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The information set forth in this website does not purport to be complete. While ACM uses reasonable efforts to update the information on this site, ACM makes no representations or warranties as to the accuracy, reliability or completeness of any information at this site. Any contents at this site are subject to change without notice. ACM has not reviewed any of the sites linked to this site, and is not responsible for the content of off-site pages or any other site linked or linking to the site. Your linking to any off-site pages or other sites is at your own risk.
ACM owns and maintains this site. Nothing at this site shall be construed as granting, by implication, estoppel or otherwise, any license or right to use any image, trademark, logo or service mark at the site. No act of downloading or otherwise copying from this site will transfer title to any software or material at this site to you. Anything that you transmit to this site becomes the property of ACM, may be used by ACM for any lawful purpose, and is further subject to disclosure as deemed appropriate by ACM, including to any legal or regulatory authority to which ACM is subject. ACM reserves all rights with respect to copyright and trademark ownership of all material at this site, and will enforce such rights to the full extent of the law. This site is for your personal and non-commercial use. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products, or services obtained from this site.
The information within this site is issued by Advent Capital Management UK Limited which is Authorised and Regulated by the Financial Services Authority.
The Funds are not Authorised or Recognised collective investment schemes for the purposes of the Financial Services and Markets Act (2000) and the promotion of the Funds is accordingly restricted by law. The Fund’s Prospectuses may only be issued to categories of persons permitted under the Financial Services and Markets Act (2000) (Promotion of Collective investment Schemes) (Exemptions) Order 2001. This document is directed at persons who are both (a) professional clients or eligible counterparties for the purposes of the FSA Conduct of Business Sourcebook (“COBS”) and (b) of a kind to whom the Funds may lawfully be promoted by a person authorised under the Act by virtue of Section 238(5) of the Act and COBS 4.12 of the New Conduct of Business Sourcebook. The investments and investment services to which this document relates are only available to the persons referred to above and other persons should not act or rely on it. This document is exempt from the scheme promotion restriction in Section 238 of the Act on the communication of invitations or inducements to participate in unregulated collective investment schemes on the grounds that it is being issued only to the types of person referred to above.
Investors in the Funds will not benefit from the rules and regulations made under the Act for the protections of investors, nor from the UK Financial Services Compensation Scheme.
ADVENT CAPITAL MANAGEMENT UK LKIMITED
RENUMERATION CODE DISCLOSURE – 31 DECEMBER 2010
Scope and application of the requirements
BIPRU 11.5 sets out the disclosure requirements in relation to the remuneration of code staff which all FSA regulated firms are required to comply. The Company is a Tier 4 firm and the following disclosures are intended to fully satisfy the requirements of the remuneration code (“the Code”).
Disclosure of compliance with Remuneration Code
The Company has in place internal policies, practices and procedures consistent with the FSA’s rules and regulations for Tier 4 firms. The members of the Board form the remuneration committee and the members fully acknowledge their responsibilities under the Code including their overriding responsibility to ensure that Advent Capital Management UK Limited’s (“Advent Capital” or the Firm”) remuneration policies, practices and procedures:
- are in line with the business strategy, objectives and long-term interests and values of the Firm;
- are consistent with and promote sound and effective risk management and do not encourage risk taking that exceeds the level of tolerated risk of the Firm;
- are appropriate to attract, motivate and retain suitable staff;
- are representative of the underlying performance of the business and do not reward individuals for poor performance; and
- include measures to avoid conflicts of interest.
The following disclosures have been made in accordance with the FSA rules and regulations as outlined under BIPRU 11.5.18 and SYSC 19A, specifically in the context of the Firm’s obligations under the FSA’s remuneration code.
As permitted by the Code, the Firm has adopted the FSA’s proportionality approach for Tier 4 firms in applying the requirements of the Code. All decisions in relation to the remuneration of code staff are made and approved by the Firm’s remuneration committee, with no input from external consultants. Remuneration is determined with reference to a number of factors including, but not limited to, the performance of the individual, the Company and the individual’s adherence to the Firm’s risk management and compliance procedures.
Variable remuneration which is paid in the form of bonuses is only awarded after full consideration of these factors together with an assessment of any current or potential risks to the business in the context of these payments.
In accordance with the FSA’s proportionality approach for Tier 4 firms, the Firm has elected not to apply the FSA’s specific regulatory requirements in relation to the fixed and variable elements of total remuneration; the payment of variable remuneration through retained shares or other instruments; the deferral of these payments; or performance adjustments.
The remuneration committee believes that its remuneration policies, procedures and practices are fully aligned with the objectives of funds under management and its customers and that the payment of variable remuneration is therefore aligned to the performance and success of the funds which the Firm acts as investment manager or advisor.
On an annual basis, the Firm’s directors and senior management are notified of the Firm’s profits. Profits can be allocated as employee bonuses or director’s dividends and adjustments can be made at any time after Advent Capital ensures that FSA capital and liquidity requirements are satisfied. The amounts of any discretionary awards are determined by the Advent Capital’s directors / senior management in their capacity as the Firm’s remuneration committee and the Firm’s Code Staff received aggregate remuneration of £1,109,460 for the year ended 31 December 2010.