We take care to maintain high standards of service. If we are aware of client concerns or unease, we give priority to resolving the matter as quickly as possible. To assist with this process we have prepared procedures to ensure that complaints are handled fairly and within reasonable timescales. The below is a summary of our complaint handling procedure. A copy of our full procedure is available on request.
How to make a complaint
If you have a complaint about us and/or our services, you should direct this in the first instance to your investment manager. If you are uncomfortable doing so, your complaint can be directed to the Compliance Officer or the Chief Executive Officer. You can complain in writing, by telephone, by fax or via e-mail. Details can be found on the Contact us page.
What happens after I have complained?
Upon receipt of a complaint, a senior person who, where possible is independent of the case, will investigate the complaint. You will be given the name and contact details of the person dealing with your complaint. We will aim to resolve the complaint as quickly as possible. The person investigating your complaint will:
The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary. Your complaint will be investigated using our files together with reports from other parties if relevant. We may also write to you if further information is required.
We will keep you informed of the progress of the complaint investigation. After eight weeks, if a final response letter has not already been sent to you, you will receive a final response letter detailing our conclusions and resolution to the complaint. If we are not in a position to make a final response, we will give the reasons for the delay and will indicate when we expect to be able to provide a full response.
What if I am still not satisfied?
Within our final response letter to you, we will include details of the Financial Ombudsman Service (the “FOS”) whom, provided you are an eligible complainant, you have the right to right to refer a complaint if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. Further information about the FOS and whether you are an eligible complainant can be found at http://www.financial-ombudsman.org.uk or by calling 0800 023 4567.
This Special Regulatory Information document (together with the documents referred to in it) provides you with important information about the regulatory framework within which LGT Wealth Management US Limited ("LGT WM US", "We" or "us") operates.
The information contained herein may be changed by us without notice and so you should check this page from time to time for any updates.
LGT WM US is authorised and regulated by the Financial Conduct Authority ("FCA") in the United Kingdom, and is a Registered Investment Adviser with the Securities & Exchange Commission ("SEC") in the United States. Our FCA registration details are set out in the FCA Register under Firm Reference Number 585547 (www.fca.org.uk). Our SEC details are set out in the Investment Adviser Public Disclosure under SEC Reference Number 801-77580 (http://www.adviserinfo.sec.gov).
LGT WM US is registered in England & Wales (registered number 06455240) and our registered office is 14 Cornhill, London EC3V 3NR.
LGT WM US is a wholly owned subsidiary of LGT Wealth Management UK LLP. LGT Wealth Management UK LLP is a limited liability partnership incorporated in England & Wales (registered number OC329392), is authorised and regulated by the FCA under Firm Reference Number 471048 and is a Member of the London Stock Exchange.
LGT WM US's advisory and discretionary portfolio management services are restricted to providing clients with specialist expertise and advice on the management of investment portfolios. As a firm, LGT WM US is able to source investment solutions from the whole of market and we are not tied to any products or providers. However, we will not consider clients’ wider financial planning and pension requirements, unless a client expressly wishes us to do so, when the client will be referred to one of our wealth planners.
We take care to maintain high standards of service. If we are aware of client concerns or unease, we give priority to resolving the matter as quickly as possible. To assist with this process we have prepared procedures to ensure that complaints are handled fairly and within reasonable timescales. The below is a summary of our complaint handling procedure. A copy of our full procedure is available on request.
How to make a complaint
If you have a complaint about us and/or our services, you should direct this in the first instance to your investment manager. If you are uncomfortable doing so, your complaint can be directed to the Chief Compliance Officer or the Chief Executive Officer. You can complain in writing, by telephone, by fax or via e-mail. Details can be found on the Contact us page.
What happens after I have complained?
Upon receipt of a complaint, a senior person who, where possible is independent of the case, will investigate the complaint. You will be given the name and contact details of the person dealing with your complaint. We will aim to resolve the complaint as quickly as possible. The person investigating your complaint will;
The acknowledgement may, especially in the case of an oral complaint, set out the nature of the complaint and may request further clarification if necessary. Your complaint will be investigated using our files together with reports from other parties if relevant. We may also write to you if further information is required.
We will keep you informed of the progress of the complaint investigation. After eight weeks, if a final response letter has not already been sent to you, you will receive a final response letter detailing our conclusions and resolution to the complaint. If we are not in a position to make a final response, we will give the reasons for the delay and will indicate when we expect to be able to provide a full response.
What if I am still not satisfied?
Within our final response letter to you, we will include details of the Financial Ombudsman Service (the “FOS”) whom, provided you are an eligible complainant, you have the right to right to refer a complaint if you are not satisfied with our response. Any referral to the FOS must be made within 6 months of receiving our final response. Further information about the FOS and whether you are an eligible complainant can be found at http://www.financial-ombudsman.org.uk or by calling 0800 023 4567.
For more information about our Execution Venues please click here.
Pillar III Disclosures
Given the industry in which LGT Vestra US operates is subject to a number of risks including but not exclusively credit risk, market risk, operational risk, liquidity risk and interest rate risk. Please click here for our Pillar 3 disclosure.
Remuneration
Our remuneration policy is designed to ensure that we comply with the Remuneration Code and our compensation package is in line with the Firm’s strategy and objectives. The policy is designed to create a direct link between reward and performance, encourage a team ethic throughout the business, and promote effective risk management. For our full disclosure statement, contained within our Pillar 3 disclosure.
