General

The data protection policy of MAC Asset Management aims to comply with the GDPR issued by the European Commission 2016/679. This policy explains how data collected about you will be treated — how it will be collected, used, protected and stored — and sets out the rights you have regarding this data.

Who Are the People Subject to the Collection?

MAC Asset Management clients, website visitors and individuals who voluntarily submit their data.

Why MAC Asset Management Collects Your Data?

MAC Asset Management uses this data in order to comply with its regulatory obligations and to improve the services offered to its clients.

How Do We Collect the Data?

Confirmation of reading these terms and conditions will place a cookie on your computer's hard drive to facilitate your navigation on our website. By voluntarily completing forms on our site, you also submit information directly to us.

What Data Do We Collect?

MAC Asset Management collects personal data such as address, phone number, email address, and other information when voluntarily submitted on the website.

Who Has Access to Your Data?

MAC Asset Management uses and stores this data on its internal systems, and may transfer it to partner companies inside or outside the European Union for the purpose of providing services to you.

How Long Is Your Data Kept?

Your data is kept for a period of five years in order to comply with regulatory requirements.

What Rights Do You Have?

You have the right to freely access, update, delete and recover your data, and can at any time withdraw your consent to the processing of your data. Contact: info@mac-am.co.uk

Documents & Disclosures

• Conflicts of Interest PolicyRead Document
• UK Stewardship Code DisclosureRead Document
• Order Execution PolicyRead Document
• Capital Requirement DisclosureRead Document

Introduction

MAC Asset Management Limited ("MAC AM") is authorised and regulated by the Financial Conduct Authority. This policy sets out the arrangements MAC AM has in place to identify and manage conflicts of interest that may arise in the course of carrying out its regulated activities.

What is a Conflict of Interest?

A conflict of interest arises when the interests of MAC AM, or individuals associated with it, diverge from the interests of a client, or where the interests of two or more clients diverge. MAC AM is committed to identifying and managing such conflicts fairly.

Identification of Conflicts

MAC AM has identified the following potential sources of conflict:

Own account dealing: Staff may hold personal investments that conflict with client interests. MAC AM operates a personal account dealing policy that restricts and monitors such activity.

Remuneration structures: Staff remuneration may create incentives to favour certain transactions. MAC AM's remuneration policy is designed to avoid such incentives.

Multiple client relationships: MAC AM may act for clients with competing interests in the same financial instruments or markets.

Gifts and inducements: Receipt of gifts or inducements from third parties could create conflicts. MAC AM maintains a gifts and inducements register and policy.

Management of Conflicts

MAC AM manages conflicts of interest through the following measures:

Information barriers: Restricting the flow of information between departments where conflicts may arise.

Independent supervision: Ensuring that individuals involved in activities giving rise to potential conflicts are supervised independently.

Disclosure: Where conflicts cannot be adequately managed, MAC AM will disclose the nature of the conflict to the client before proceeding.

Declining to act: In certain circumstances, MAC AM may decline to act where a conflict of interest cannot be adequately managed or disclosed.

Personal Account Dealing

MAC AM operates a personal account dealing policy that requires staff to obtain pre-clearance before undertaking personal transactions in securities. Staff are prohibited from dealing in advance of client orders or using confidential client information for personal benefit.

Disclosure

Where MAC AM determines that the arrangements in place are not sufficient to prevent a conflict of interest from adversely affecting a client's interests, MAC AM will disclose the general nature and sources of the conflict to the client prior to carrying out business on their behalf.

Review

This policy is reviewed annually and updated as required to reflect changes in the business or regulatory environment. MAC AM's Compliance function is responsible for overseeing its implementation.

Last reviewed: 2024  |  FCA Reference: 752141

Statement on the UK Stewardship Code

MAC Asset Management Limited ("MAC AM") is an investment manager authorised and regulated by the Financial Conduct Authority. This disclosure sets out MAC AM's approach to stewardship in respect of the assets it manages on behalf of clients.

Our Approach to Stewardship

MAC AM recognises the importance of stewardship and the role that investment managers can play in promoting long-term value creation for clients. MAC AM's primary focus is on fixed income and structured products. Given the nature of these asset classes, traditional stewardship activities such as voting at shareholder meetings are largely not applicable to the majority of MAC AM's activities.

Engagement

Where MAC AM invests in equity instruments, it seeks to engage with issuers on matters of governance, environmental and social responsibility where this is considered relevant to the long-term value of the investment. MAC AM may engage directly with company management or through intermediaries as appropriate.

Conflicts of Interest in Stewardship

MAC AM manages conflicts of interest arising in the context of stewardship activities in accordance with its Conflicts of Interest Policy. Where a potential conflict is identified, MAC AM will seek to manage it through disclosure, escalation or abstention as appropriate.

