Order execution policy

Overview

CCLA Investment Management Ltd (“CCLA IM”) and CCLA Fund Managers Limited (“CCLA FM”) are authorised and regulated by the Financial Conduct Authority and registered and incorporated in the United Kingdom. CCLA IM provides MiFID II services and activities for all CCLA clients and is the manager of the CBF Church of England Funds, the Public Sector Deposit Fund and all the Segregated client accounts. CCLA FM acts as the manager of the Alternative Investment Funds comprising of the COIF Charity Funds, the Local Authorities’ Property Fund and the Diversified Income Fund, which all fall within the scope of AIFMD. CCLA FM is a wholly owned subsidiary undertaking of CCLA IM.

CCLA FM, as an AIFM, has delegated the portfolio management function to CCLA IM.

CCLA IM’s permissions enable it to advise on investments, arrange deals in investments, deal in investments as agent and make arrangements with a view to transactions in investments and manage investments. As an investment manager CCLA IM makes the decisions to deal and subsequently either transmits or actually executes these decisions on behalf of clients , and therefore CCLA IM is subject to COBS 11.2 of the FCA Handbook of rules and guidance (the “FCA Handbook”) issued by the United Kingdom Financial Conduct Authority (the “FCA”).  In accordance with COBS 11.2, CCLA IM will, when executing orders (either directly with counterparties or passing orders to third party brokers for execution), take all sufficient steps to obtain the best possible result on behalf of its clients. (“Best Execution”). This Execution Policy sets out how CCLA IM will seek to achieve Best Execution. For the purposes of this policy, CCLA refers to CCLA Investment Management Limited.

This Execution Policy is intended to function as a guideline for ensuring Best Execution by the investment making teams within CCLA. It is not intended to be interpreted or applied in a rigid manner that unnecessarily restricts or limits CCLA’s ability to achieve the best result for clients in any given       situation. Please note that although the procedures set out in this Execution Policy are generally expected to produce the best possible result for clients, there is no guarantee that circumstances will enable this to be achieved in every single transaction.

This Execution Policy is owned by the CCLA Chief Investment Officer (“CIO”), with support from CCLA’s investment and compliance teams and subject to oversight by CCLA Investment Risk Committee.

Scope

This Execution Policy applies only to CCLA in respect of Financial Instruments (as such terms are defined for the purposes of MiFID and the FCA Handbook) where CCLA executes orders directly with counterparties or transmits orders to third party brokers for execution. Therefore, throughout this Execution Policy, references to execution of orders should be interpreted as executing orders directly with counterparties or passing orders to third party brokers for execution. CCLA will be arranging deals for clients whether by way of (i) arranging and executing purchases or sales of listed securities, loans, bonds or other instruments in the secondary market or (ii) arranging and executing participations in primary transactions, including new loan or bond financings. Execution of ancillary transactions such as the execution of foreign exchange or other derivative transactions (“Ancillary Transactions”) shall also be covered by this Execution Policy. Some of these transactions may not be regarded as “financial instruments” (for example loan agreements). However, in line with CCLA’s commitment to high regulatory standards, it will seek to apply equivalent compliance standards to all transactions as part of its best practices.

Client

CCLA’s clients consist of collective investment schemes and segregated mandates (“clients”).

CCLA’s strategies and order types

Execution of orders by CCLA may take place in the context of the following strategies:

•    Liquid investments: orders are executed on a global Recognised Market stock exchange or through the Transfer Agent of a recognised collective investment scheme that is readily realisable on a daily basis.  This includes Money Market funds.

•    Illiquid investments: orders are executed in relation to the primary participation or secondary purchase of loans, bonds, alternative investment funds or other instruments that are generally illiquid and/or not regularly traded in any market.

•    Liquid investments: orders are executed in relation to the secondary purchase of loans, bonds and other liquid instruments. Traders generally will execute transactions in respect of liquid investments in open market transactions with a broad number of regulated broker-dealers.

•    Ancillary Transactions: orders are executed in relation to derivatives, particularly FX derivatives, and generally as part of a hedging policy to manage portfolio risk.

Execution Factors

When executing orders on behalf of CCLA in relation to a financial instrument, CCLA will take sufficient steps to achieve Best Execution to ensure CCLA clients are treated fairly. CCLA will exercise its discretion in assessing the factors that it needs to take into account (and their relative importance) to provide CCLA clients with Best Execution. CCLA may receive minor non-monetary benefits from Brokers such as macro research which is not considered to be “research” for the purposes of the FCA research payments rules. CCLA operates a separate policy of research and operates a fully unbundled approach to execution payments.

The relative importance of the execution factors will be judged on an order by order basis in line with CCLA’s commercial judgement and experience in light of current market information and taking into account:

•    the characteristics of the client;

•    the characteristics of the transaction in question;

•    the characteristics of the financial instrument(s) in question; and

•    the characteristics of the possible Execution Venues to which the order may be directed.

