Regulatory & Legal
Terms and Conditions
Welcome to the website (“Site”) of Scott Investment Partners LLP (“Firm”), a limited liability partnership registered in England (Reg. No. OC 379480) and governed under the laws of England, which laws limit the personal liability of partners.
Please read the following information carefully. Access to this website is subject to conditions. By accessing the website, you confirm the following:
- That you are permitted to access this Site because you are a professional client or an eligible counterparty for the purposes of the FCA Rules or an accredited investor and sophisticated person under Regulation D of the SEC Rules.
- That you are accessing this Site on an unsolicited basis, on your own initiative and in compliance with the laws and regulations of the jurisdiction or country in which you are residing.
- You acknowledge expressly that you have read and understood the Terms & Conditions of use (“T&Cs”) and agree to abide by them.
The services described on this website are provided by Scott Investment Partners LLP.
The contents of this website have been issued and approved for the purposes of Section 21 of the Financial Services and Markets Act 2000 by Scott Investment Partners LLP, which is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom with a firm registration number 592409. The Firm is also registered with the US Securities and Exchange Commission (‘‘SEC’’) as a Registered Investment Adviser.
By accessing this Site you confirm that you understand and agree to be bound by the T&Cs and any regulatory requirements governing the use of the Site. You may not use the Site in any way that is fraudulent or unlawful.
This Site is for information purposes only. Nothing on this Site is intended to constitute an offer or solicitation to invest or sell of any nature in any jurisdiction, or to recommend any investment or transaction.
The Firm will not be held liable for any virus, imperfection, fault, omission, mistake or inaccuracy on this Site, its contents or associated services, or due to any unavailability of the Site or any part thereof or any contents or associated services.
This website may contain links to third-party websites. Please note that our T&Cs apply only to our website. Scott Investment Partners LLP has no control over the content of third-party websites.
Scott Investment Partners LLP is the exclusive owner or licensee of all copyright, trademarks, design rights and other intellectual property rights relating to any information contained within this website.
Reproduction of part or all of the website contents in any form is prohibited except for personal use. No content of this website may be used, copied or distributed to any other publication in any form including electronic, hard copy or any other.
Scott Investment Partners LLP is committed to complying with the applicable law on data protection and privacy including the General Data Protection Regulation (Regulation 2016/679), UK GDPR and Data Protection Act 2018. Any dealings we have with your personal data will be governed accordingly.
Regulatory & Legal
Stewardship and Engagement
Scott Investment Partners LLP is fully supportive of the Financial Reporting Council’s (“FRC”) UK Stewardship Code (“Code”). Effective from 1st January 2020, the Code has been substantially updated to be applicable to a broader range of investment strategies. It also reflects the growth of environmental factors, particularly climate change, as well as social and governance factors (together, “ESG”) as material issues for asset managers to consider when making investment decisions and undertaking stewardship.
In the 2020 version, the Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society”.
There are twelve Principles of the Code that apply to asset owners and asset managers. These are grouped under four headings as follows:
Purpose and Governance
- Purpose, strategy and culture.
- Governance, resources and incentives.
- Conflicts of interest.
- Promoting well-functioning markets.
- Review and assurance.
- Client and beneficiary needs.
- Stewardship, investment and ESG integration.
- Monitoring managers and service providers.
Exercising Rights and Responsibilities
- Exercising rights and responsibilities.
Rule 2.2.3R of the Financial Conduct Authority Conduct of Business Sourcebook (“COBS”) requires an FCA authorised firm to disclose the nature of its commitment to the FRC’s UK Stewardship Code or, where it does not commit to the code, its alternative investment strategy.
As an investment manager Scott Investment Partners LLP endeavours to apply its approach on stewardship to all companies in which we invest on behalf of our clients. This approach is consistent with the Firm’s overall aims, which are to provide good long-term performance to our clients and to keep our clients’ interests paramount.
