Liontrust Responsible Capitalism Report 2022 - Flipbook - Page 38
Code of Conduct
Liontrust’s required standards of conduct and behaviour are promoted and enforced through a
comprehensive suite of policies and procedures which, together with our Compliance Manual
and our values, constitute our code of conduct.
Compliance
Liontrust’s business activities require regulatory authorisation or registration. The majority of
our funds are regulated by the Financial Conduct Authority (FCA), with the remainder being
regulated by the Central Bank of Ireland.
Liontrust’s UK subsidiaries are regulated by the FCA and the
Luxembourg subsidiary is regulated by the Commission de
Surveillance du Secteur Financie (CSSF). We adhere fully to the
FCA’s principles for business.
The Compliance Manual covers various regulations and summarise
how they apply to Liontrust, including details on the regulatory
structure in the UK. The Compliance Manual also acts as the Code
of Ethics for the company. We have also adopted the Chartered
Financial Analyst Institute’s Asset Manager Code, a voluntary code
of conduct to help asset managers practice ethical principles that
put client interests first. The Compliance Manual must be read and
attested to on an annual basis by all employees and partners.
We will provide a brief description of some of the key areas
covered by our Compliance Manual, given their relevance for our
industry and their associated risks.
Anti-bribery and Corruption
Liontrust has an internal policy on Anti-Bribery and Corruption, which
is reviewed annually. A risk assessment on Bribery is also undertaken
annually. 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 its clients. 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. At no time should staff bribe another
person or accept a bribe: Liontrust has appropriate policies,
procedures and reporting measures in place, and staff undertake
training on a biennial basis.
Financial Crime and Market Abuse
Liontrust takes its obligations to tackle financial crime seriously;
not only does it pose a reputational and legal risk to the firm
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and its stakeholders, it is also the right thing to do. 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. These include: 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; keeping
abreast of industry developments and ensuring that any significant
developments are noted in staff training.
We will proactively manage any problem accounts where the
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 courtesies. In addition,
Liontrust 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 ensure that our staff are provided with appropriate
training in relation to their respective roles to prevent of financial
crime and money laundering.
Whistle Blowing
Our Whistle Blowing Policy forms an integral part of our culture
of openness, transparency and fairness. Where any employee
discovers information which they believe shows malpractice or
wrongdoing within Liontrust, under most circumstances they will raise
concerns with their line manager, who will pass this information to
the appropriate Executive Director or to the Compliance team. Staff
can also raise concerns directly to the Compliance team. Should
these routes not be suitable, then the employee may contact the
FCA directly. Our policies are clear that there should be no fear of
reprisal or victimisation or harassment for whistle blowing.