In many circumstances, the Execution Venue will be the counterparty to the trade. For liquid investments, CCLA maintains a list of approved Execution Venues that are included in Appendix A.

CCLA may take into account the following execution factors for market traded or OTC securities:

•    price (relative importance – generally high);

•    location of assets which are the subject of the deal (relative importance – generally medium);

•    location of professional support (relative importance – generally medium);

•    market impact (relative importance – generally high);

•    costs and tax issues (relative importance – generally high);

•    order size (relative importance – generally high);

•    certainty of execution (relative importance – generally high);

•    speed of execution (relative importance – generally high);

•    settlement (relative importance – generally high); and

•    any other criteria relevant to the execution of the order.

CCLA may prioritise other factors at its discretion. Due to the differences between CCLA’s strategies and the types of instruments in which CCLA transacts, different execution factors may apply to each strategy and/or instrument.

In addition, the nature of CCLA’s business means that Best Execution will not necessarily be entirely dependent upon any one of the traditional execution factors (price, cost, speed, settlement, likelihood of execution, liquidity) nor upon execution venue.

 

CCLA, therefore, applies its Best Execution obligations in a manner which takes into account the circumstances associated with the execution of orders in relation to the strategies and particular types of financial instruments in which CCLA deals, including:

•    credit fundamentals, investment thesis, risks and mitigation factors;

•    deal structure;

•    likelihood of deal completion;

•    capital structure;

•    jurisdiction; and

•    financial analysis.

Bonds

Orders for bonds are generally placed on over-the-counter (“OTC”) markets. The OTC markets, which are characterised by proprietary trading transactions, are decentralised, fragmented and may have low transparency, because the counterparties generally do not make the prices quoted available to a broad market. Rather, these prices are negotiated on a bilateral basis with the counterparties. The choice of counterparties for bonds is often limited. In many cases, as the products are only offered by a limited number of counterparties, there is not much transparency in terms of liquidity or price. In volatile non-transparent markets, it may be necessary to accept the first price offered without the opportunity to obtain or request other prices. Moreover, there may be bonds offered exclusively through one counterparty, or for which settlement of an order of a certain size can only be guaranteed by one counterparty, in which cases it is not possible to obtain a comparative offer.

Loans

Primary orders for loans are agreed and made directly with the counterparty (i.e., the borrower). Secondary orders for loans are generally placed with investment banks or other counterparties and are traded by such counterparties making markets for specific issues. If CCLA wishes to purchase a loan in a secondary trade it must contact the counterparty to agree a price. As a general rule, loans are less liquid and are traded less frequently than bonds and the choice of counterparties may be even more limited and the lack of market transparency even more marked. An order can be executed between two participants without others being aware of the price at which the transaction was effected.

Equities

The types of equity instruments in which CCLA invests will generally be traded on recognised markets. In addition, equity instruments may be ancillary to a primary debt investment where a company issues an equity instrument in the same transaction where a debt investment has been made.

Derivatives

Orders for derivatives are generally executed via trading intermediaries (broker-dealers). All derivatives must be traded under industry standard legal documentation. CCLA’s choice of counterparty for trading derivatives is limited to those counterparties where the required documentation is in place.

Given the nature of the particular financial instruments that CCLA deals in, some execution factors may not be applicable to the orders executed by CCLA. When executing orders, in the absence of any specific instructions, CCLA will give precedence to the factors that allow it to deliver Best Execution in terms of total consideration, representing the price and the costs associated with the execution, which includes all expenses incurred by CCLA which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees, and any other fees paid to third parties involved in executing an order. Price will ordinarily merit a high relative importance in obtaining the best possible result. However, in some circumstances, CCLA may appropriately determine that other execution factors are more important than price in obtaining Best Execution. In order to make any such determination, our front office staff will use their commercial judgement and experience in light of available market information to achieve the best balance across a range of sometimes conflicting factors. This does not necessarily mean achieving the best price for every order, but the best possible result that can reasonably be expected given the resources available to our front office staff. In determining the “price” of a financial instrument, we will take into account a number of considerations including market parameters (i.e., the price at which a financial instrument may be trading on a regulated market or Multilateral Trading Facility (“MTF”)), level of market liquidity and volatility, valuation, and the risks incurred by entering into transactions.

 

Examples of specific scenarios where price may not be the most important execution factor are:

•    Certainty of execution: in some circumstances, CCLA’s ability to actually execute the order may be the primary factor to be considered, for example where the instrument is illiquid or rarely traded or the size of the order is very large.

•    Costs and tax issues: where charges, taxes or other settlement costs may make the consideration prohibitive, then this may be the most important factor for CCLA to consider.