The investment philosophy of Scott Investment Partners LLP was created by Dr Walter Scott in the early 1980s. This philosophy has been successful over many years by already including the principles of the UK Stewardship Code of 2020. Although not a signatory to the Code we are therefore fully supportive of its principles which closely correlate with our pre-existing investment philosophy and culture.
As an asset manager Scott Investment Partners LLP is also fully supportive of the goals of the Shareholder Rights Directive II (SRD II). The Firm has chosen to not release an annual disclosure of its engagement activity and voting behaviour on the grounds of confidentiality but is confident that its long-held investment philosophy and culture are commensurate with the goals of SRD II.
As an active investor Scott Investment Partners LLP believes that the purchase of a share in a business comes with rights and responsibilities. Positive engagement with these businesses is a powerful tool in driving shareholder value. As such we:
- Engage with the management of investee and prospective investee companies.
- Evaluate a company’s performance of its business strategy, financial management, risk assessment and ESG factors.
- Continually monitor all investee companies to ensure execution is as expected.
- Exercise our right to vote on all issues where we have authority to do so at shareholder meetings.
- Cast all votes in the best interests of our clients.
- Regularly report our voting activities to clients where they have requested us to do so.
- Ensure there are no conflicts of interest – the interests of the clients always come first.
Regulatory & Legal
The Financial Conduct Authority in the Prudential sourcebook for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Scott Investment Partners LLP. Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which the Firm must comply, further to those prudential requirements.
Scott Investment Partners LLP is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.
The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture and to assist stakeholders in making more informed decisions about their relationship with the Firm.
Remuneration Policy and Practices
Overview As an SNI MIFIDPRU Investment Firm, Scott Investment Partners LLP is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of the remuneration requirements is to:
- Promote effective risk management in the long-term interests of the Firm and its clients.
- Ensure alignment between risk and individual reward.
- Support positive behaviours and healthy firm cultures.
- Discourage behaviours that can lead to misconduct and poor customer outcomes.
The objective of the Firm’s remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the conservative risk profile of the Firm and the services that it provides to its clients.
In addition, Scott Investment Partners LLP recognises that remuneration is a key component in how the Firm attracts, motivates and retains quality staff, and sustains consistently high levels of performance, productivity and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and provide its greatest competitive advantage.
Scott Investment Partners LLP is committed to excellence, teamwork, ethical behaviour and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude and results.
Characteristics of the Firm’s Remuneration Policy and Practices Remuneration at Scott Investment Partners LLP comprises fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance as well as the financial and non-financial performance of the individual in contributing to the Firm’s success. All staff members are eligible to receive variable remuneration.
Scott Investment Partners LLP is an investment management firm with a long-term, conservative view both in its approach to equity investing and in how the business is run. The Firm takes a similarly conservative approach to remuneration, ensuring that sufficient capital is always maintained.
Governance and Oversight The Executive Committee of Scott Investment Partners LLP is responsible for setting and overseeing the implementation of the Firm’s remuneration policy and practices. In order to fulfil its responsibilities, the Executive Committee:
- Is appropriately structured to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital and liquidity.
- Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm.
- Ensures that the Firm’s remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors and other stakeholders in the Firm.
- Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of the Firm and of its clients.
Regulatory & Legal
Scott Investment Partners LLP strives to uphold the highest of standards. However, we acknowledge that on occasion a complaint may be made against the Firm. We take all complaints seriously.
If you are dissatisfied or feel the need to make a complaint in respect of the services that we provide to you, please contact us through one of the following methods:
Or write to:
The Compliance Officer
Scott Investment Partners LLP
The Old Rectory
Oxon RG9 1BH
Or telephone: +44 (0) 1491 412 172
You do not need to make the complaint in writing, but it would help our investigation if you could set out all the details clearly in your communication.
We will acknowledge your complaint in writing and provide the name and title of the person who will handle your complaint. This individual will have the authority necessary to investigate the complaint and will be independent of the circumstances of the complaint. We will write to you with the conclusion of the investigation.
Should you not be satisfied with our response, you may refer your complaint to the Financial Ombudsman Service at www.financial-ombudsman.org.uk.