2 If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

14.3 These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use.

[MAY 2018]


Public sector funds

Public sector funds

I confirm that I have read and accepted the terms of this website and that I am a local authority/public sector client as defined in section 23 of the Local Government Act 2003.