•    Order size: The best price in a market is usually represented by the opportunity to trade in a particular size which may not match the size of the CCLA order. Where the order is bigger than the typical quoted size, then the part of the order executed over and above the threshold may only be available at a less favourable price. Similarly large orders may be available at a more favourable price than smaller orders.  

 

Execution Venues

When CCLA transacts directly with a counterparty, the counterparty is the execution venue for that trade. For more liquid investments, broker-dealers and other similar market participants is likely to be the relevant execution venue.

Having assessed the relevant execution factors and relative importance of the execution factors specific to that order to achieve consistently the best overall result as well as any specific instructions, CCLA will select the most appropriate Execution Venue(s) from those available (when there is a choice) and execute the order accordingly.

For purposes of MIFID, a “venue” includes an exchange, a multilateral trading facility, a broker, a market maker, a systematic internaliser or another liquidity provider. CCLA expects to use a selection of Execution Venues. Sometimes there is only one appropriate venue, and, in such cases, CCLA will only use a single venue.

CCLA may execute otherwise than on a Regulated Market or MTF where bringing together the parties of a transaction in relation to a financial instrument which is not traded on a traditional execution venue, for example when arranging or participating in a primary lending transaction.

The factors affecting choice of Execution Venue are price, the need for timely execution, market liquidity, the size and nature of the order and counterparty risk. Our choice of venue may be constrained by the fact that there may be no choice of venue where an order can be executed due to the nature of the order or requirements by CCLA or due to the nature of the particular instrument (e.g. an illiquid loan is likely to have no choice of venue) and the fact of execution may itself constitute Best Execution.

 

Price

In the context of selecting execution venues, price refers to whether an execution venue generally offers prices that are as good as, or better than, its competitors. Price is therefore a relevant factor in selecting execution venues to execute orders.

 

Counterparty risk

While trading of bonds generally settle quickly, primary or secondary settlements in respect of loans may be more extended, particularly if the asset is trading under distressed circumstances. In order to manage counterparty risk in respect of Execution Venue, CCLA monitors and manages extended settlements through its weekly settlement update with a view to minimising, where possible, settlement time, thereby managing counterparty risk.

In addition, CCLA maintains a list of approved brokers or counterparties. CCLA expects to undertake appropriate due diligence of approved brokers to mitigate counterparty risk, with a particular focus on the following criteria: financial soundness; market presence; rating; and no material adverse market information.

The Execution Venues typically used by CCLA will vary depending on the type and geographical location of the transaction. 

 

Private Market transactions

Execution of orders by CCLA on behalf of clients may take place in private market type transactions; including private equity, venture capital, loans and real assets such as property. The execution of such a transaction is generally by way of signing a contract, by CCLA as agent of its client, directly to take ownership of, or a percentage of, an asset. The asset will generally be illiquid and/or not regularly traded in any market. For these particular investments CCLA may take into account the following execution factors:

•    price (relative importance – generally high);

•    location of professional support (relative importance – generally medium);

•    costs and tax issues (relative importance – generally high);

•    yield (relative importance – generally high);

•    certainty of execution (relative importance – generally medium); and

•    any other criteria relevant to the execution of the transaction.

The relative importance of the execution factors will be judged on a transaction by transaction basis in line with CCLA’s commercial judgement and experience in light of relevant information and taking into account the characteristics of:

•    the client;;

•    the transaction in question, including liquidity and yield;

•    the asset type in question; and

•    the execution venue the order may be executed.

In private market transactions CCLA will transact as agent of its client directly with the counterparty and in private market trades the counterparty will be the execution venue.

 

Specific Client Instructions

As an investment manager/adviser of funds and segregated accounts, CCLA’s client is unlikely to provide specific instructions. In the event that a client does provide CCLA with specific instructions to deal on their behalf, it will execute the orders in accordance with those specific instructions and will have complied with its obligation to obtain the best possible result when executing that order by following those instructions. Where the instructions relate to only part of an order, CCLA will continue to apply its Execution Policy to those aspects of the order not covered by such specific instructions. Client’s should be aware that providing specific instructions to CCLA in relation to the execution of a particular order may prevent it from following this Execution Policy which is designed to obtain Best Execution for CCLA’s clients on a consistent basis taking into account the factors outlined above.

 

Subject to any specific instructions that clients may give to CCLA (see the section above, this is unlikely to occur), CCLA may transmit an order to another entity which is affiliated with or related to CCLA or to an external entity for execution.  In doing so, CCLA will act in the best interests of CCLA and consider the provisions of this Execution Policy.

 

 

Monitoring and Review

CCLA regularly monitors the effectiveness of this Execution Policy and its execution arrangements to identify, and where appropriate, correct any deficiencies. On a monthly basis a Best Execution report is provided by LiquidMetrix, an independent report, to the CIO or his designates.  From time to time, CCLA’s Assurance team will also undertake a periodic review of concentration by broker to flag trading levels that appear off market or show high levels of concentration by broker.

