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Here you will find M&G's policies, regulatory reporting information, The Financial Conduct Authority's Business Principles and M&G's own set of Business Principles.
Financial Regulatory Reporting
Pillar 3 Disclosures
The EU Capital Requirements Directive requires firms to publish details of their risks, capital and risk management. These are known as Pillar 3 disclosures.
FMSB Statement of Commitment
M&G lnvestment Management Limited (‘M&G’) acknowledges that the Standards published by the FICC Markets Standards Board ("FMSB") represent generally recognised good practice in the wholesale Fixed lncome, Currencies and Commodities ("FICC") markets. M&G confirms that it is committed to conduct its FICC market activities (its "Activities") in a manner consistent with the Core Principles contained in FMSB Standards, and to have internal policies, procedures and controls reasonably designed to give effect to those Core Principles where they are applicable to its Activities, in a manner that is commensurate with the nature of its Activities in the relevant entity or jurisdiction.
This Statement of Commitment applies to all Standards published by FMSB in final form between 1 January 2018 and 31 December 2018 and reaffirms any previous Statements of Commitment made by M&G.
Gender pay gap reporting
The Government requires all businesses with more than 250 employees in the UK to publish their UK gender pay gap data annually. M&G’s 2017 gender pay gap report can be found here:
Gifts and hospitality policy
M&G may provide or receive hospitality or small business gifts from intermediaries who sell our products, operators of funds in which we invest clients’ money, or other counterparties with whom we deal on your behalf. The hospitality is typically a meal or attendance at a social engagement, where the opportunity exists for participants to discuss business issues such as market developments or M&G Group products. M&G may also provide assistance – such as providing a speaker or paying towards materials used at a business training event or a conference organised by or for such firms. Such gifts and hospitality are in no way predicated on past current or future business activity. M&G’s procedures place controls on such arrangements to ensure that there is no customer disadvantage.
Further details can be obtained on request: email@example.com
M&G's business principles
M&G has its own set of business principles which reflect and reinforce our culture and reflect the importance of treating customers fairly. In summary, they act as a framework for how we run our business. They are:
Shareholder Rights Directive Engagement Policy
This policy sets out how M&G meets the requirements of the Shareholder Rights Directive and how we exercise our engagement responsibilities as stewards of our clients' assets. Its scope covers all funds and portfolios managed, whether directly or via a delegation, by M&G Investment Management Limited and M&G Alternatives Investment Management Limited.
In response to the Market Abuse Regulation, effective date 3 July 2016, and with particular reference to ESMA’s final report on market soundings and delay of disclosure of inside information [ESMA/2016/1130] of the 13 July 2016, M&G has designated specific personnel to receive market soundings for M&G. All other individuals within M&G have been advised that they are not permitted to receive market soundings.
Article 11(1) of MAR describes a ‘market sounding’ as a communication of information, prior to the announcement of a transaction, in order to gauge the interest of potential investors in a possible transaction and the conditions relating to it such as its potential size or pricing, to one or more potential investors.
To request the list of personnel authorised to receive market soundings, please contact firstname.lastname@example.org
MiFID II Policies and Disclosures
This Execution Policy outlines the execution service M&G Investment Management Limited (“MAGIM”) provides for its Professional Clients, in accordance with the UK Financial Conduct Authority’s amended rules (which implement the Markets in Financial Instruments Directive 2014/65/EU and Markets in Financial Instruments Regulation (EU) 600/2014 (“MiFIR”), together “MiFID II”.
MAGIM has published these documents in line with the requirements of MiFID II, which requires portfolio managers to summarise and disclose annually the top five execution venues in terms of trading volumes where they executed decisions to deal in the preceding year and associated information on the quality of execution for each class of financial instrument.
This Statement outlines M&G’s approach to inducements and investment research in connection with services M&G provides to you.
The Financial Conduct Authority's business principles
All financial services companies have to operate within the Financial Conduct Authority's stated ‘Principles for businesses’. They are:
1. Integrity. A firm must conduct its business with integrity.
2. Skill, care and diligence. A firm must conduct its business with due skill, care and diligence.
3. Management and control. A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
4. Financial prudence. A firm must maintain adequate financial resources.
5. Market conduct. A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
6. Customers' interests. A firm must pay due regard to the interests of its customers and treat them fairly.
7. Communications with clients. A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.
8. Conflicts of interest. A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client .
9. Customers: relationships of trust. A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgment.
10. Clients' assets. A firm must arrange adequate protection for clients' assets when it is responsible for them.
11. Relations with regulators. A firm must deal with its regulators in an open and cooperative way, and must disclose to the appropriate regulator appropriately anything relating to the firm of which that regulator would reasonably expect notice.