Vedra Partners Limited (“Vedra” or “the Firm”) is a company registered in the UK.
For the purposes of the General Data Protection Regulation (‘GDPR’), Vedra will be the ‘controller’ of personal data that we have received. Please read the following information carefully in order to understand the Firm’s practices in relation to the treatment of your personal data.
What data privacy principles does the Firm adhere to?
- The Firm will process all personal data in a lawful, fair and transparent manner;
- The Firm will only collect personal data where it is necessary;
- For the Firm to provide a service to you and to the company that you represent (hereinafter referred to as “you” as is appropriate to the context);
- For you and the company that you represent to provide a service to the Firm;
- For the Firm to keep you informed of its products and services; or
- For the Firm to comply with its legal and regulatory obligations.
- The personal data collected by the Firm will be adequate, relevant and limited to what is necessary in relation to the specific purpose for which your data will be processed;
- The Firm will take all reasonable steps to ensure that personal data is accurate and, where necessary, kept up-to-date;
- The Firm will maintain personal data in a form that permits identification no longer than is necessary for the purposes for which the personal data has been collected for processing, in accordance with the Firm’s record retention procedures;
- The Firm will hold and process personal data in a manner that ensures appropriate security;
- The Firm may share personal data with other entities within the Vedra group where necessary for the provision of services. Where such entities are outside of the EEA, personal data will be treated as is required under GDPR;
- The Firm will only share personal data outside of the Vedra group where it is necessary to provide the agreed service or where it is necessary for the Firm to comply with its legal requirements;
- The Firm will only utilise a service provider based outside of the EEA for the processing of personal data where this is strictly necessary to facilitate our services to you. In all cases, we will ensure service providers are fully compliant with GDPR ahead of transferring any personal data.
What personal data does the Firm collect and why?
The type of personal data (e.g. name, contact details, address etc.) that we may collect will depend upon the relationship between Vedra and you. The data so collected may be provided directly by you or, where appropriate, provided by third parties e.g. references, credit checks etc.
As a client, a contact, or service provider of Vedra we will require some personal information in order to verify your identity and have the applicable relationship with you. The information collected will vary depending on the service the Firm provides to you or you provide to the Firm, but typically includes:
- Personal information: Such as your name, date of birth, passport number or national insurance number;
- Contact information: Including your address, telephone number and email address.
Where does the Firm store my personal data?
The Firm has comprehensive policies and procedures in place to ensure your personal data is kept safe and secure. Further details can be provided on request.
How long does the Firm retain personal data?
Vedra will retain personal data for as long as is necessary for the purposes for which it was collected (or longer period if so required by law or legitimate interests) which will be at least for the period in which Vedra has a business interest with you.
Any information that is outside the scope of this requirement will be retained whilst relevant and useful, and destroyed where this ceases to be the case or where the data subject specifically requests this.
How have I been categorised in accordance with GDPR?
The GDPR requires the Firm to inform you of the legal basis on which we maintain your personal data. As a general rule the following is applicable:
- Clients – Information is maintained on the basis of contractual obligation and/or legitimate interests (where relevant);
- Service providers – Information is maintained on the basis of contractual obligation;
- Database/marketing contacts – Information is maintained on the basis of legitimate interest; and
- Other contacts – we may on occasion request your consent to use and process personal data.
What are my rights?
You have certain rights which apply in respect of your personal data, depending on your relationship with the Firm and the Firm’s legal and regulatory obligations.
- You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email the Firm (details shown below). The Firm will provide this information to you within one month (with the ability to extend this by an additional two months where necessary), free of charge.
- You have the right to request that the information the Firm holds about you is erased under certain circumstances including where there is no additional legal and/or regulatory requirement for the Firm to retain this information.
- You have the right to request that any personal data you have provided to the Firm be transmitted to another controller in a commonly used and machine-readable format, otherwise known as ‘data portability’.
