Regulatory and Other Information

Trading and Status Disclosures

Sanderson Asset Management LLP (“Sanderson”) is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom and is registered with the United States Securities and Exchange Commission. Sanderson may only provide investment management services in those states and countries in which it is appropriately registered or otherwise exempt or excluded from registration requirements.

Sanderson is a UK limited liability partnership (“LLP”) incorporated under the laws of England and Wales (Company Number: 0C375320) with its registered address at Heathcoat House, 20 Savile Row, London, W1S 3PR.

No Offer or Advice

Sanderson makes this website available as a source of information about the firm, its people and services. The services described may not be available to, or suitable for you. Nothing on the site constitutes investment advice nor does it represent any offer to provide services or to buy or sell securities of any kind.

An offer or solicitation will be made only through a final private placement offering memorandum, subscription agreement and other related documents with respect to a particular investment opportunity and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor.

Stewardship Policy and Pillar 3 Disclosures

As required under Chapter 11 of the Prudential Sourcebook for Banks, Building Societies and Investment Firms (“BIPRU”) of the FCA Handbook, a summary of Sanderson's risk management objectives and policies, capital computation and computation methods, data on capital resources and other information required under the rules (“Pillar 3 Disclosure Statement”) is available here. As required under Chapter 2 of the Conduct of Business Sourcebook (“COBS”) of the FCA Handbook, Sanderson’s Stewardship Policy is available here .

Complaints Handling

Sanderson is subject to the complaint handling requirements of the Dispute Resolution: Complaints Sourcebook ("DISP") of the FCA Handbook. Under DISP, Sanderson is required to establish effective and transparent procedures for the reasonable and prompt handling of complaints received from eligible complainants. In the event a complaint cannot be rectified, Sanderson must notify the client of their rights of referral to the Financial Ombudsman Service.

Illegal Use of Firm Name

Please be aware that Sanderson’s name, as well as the names of connected entities and individuals, may be misused for fraudulent purposes by organisations and individuals unconnected to us. To appear genuine, fraudsters may quote Sanderson’s FCA Firm Reference Number, address, company registration details or logo.

If you suspect that you have been the target of a fraud by someone claiming to represent or be connected to Sanderson, in the first instance, please contact Action Fraud on 0300 123 2040 or visit www.actionfraud.police.uk to make a report, quoting reference number NFRC160501413607. Alternatively, please contact us using the details shown on the Financial Services Register on the Financial Conduct Authority’s website (www.fca.org.uk) or provided at the bottom of this page.

Website Disclaimer

No representation or warranty is given as to the accuracy, completeness or current nature of the information on this site. Sanderson shall not be liable for any loss or damage however it arises from the use of its website or its content, except as imposed by law or regulation.

International Use

This website is operated and controlled by Sanderson in/from the United Kingdom (“UK”). Owing to the global nature of the Internet, this website may be accessed by users in countries other than the UK. Sanderson’s makes no warranties that the information and materials on this website are appropriate or available for use in such locations. If it is illegal or prohibited in your country of origin to access or use this site, then you should not do so.

Restrictions on Use

This website and its contents are the property of Sanderson. You may not reproduce, modify or distribute the contents of this website without prior consent from Sanderson.

Modifications to Content

Sanderson may, at its discretion, modify or discontinue any of the content of this site, or any portion thereof, with or without notice.

Anti-Slavery and Human Trafficking Statement

Modern slavery is a crime and a violation of fundamental human rights. It can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Sanderson Partners Limited, Sanderson Asset Management LLP and Sanderson Asset Management, Inc. (for purposes of this statement only, “Sanderson”) is committed to acting ethically and with integrity in its business dealings and commercial relationships and to implementing and enforcing effective systems and controls to help to ensure that modern slavery is not taking place within its business or supply chains.

Sanderson’s services are provided from offices in London and Chicago. Sanderson’s directors, officers, employees and legal members (as appropriate) are subject to a Code of Ethics which sets out high ethical standards for business conduct. Annual training is provided on the importance of ethical conduct.

Sanderson’s primary suppliers include custodians, fund administrators, IT service providers and professional services firms (these typically provide legal, tax and accounting services). Sanderson has considered its risk profile and that of its primary suppliers. Sanderson’s larger primary suppliers in the UK are required to publish anti-slavery policies and procedures, which Sanderson has reviewed. In the case of certain smaller suppliers, where Sanderson has determined that the risks of exploitation may be higher, Sanderson has utilised contract wording (for example on right to work status and minimum pay levels in excess of living wage figures) to help ensure compliance.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes Sanderson’s slavery and human trafficking statement for the current financial year.

Contact Information

If you have any questions regarding Sanderson’s website, in particular relating to the documents and information provided above, please contact James Longbottom, Sanderson’s Chief Compliance Officer, direct on +44 (0)207 468 5961 or via email at jlongbottom@sandersonam.com.