LGT WM US and the UK Stewardship Code
LGT WM US complies with the UK Stewardship Code (the "Code") which was issued by the Financial Reporting Council in July 2010 and amended in September 2012 in respect of our activities for professional clients. "Stewardship" means the way in which we look after our clients’ best interests and manage their investments by actively monitoring the companies in which we invest on their behalf.
Although LGT WM US primarily manages the assets of natural persons who are classified as retail investors, this policy statement focuses instead on our professional clients and summarises how we apply the seven principles of the Code.
1.Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities
LGT WM US manages client assets on a discretionary and advisory basis, seeking to maximise investment returns for each client. It is central to our investment process to consider each company’s ability to create, sustain and protect value. Therefore, we continually assess the performance of the management of companies in which we have invested on behalf of our clients and whether or not our clients' interests are being best served. Effective monitoring of investee companies is fundamental to fulfilling our responsibility of our clients. An investment is unlikely to be made if we have significant concerns about either management or matters of corporate governance.
From time to time where deemed appropriate, discretionary proxy voting decisions may be taken. This is done with our clients' best interests in mind at all times.
2. Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.
LGT Vestra US maintains a robust policy on managing conflicts of interest which is designed to ensure its decisions are taken wholly in the interest of its clients. LGT WM US aims to ensure that all potential and actual conflicts are identified, recorded, evaluated, managed and monitored.
A summary of LGT WM US's conflicts of interest policy is available to clients upon request.
3. Institutional investors should monitor their investee companies.
Comprehensive and continuous research and monitoring of investee companies is fundamental to LGT WM US's investment process as our investment strategy typically looks to long term investment rather than continual turnover of clients’ portfolio holdings. Monitoring typically occurs though financial reporting, general meetings, in connection with news and announcements and research LGT WM US may conduct when looking into investment ideas or reviewing our approved lists of securities.
4. Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.
Where we have concerns about the performance or strategy of an investee company or where we have reason to believe that our client’s rights as shareholders are being compromised in any way, we will escalate our engagement with the investee company’s management and take any trading decisions accordingly.
5. Institutional investors should be willing to act collectively with other investors where appropriate.
LGT WM US's long-term investment strategy and research process mean that it will rarely be necessary for such collective action to taken. However, if such collective action is deemed to be in the best interests of our clients, it will be carefully considered and may be taken accordingly.
6. Institutional investors should have a clear policy on voting and disclosure of voting activity.
Where we take voting decisions on behalf of our clients, we will always act in a manner consistent with our clients' best interests. Where necessary or appropriate, we endeavour to engage with investee companies. Records of our votes on behalf of particular clients are available to those clients upon request.
We do not lend stock.
7. Institutional investors should report periodically on their stewardship and voting activities.
We regularly report investment activity to our clients, and where it is considered relevant to the client, we will report details of our stewardship and voting activities.
YOU SHOULD BE AWARE THAT A POSITIVE PERFORMANCE IN THE PAST IS NO GUARANTEE OF A POSITIVE PERFORMANCE IN THE FUTURE. THE RISK OF FALLING PRICES, FOREIGN CURRENCY LOSSES AND FLUCTUATING RETURNS DUE TO EXCHANGE RATES WHICH ARE UNFAVOURABLE FOR INVESTORS CANNOT BE EXCLUDED. IT IS POSSIBLE THAT INVESTORS WILL NOT GET BACK THE FULL AMOUNT THEY INVESTED. COMMISSIONS AND CHARGES LEVIED ON THE ISSUANCE AND REDEMPTION OF UNITS ARE DEBITED SEPARATELY TO EACH INVESTOR.
INVESTORS ARE SPECIFICALLY ADVISED THAT CERTAIN INVESTMENTS ARE HIGHLY VOLATILE. SUCH INVESTMENTS, SUCH AS DERIVATIVES, MAY BE SUBJECT TO SIGNIFICANT PRICE FLUCTUATION, WHICH MAY BE EQUAL TO OR GREATER THAN THE AMOUNT OF CAPITAL INVESTED.
CERTAIN SPECIFIC INVESTMENTS MAY NOT BE IMMEDIATELY REALIZABLE. IT MAY THEREFORE BE DIFFICULT FOR INVESTORS TO SELL AN INVESTMENT, REALISE A PROFIT, OR OBTAIN RELIABLE INFORMATION AS TO ITS VALUE OR THE DEGREE OF RISK TO WHICH THE INVESTMENT IS EXPOSED.
WHEN BUYING OR SELLING INVESTMENTS INVOLVING A CONTINGENT LIABILITY, NOT ONLY MAY YOU LOSE THE AMOUNT INVESTED, BUT IN CERTAIN CIRCUMSTANCES YOU MAY ALSO BE REQUIRED TO PAY AN ADDITIONAL AMOUNT.
Forward-looking for generations
Advice is subject to any legal, regulatory or jurisdictional constraints. Investors should be aware that past performance is not an indication of future performance, the value of investments and the income derived from them may fluctuate and you may not receive back the amount you originally invested.
LGT Wealth Management US Limited is Authorised and Regulated by the Financial Conduct Authority ("FCA") in the United Kingdom, and is a Registered Investment Adviser with the Securities & Exchange Commission ("SEC") in the United States. Registered office: Fourteen Cornhill, London, EC3V 3NR.