Liontrust Responsible Capitalism Report 2022 - Flipbook - Page 70
COMPLIANCE
Liontrust operates in both the UK and the European Union and is subject
to authorisation and ongoing compliance with regulatory requirements
from multiple regulatory bodies.
These include the FCA in the UK, the Central Bank of Ireland
(CBI) in Ireland and the Commission de Surveillance du Secteur
Financier (CSSF) in Luxembourg. Liontrust’s Chief Compliance
Officer, who holds the SM&CR responsibility for Compliance
Oversight and Financial Crime Compliance (SMF16/SMF17)
in the UK, is supported by a seven-strong team of compliance
professionals in implementing policies, procedures and controls,
as well as ongoing monitoring activity, cyclical and thematic
reviews, regulatory change management and training delivery.
employees receive mandatory annual training on anti-bribery and
corruption, as well as when joining Liontrust, and are asked to make at
least annual attestations on any potential conflicts which may give rise
to the risk of bribery or corruption occurring. Due diligence processes
are in place for any contracted parties or outsourced providers and
these are reviewed in line with the internal Liontrust Counterparty
Selection and Management Policy. Liontrust also has guidelines on
receiving and giving inducements; staff must act honestly, fairly and
professionally in accordance with the best interests of our clients.
Financial crime compliance
Liontrust takes its obligations to tackle financial crime seriously. Not
adhering to regulatory requirements focusing on financial crime poses
a reputational and legal risk to the company and its stakeholders.
Gifts and hospitality
Any gift or hospitality given or received (in line with the relevant
policy) should not impact the business judgement of Liontrust or
its stakeholders and is handled in a transparent and fair manner.
Liontrust will not knowingly allow itself to be used in connection
with money laundering or financial crime. We assess and manage
the risks associated with money laundering and financial crime
in a variety of ways. This includes considering the procedures
adopted to identify customers on a regular basis in association
with our third-party providers; obtaining regular updates on any
unidentified customers and considering the action taken to resolve
those outstanding; undertaking annual (or more frequently as the
risks increase) monitoring reviews of identification procedures;
and sampling paperwork relating to transactions. We keep up
to date with industry developments and seek to ensure that any
significant issues are noted in staff training and implemented in
our processes and policies where appropriate.
Whistleblowing
Liontrust actively seeks to foster a culture of openness, transparency
and fairness. As part of this, it is essential to have a mechanism in
place to allow employees to raise concerns without fear of reprisal,
victimisation or harassment. All employees are made aware of
and have access to our anonymous Whistleblowing reporting
forms through which they can submit concerns on malpractice or
wrongdoing within Liontrust to Compliance. All employees are
also made aware of their ability to make a Whistleblowing report
directly to the FCA.
We will also proactively manage any problem accounts, where
the client’s identity is difficult to confirm, and make the necessary
regulatory reports as appropriate. Liontrust and its staff are not
permitted to offer, make or receive improper payments such
as bribes or kickbacks (whether to government officials or to
private sector customers) or excessively generous business gifts.
In addition, Liontrust and its staff should never use a third party
to undertake any act or function on their behalf which would
circumvent these policies. We are committed to ensuring that our
staff are provided with sufficient training to prevent financial crime
and money laundering.
Anti-bribery and corruption
Liontrust is committed to demonstrating the highest level of integrity
in conducting its business and, as such, has established a number
of controls to support the prevention of bribery and corruption. All
70 - Responsible Capitalism Report 2022
Compliance training
Our policies and procedures are communicated and
enforced through periodic training and auditing.
Our Compliance team develops various e-learning
modules, followed by an assessment or attestation.
Training on key policies and procedures include:
• anti-money laundering
• anti-bribery and corruption
• dealing with conflicts of interest
• market abuse regulations
• treating customers fairly
These e-learning modules are rolled out on a cyclical basis. All
employees and members must complete these modules. All new
joiners are required to complete them within three months of starting.