Monitoring Issuers

MAC AM monitors investee companies and issuers on an ongoing basis, taking into account financial performance, strategy, capital structure, risk management and, where relevant, environmental, social and governance ("ESG") factors. Monitoring activities are conducted as part of MAC AM's broader investment process.

Non-Compliance with the UK Stewardship Code

The UK Stewardship Code 2020 sets out a series of principles for asset managers. MAC AM acknowledges that, as a predominantly fixed income manager, full compliance with all principles of the Code is not practicable given the nature of its business. MAC AM is committed to applying the principles of stewardship in a manner that is proportionate and appropriate to its business model.

Last reviewed: 2024  |  FCA Reference: 752141

Introduction

MAC Asset Management Limited ("MAC AM") is required under the Markets in Financial Instruments Directive II ("MiFID II") and FCA rules to take all sufficient steps to obtain the best possible result for its clients when executing orders. This document sets out MAC AM's Order Execution Policy.

Scope

This policy applies to all orders executed by MAC AM on behalf of its professional clients in financial instruments including fixed income securities, equities, structured products and other instruments.

Best Execution Factors

When executing client orders, MAC AM takes into account the following factors to achieve best execution:

Price: The price at which the transaction is executed, including any commissions or fees.

Costs: All explicit costs borne by the client, including commissions, exchange fees and clearing costs.

Speed: The speed at which an order can be executed in the prevailing market conditions.

Likelihood of execution and settlement: The probability that the order will be executed at the required size and settled in a timely manner.

Size and nature: The size of the order and the nature of the financial instrument, including whether it is traded on a regulated market or OTC.

Market impact: The potential impact that executing the order may have on the market price of the instrument.

Execution Venues

MAC AM operates its own trading desk, which provides a significant advantage in terms of execution quality, speed and liquidity access. MAC AM maintains relationships with a range of counterparties including major investment banks, specialist brokers and electronic trading platforms. Execution venues are selected on the basis of their ability to deliver consistent best execution across relevant asset classes.

Monitoring and Review

MAC AM monitors the effectiveness of its order execution arrangements on an ongoing basis and reviews this policy at least annually. Where deficiencies are identified, corrective action will be taken promptly.

Client Consent

By entering into an agreement with MAC AM, clients are deemed to have consented to this Order Execution Policy. Clients may request information on MAC AM's execution arrangements and the venues used at any time.

RTS 28 Reporting: MAC AM publishes annual RTS 28 reports setting out the top five execution venues used in the preceding year, available on request.

Last reviewed: 2024  |  FCA Reference: 752141

Introduction

MAC Asset Management Limited ("MAC AM") is required under the Investment Firms Regulation ("IFR") and Investment Firms Directive ("IFD") to disclose information in relation to its capital resources and requirements. This disclosure is made in accordance with the FCA's rules implementing the IFR/IFD framework for investment firms.

Regulatory Capital

MAC AM is classified as a non-interconnected investment firm ("Class 3") under the IFR/IFD framework. As such, MAC AM is subject to capital requirements determined by reference to a fixed overhead requirement ("FOR") or a permanent minimum capital requirement ("PMR"), whichever is higher.

Capital Resources

MAC AM's regulatory capital consists entirely of Common Equity Tier 1 ("CET1") capital, comprising paid-up share capital and retained earnings. MAC AM does not hold any Additional Tier 1 or Tier 2 capital instruments.

Capital Adequacy

MAC AM maintains capital resources in excess of its regulatory capital requirements at all times. The firm conducts an Internal Capital Adequacy Assessment ("ICAA") on an annual basis to assess whether its capital resources are adequate relative to the risks it faces.

Remuneration Policy

As a Class 3 investment firm, MAC AM is exempt from the full remuneration requirements under the IFD. MAC AM nonetheless maintains a remuneration policy that is consistent with sound risk management and does not encourage excessive risk-taking.

Contact

For further information regarding MAC AM's capital position or regulatory disclosures, please contact: info@mac-am.co.uk

Last reviewed: 2024  |  FCA Reference: 752141

Legal Information

The information on this site is issued by MAC Asset Management Limited ("MACAM"), authorised and regulated by the Financial Conduct Authority ("FCA") in the United Kingdom. Investment products and services are only available to professional clients and eligible counterparties.

Past Performance

Any performance data quoted represents past performance and does not indicate future results. Future returns are not guaranteed and a loss of principal may occur.

Accuracy of Information

The information contained on this site has been obtained from sources believed by MACAM to be reliable, but is not guaranteed as to its accuracy or completeness.

Copyright

Copyright, trademarks and all similar rights in this site are owned by MACAM. You may use and reproduce information on this site in hard copy for personal reference only.

Data Protection

MACAM collects certain personal information when voluntarily submitted on this site and uses this information for regulatory compliance and internal purposes.