- You have the right to ensure that your personal information is accurate and up to date, or where necessary rectified. Where you feel that your personal data is incorrect or inaccurate and should therefore be updated, please contact the Firm (details shown below).
- You have the right to object to your information being processed, for example for direct marketing purposes.
- If Vedra has relied upon ‘consent’ for the processing of personal data then you have the right to withdraw such consent.
- You have the right to restrict the processing of your information, for example limiting the material that you receive or where your information is transferred.
- You have the right to object to any decisions based on the automated processing of your personal data, including profiling (although Vedra does not use any automated processing or profiling).
- You have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/ if you are not happy with the way that we manage or process personal data.
Will I be notified of changes to this policy?
The Firm may, from time to time, review and update this policy. The Firm will maintain the latest version of this policy on its website, and where the changes are deemed material, it will make you are aware of these.
Who should I direct questions to?
If you have any questions, concerns or complaints about the practices contained within this document or how the Firm has handled your data, please contact us on 0203 941 2891.
Vedra Partners Limited (the “Company”) has a zero tolerance policy to tax evasion and the facilitation of tax evasion. We are fully committed to complying with all legislation and appropriate guidelines designed to prevent tax evasion and the facilitation of tax evasion in the jurisdictions in which we, our service providers and business partners operate. The Company is subject to the Criminal Finances Act 2017 and has adopted a policy, endorsed by the board, designed to prevent tax evasion and the facilitation of tax evasion. Our policy establishes a culture across the company and in relation to our service providers and other counterparties, in which tax evasion and the facilitation of tax evasion is unacceptable. The policy is based on a detailed risk assessment undertaken by the board annually.
Vedra Partners Limited commitment to the UK Stewardship Code
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Vedra Partners Limited (the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.
The seven principles of the Code are that institutional investors should:
- Publicly disclose their policy on how they will discharge their stewardship responsibilities;
- Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
- Monitor their investee companies;
- Establish clear guidelines on when and how they will escalate their activities;
- Be willing to act collectively with other investors where appropriate;
- Have a clear policy on voting and disclosure of voting activity; and
- Report periodically on their stewardship and voting activities.
The Firm provides investment management services to various professional clients (“the Clients”) that pursue investment strategies that may involve both bond and equity investments via ETF’s and or directly with listed equity providers. While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The approach of the Firm in relation to engagement with issuers and their management is determined globally. The Firm takes a consistent approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.
For further information, please contact us on 0203 941 2891.
Shareholder Rights Directive II (“SRD II”)
Vedra Partners Limited
SRD II aims to improve stewardship and corporate governance by firms, including UK MiFID investment firms that invest in shares traded on a regulated market in the EEA, as well as ‘comparable’ markets situated outside of the EEA. Under FCA COBS 2.2.B.5R, we are required to:
- develop and publicly disclose an engagement policy that meets the requirements of COBS 2.2B.6R; and
- publicly disclose on an annual basis how our engagement policy has been implemented in a way that meets the requirements of COBS 2.2B.7R; or
- publicly disclose why we have chosen not to comply.
The engagement policy must describe how we:
- integrate shareholder engagement in our investment strategy:
- monitor investee companies on relevant matters, including:
a) strategy;b) financial and non-financial performance and risk;c) Capital structure; andd) social and environmental impact and corporate governance;
- conduct dialogues with investee companies;
- exercise voting rights and other rights attached to shares;
- cooperate with other shareholders;
- communicate with relevant stakeholders of the investee companies; and
- manage actual and potential conflicts of interests in relation to our engagement.
On an annual basis, we must disclose a general description of voting behaviour, an explanation of the most significant votes and reporting on the use of the services of proxy advisors. The disclosure must include details of how votes have been cast, unless they are insignificant due to the subject matter of the vote or to the size of the holding in the company.
Vedra Partners Limited is considering whether or not an engagement policy will apply based on the investment strategies pursued by the fund(s) to which we provide investment services.