Conflicts of interest policy

Introduction

CCLA has taken all reasonable steps to identify the key 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;

  • Favouring CCLA shareholders over a client

Some of the key conflicts faced by CCLA are summarised in the Conflicts Inventory below. This inventory will be reviewed and approved annually by CCLA’s Executive Committee.

Conflict management

Conflicts are unavoidable and CCLA has established processes and procedures to ensure that all conflicts of interest that have been identified are managed as effectively as possible and 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. This will include, where applicable, disclosure of specific conflicts of interest to any and all relevant investors and/or potential investors. 

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 the course of their day to day business.

All existing key conflicts of interest, as identified in the Conflicts Inventory below, are subject to ongoing monitoring and review by CCLA’s Executive Committee. 

Education and awareness

All staff members receive a copy of CCLA’s Compliance Manual which outlines their responsibilities with regards 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. 

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.

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 £100 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.

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.

July 2014

Terms and conditions

Website terms of use policy

Welcome to CCLA's website for:

  • fund management services for The CBF Church of England Funds and the COIF Charities Funds (together referred to as "the Funds"); and for
  • 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") 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 and conditions you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time and where this is the case we will do so 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. Information about CCLA

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

CCLA Investment Management Limited (a company registered in England and Wales with Company No. 2183088) and CCLA Fund Managers Limited (a company registered in England and Wales with Company No. 8735639) are each authorised and regulated by the Financial Conduct Authority ("FCA") under the Financial Services and Markets Act 2000 ("FSMA"), and are entered in the FCA Register under Registration Numbers 119281 and 611707 respectively. CCLA Fund Managers Limited is a wholly owned subsidiary of CCLA Investment Management Limited.

CCLA Investment Management Limited is the manager of The CBF Church of England Funds and provides discretionary investment management services for individual client portfolios. CCLA Fund Managers Limited is the manager of the COIF Charities Funds. The registered office of CCLA Investment Management Limited and CCLA Fund Managers Limited is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

2. Who may use this website

The information in this website is primarily intended for "charities" in the United Kingdom (and in particular the information in relation to the Funds is intended for UK "charities" only).  "Charities" for these purposes are charities or charitable organisations who are registered with the Charity Commission, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958 or section 24 of the Charities Act 1993, or equivalent organisations in Scotland or Northern Ireland. Certain investments or services to which this material relates may only be available to such persons. This material must not be relied upon or acted upon by any other persons in the United Kingdom.

3. The purpose of this website

This website is for information purposes only and is intended as a general introduction to CCLA and its products. The website content and any products and/or services described within it are subject to change without notice. We do not accept any liability to you, or any third party, for the accuracy, completeness or appropriateness of the information and materials made available on this website and your use of any information or materials is entirely at your own risk provided that nothing contained in this section or elsewhere in these terms shall limit or exclude our liability to you to the extent that such liability is attributable to a breach by us of the FCA's rules, FSMA or any other applicable law.

Any application or investment must only be made on the basis of the relevant investment documents which will be issued to you when you make an enquiry about investing in a CCLA fund, such as, for example, the scheme particulars and terms and conditions. Nothing contained on this website constitutes the provision of investment, tax, legal or other advice.

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. 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.

4. Risk warning

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.

Please refer to the Funds’ scheme particulars 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.

The investments and investment services referred to on this website may not be suitable for all eligible investors.

As the Funds are not authorised unit trusts within the meaning of FSMA, investments or deposits in the Funds are not covered by the Financial Services Compensation Scheme (FSCS).

However, unitholders and/or shareholders may be eligible for compensation under 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 www.fscs.org.uk

5. CCLA's liability for website content

The information on this website does not necessarily reflect our views and opinions. Neither should any suggestions or advice contained on the website be relied upon in place of individual advice. You are responsible for checking the accuracy of relevant facts, instructions, suggestions and/or opinions given on the website before entering into any commitment based upon them. We do not accept any liability arising from any inaccuracy or omission in the information.

CCLA is not responsible for the accuracy of information contained within websites provided by third parties, which may have links to or from our pages.

The information on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Under no circumstances should this information or any part of it be copied, reproduced or redistributed.

Due to the inherent nature of the Internet, errors, interruptions and delays may occur in the service at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. CCLA shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between CCLA and you, regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

CCLA shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this website or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. CCLA makes no warranty whatsoever to you, express or implied, regarding the security of the website.

This service may provide links to certain websites sponsored and maintained by third parties. CCLA 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. Your use of the products and services on this website may be monitored by CCLA.

6. Copyright and trade marks

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.

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.

No use of CCLA's name, logos and/or other trade marks (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.

7. Data protection

We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with the Data Protection Act 1998. CCLA is the data controller of any such information for these purposes. CCLA will use any such information for the administration and servicing of your investments and all other related activities. We may disclose your information to our agents and service providers. Where a financial adviser acts on your behalf, we may disclose such information to that financial adviser.

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 upon payment of a fee and to require us to correct any inaccuracies in your personal data.

If you supply such information to us via this website, CCLA may use your personal data to 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.

Full details of CCLA’s Data Protection Policy, including its Privacy Notice are available on request.

8. Cookies

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.

Please note that 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.

Please note that 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.

For more information about cookies, including how to set your Internet browser to reject cookies, please visit www.allaboutcookies.org.

9. General

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information (including personal data), we cannot guarantee the security of your data transmitted to this website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. However, CCLA accepts no liability in the unlikely event of a breach of our secure computer servers.

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 and regularly check for the presence of viruses and other malicious code. 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.

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.

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.

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 arising under these Terms of Use.

September 2015