Your privacy is very important to us. This notice (“Privacy Notice”) is provided by High Ground Investment Management LLP (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

How we collect information about you 

We may collect personal data about you through:

• information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
• information that we obtain in relation to any transactions between you and us;
• recording and monitoring of telephone conversations and electronic communications with you as described below; or
• the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

Why we collect information about you 

We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

What are the consequences of failing to provide your personal information? 

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

The types of personal data we may collect and use 

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials.

Do we use automated decision-making processes? 

No.

Do we share your personal information with third parties? 

We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

• our affiliates or other entities that are part of our group or with our clients;
• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
• our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
• service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
• credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
• any person, as directed by you; or
• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

Transfers of personal information to countries outside of the European Economic Area (EEA) 

Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

For how long do we keep your personal information? 

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

What are your rights? 

You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

• to request access to your information;
• to request rectification of inaccurate or incomplete information;
• to request erasure of your information (a “right to be forgotten”);
• to restrict the processing of your information in certain circumstances;
• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
• where relevant, to request the portability of your information;
• where you have given consent to the processing of your data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority.

How to contact us 

If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Chief Operating Officer by email at operations@hgim.co.uk or by writing to High Ground Investment Management LLP, 2 Babmaes Street, London, SW1Y 6HD United Kingdom.

Complaining to ICO 

You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.

Use of cookies 

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

Recording and monitoring of communications 

We may record and monitor telephone conversations and electronic communications with you for the purposes of:

• ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;
• ensuring compliance with our regulatory obligations; or
• detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, High Ground Investment Management LLP (“HGIM” or “theFirm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code 2020 (the“Code”) or, where it does not commit to the Code, explain its considered choice based on the Firm’s investment approach.

The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.

The Firm pursues a strategy involving investment in global equities, including UKequities. The code is therefore relevant to some aspects of the Firm’s activity. A consistent global approach is taken to engagement with issuers and their management in all of the jurisdictions in which the Firm invests and, consequently, the Firm does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

Whilst the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code at this time.

Under Rule 2.2B.5 of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, High Ground Investment Management LLP (“HGIM” or “the Firm”) is required to make disclosures in relation to compliance with the Shareholder Rights Directive II (“SRD II”). SRD II aims to strengthen shareholder engagement and increase transparency for asset managers and owners.

Under Rule 2.2B.5 of the FCA Conduct of Business Sourcebook, we are required to:

1. 1. develop and publicly disclose an engagement policy that meets the
      requirements of COBS 2.2.B.6R; and
   2. 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
2. publicly disclose an explanation of why we have chosen not to comply with
   any of the requirements imposed by (1).

 

The engagement policy must describe how a firm:

1. integrates shareholder engagement in its investment strategy;
2. monitors investee companies on relevant matters, including;
   1. strategy;
   2. financial and non-financial performance and risk;
   3. capital structure; and
   4. social and environmental impact and corporate governance.
3. conducts dialogues with investee companies;
4. exercises voting rights and other rights attached to shares;
5. cooperates with other shareholders;
6. communicates with relevant stakeholders of the investee companies; and
7. manages actual and potential conflicts of interests in relation to the
   firm’s engagement.

 

Annual disclosure must include 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 how it has cast votes in the general meetings of companies in which it holds shares unless votes are insignificant due to the subject matter of the vote or the size of the holding in the company.

HGIM believe firmly in the importance of effective stewardship and long-term decision making. The Firm has chosen not to comply currently on the basis that it does not expect to make investments that would constitute a significant holding in any single investee company.