For more liquid investments, CCLA also expects portfolio managers to be able to monitor execution quality by comparison to the last Bloomberg price and current observable pricing and quotes at the time of the trade.

The best execution obligation requires CCLA to take all sufficient steps to deliver the best possible result for clients. Although CCLA expects to find instances where it will be apparent that best execution was not provided, there may be legitimate reasons for this, or it may be that CCLA could have improved the service provided to clients.  The relevant teams will work together to learn from these incidents and correct any deficiencies identified as a result of CCLA’s best execution monitoring.

CCLA will review this Execution Policy at least annually or whenever a material change occurs that affects the firm’s ability to continue to obtain the best possible result for CCLA on a consistent basis using the methods described in this Execution Policy. This Execution Policy will be provided to CCLA clients.

Consent

Under MiFID and the FCA Handbook, CCLA requires the prior consent of each client to this Execution Policy and prior express consent to allow it to execute orders outside a Regulated Market or Multilateral Trading Facility. CCLA ordinarily obtains this consent in its management or advisory agreements with clients.

October 2020

 

Approved Execution Venues Appendix A.

The following are approved execution venues i.e. eligible securities markets, for the purposes of this Best Execution Policy:

EEA Member States securities markets regulated in accordance with MiFID

Austria

Belgium

Bulgaria

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Iceland

Ireland

Italy          Latvia

Lithuania

Luxembourg

The Netherlands

Norway

Poland

Portugal

Slovak Republic

Slovenia

Spain

Sweden

United Kingdom

 

Other EEA regulated markets:

Alternative Investment Market (AIM)

International Securities Market Association (ISMA)

The Grey Book Market

 

Non-EEA securities markets:

Australia

ASX Group

Brazil

BM&F BOVESPA

Canada

TMX Group

Channel Islands

Channel Islands and Securities Exchange

Hong Kong

Hong Kong Exchanges & Clearing

Indonesia

Indonesia Stock Exchange

Israel

The Tel-Aviv Stock Exchange

Japan

Japan Exchange Group

The Fukuoka Stock Exchange

The Nagoya Stock Exchange

The Sapporo Securities Exchange

Malaysia

Bursa Malaysia

Mexico

Bolsa Mexicana de Valores

New Zealand

NSX Group

Philippines

The Philippines Stock Exchange

Russia

Moscow Exchange

Singapore

Singapore Exchange

South Africa

Johannesburg Stock Exchange

Switzerland

Swiss Exchange 

Taiwan

Taiwan Stock Exchange

Thailand

The Stock Exchange of Thailand

Turkey

Borsa Istanbul

United States of America

NYSE MKT LLC

BATS Exchange Inc

CME Group

NASDAQ Stock Exchange

National Stock Exchange

New York Stock Exchange (including NYSE

MKT LLC and NYSE Arca)

The Intercontinental Exchange (ICE)

 

The following are approved Equity and Fixed Income Brokers that may be deemed an execution venue:

Barclays Capital Securities Ltd

Sanford C Bernstein Ltd

Bank of America Merrill Lynch International Ltd

BTIG Ltd

Canaccord Genuity Ltd

Cantor Fitzgerald Europe

Carnegie Investment Bank AB

CF Global Trading (UK) Ltd

Cenkos Securities Ltd

Citigroup Global Markets Ltd

CLSA UK Limited

Cowen Execution Services Ltd

Credit Suisse Securities (Europe) Ltd

Deutsche Bank AG

Fidante Partners Europe Ltd

HSBC Bank Plc

Investec Bank Ltd

Investment Technology Group Ltd

J&E Davy

Jefferies International Ltd

Joh. Berenberg, Gossler & Co. KG

JPMorgan Securities Plc

King & Shaxson Limited

Liquidnet

Lloyds Bank Corporate Markets Plc

Morgan Stanley & co Int PLC

Mirabaud Securities Ltd

Mitsubishi UFJ Securities International Plc

Numis Securities Ltd

N+1 Singer Capital Markets Ltd

Panmure Gordon & Co Ltd

Peel Hunt

Stifel Nicolaus Europe Ltd

Redburn Europe

Royal Bank of Canada Europe Ltd

Royal Bank of Scotland Plc

RiA Capital Markets Ltd

Seaport Europe

UBS Limited

Virtu Financial ireland Limited

William Blair International Ltd

Winterflood Securities Ltd

 

 

The following are approved Foreign Exchange Approved Counterparties that may be deemed an execution venue:

HSBC Banks Plc

Commerzbank AG

        Northern Trust 

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 clientservices@ccla.co.uk.

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 www.fscs.org.uk.

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 www.fscs.org.uk.

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 www.allaboutcookies.org.

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.