AIFMD Disclosures

This section deals with our responsibilities under the Alternative Investment Fund Managers Directive (AIFMD) to keep investors in Alliance Trust PLC (an AIF) informed about certain regulatory matters. Alliance Trust Investments Limited (ATI) is the manager (AIFM) of the AIF. In this section we aim to provide you with the regulatory information you need and to ensure that we maintain the high conduct standards required of us by our regulator, the Financial Conduct Authority.

Conflicts of Interest

Alliance Trust Investments has set a Policy on the management of Conflicts of Interest, with the objective of ensuring that investors are not adversely affected. This document summarises our Conflicts of Interest Policy. The Policy applies to all employees. Third parties to whom key functions are delegated are also required to operate conflicts of interest controls which meet the regulatory requirements. Alliance Trust Investments has a Conflicts of Interest Register which notes the conflicts of interest that have been identified and the controls in place to manage those conflicts of interest.

The full Conflicts of Interest document can be viewed here

Best Execution and Order Handling Policy

This Policy explains how Alliance Trust Investments arranges for the execution of decisions made by its investment team to buy or sell investments for its clients ("orders"). ATI operates a centralised dealing desk which is responsible for the execution of all trades. The dealing desk is independent of our investment team and retains discretion on how orders are executed in accordance with this Policy.

The full Best Execution and Order Handling Policy document can be viewed here

Investor Disclosure

This document is issued by Alliance Trust Investments solely in order to make certain particular information available to investors in Alliance Trust PLC before they invest, in accordance with the requirements of the FCA Rules implementing the AIFM Directive in the United Kingdom.

The full Investor Disclosure document can be viewed here

AIFMD Disclosure as at 31st December 2015

The Alternative Investment Fund Managers Directive (AIFMD) came into effect on 22nd July 2013. Alliance Trust PLC (the “Company”) is an ‘alternative investment fund’ (‘AIF’) for the purposes of the EU Alternative Investment Fund Managers Directive (Directive 2011/61/EU). Alliance Trust Investments Limited (the “AIFM”) is authorised and regulated by the United Kingdom Financial Conduct Authority with permission to manage an AIF for the purposes of that Directive. The AIFM has been appointed by the Company as its AIFM to manage the Company’s investments under an investment management agreement (IMA).

One of our commitments to investors, as described in our Investor Disclosure Document, is to disclose any changes to the maximum level of leverage which the Company may employ and also the total amount of leverage employed.

As per this document ’Leverage’ is a term used to describe any method by which the company increases its exposure, whether through borrowing (gearing) or through leverage embedded in derivative positions or by any other means. Leverage is calculated in two ways: as a gross figure, and by the ‘commitment’ method, which takes into account netting of positions. As the leverage calculation includes exposure created by the company’s investments, it is only described as ‘leveraged’ if its overall exposure is greater than its net asset value. This is shown as a leverage ratio of greater than 100%.

The Company is only permitted to use those types and sources of leverage which are consistent with its investment policy and its object of spreading investment risk. In addition to borrowing (gearing), the Company can use derivative instruments to hedge, enhance and protect positions, including currency exposures, and for investment purposes. The circumstances in which the Company may use derivatives are explained in the Investor Disclosure Document in the section entitled ‘Investment strategy and techniques’. The leverage policy has been approved by the Board which limits the leverage ratio that can be deployed by the Company at any one time to 145% (gross) and 140% (commitment method). This includes any gearing created by the Company as permitted by its investment policy. This is a maximum figure as required by regulation, and not necessarily the amount of leverage that is actually used. This maximum figure has not changed.

The Trust total leverage figures as included in the AIFMD report to the FCA for 31st December 2015 were as follows;

  • As calculated under the Gross Method – 113.0%
  • As calculated under the Commitment Method – 113.6%
The document also makes comment on Liquidity Risk Management and specifies that we will disclose the percentage of assets held which are subject to special arrangements arising from their illiquid nature. The Company does not currently hold any such assets.

The Company will make the 2015 disclosures on its website at the same time as it makes its annual report and accounts available to investors or more frequently at its discretion.

Please see the Annual Report and Accounts for details of other AIFMD disclosures.

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