Disclaimers & Legal Information

Arbion Limited is authorised and regulated by the Financial Conduct Authority (FCA).

Our registration details are set out in the FCA Register: Firm Reference No 513138 www.fca.gov.uk/register.

Arbion Limited is a private limited company incorporated in England and Wales under company number 07044573 with its registered office located at One Connaught Place, London, W2 2ET.

This website is for information only. The wording contained in this website is not to be construed as advice or an offer, advice, invitation or solicitation to enter into any financial obligation, activity or promotion of any kind. The provision of any investment services and products, whether or not mentioned in this website, may not always be suitable for an investor, and we recommend that any potential investor consults a financial adviser before entering into any investment contract.

Please remember that all investments are subject to some degree of risk and that investment value and performance may go up as well as down. You may not always get back all of your investment and there will always be a cost associated with any product which you may purchase or sell. Past performance is not always an indication of future performance.

Arbion Limited takes considerable care to ensure that the information contained in this website is accurate as of the date of publication. However, no warranty is given as to the accuracy of completeness of any such information and no liability is accepted for any errors or omissions contained therein.

Arbion Limited accepts no legal liability for any loss, damages or expenses which you may suffer or incur directly or indirectly by you accessing this website or any third party website which has a link to this website.

The website is not intended for distribution to, or use by, any individuals or entities in any jurisdiction where such distribution would be contrary to the laws of that jurisdiction or subject Arbion Limited to any registration requirements. Arbion Limited cannot accept any liability for information contained in third party websites which may have links from and to our website.

The Arbion Limited brand identity and its constituent elements (logotype, monogram, descriptor, mark, URL) are the property of Arbion Limited. All rights are reserved. Arbion Limited is SEC authorised to provide investment advice to US Persons, CRD Number 155663. We manage portfolios in compliance with US regulation. For more information on the services we provide please speak to us.

Arbion 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 in the United States. Registered office: One Connaught Place, London, W2 2ET. Our current Client Relationship Summary - Form ADV Part 3, can be found here.

Our ADV Part 2A and Part 2B for year end 31 December 2023, updated in December 2023, can be found here.

BEST EXECUTION POLICY

Under the FCA rules, we are required to put in place an order execution policy and to take all sufficient steps to obtain the best possible result on behalf of our clients when executing orders or receiving and transmitting orders for execution.

Arbion's Best Execution Policy can be found here.

TOP 5 EXECUTION VENUES

We are required by the Markets in Financial Instruments Directive (MiFID I) 2014/65/EU to set out the Top 5 execution venues where we have executed client orders in the preceding year in relation to dealings in financial instruments. Arbion does not execute client orders directly, and therefore is not responsible for the selection of trade venues or the order execution strategy. Arbion transmits client orders directly to the client’s Platform Provider or Custodian who is responsible for the selection of trade venues. Arbion's Top 5 Execution Venues can be found here.

CONFLICTS OF INTEREST

Arbion has a duty to take all appropriate steps to identify and prevent or manage conflicts of interest that arise or may arise during the course of providing services to our clients. Arbion's Conflicts of Interest Policy can be found here.

UK STEWARDSHIP CODE AND EU SHAREHOLDER RIGHTS DIRECTIVE DISCLOSURE STATEMENT

Under COBS 2.2 of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the Stewardship Code ("the Code"), which was published by the Financial Reporting Council ('FRC') in July 2010. In addition, the EU Shareholder Rights Directive II ("SRD Il'") implemented in June 2019, sets out to strengthen the position of shareholders and to ensure that decisions are made for the long-term stability of companies. The obligations which apply to asset managers are listed under COBS 2.2B.

The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a "comply or explain" basis. The FRC recognise that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
  • Monitor their investee companies:
  • Establish clear quidelines on when and how they will escalate their activities as a method of protecting and enhancingshareholder value;
  • Be willing to act collectively with other investors where appropriate;
  • Have a clear policy on voting and disclosure of voting activity;
  • Report periodically on their stewardship and voting activities. SRD I requires asset managers to "comply or explain" how it:
  • Integrates shareholder engagement in its investment strategies;
  • Monitors investee companies on relevant matters (e. g. strategy, financial and non-financial performance and risk, capital structure, social and environmental impact and corporate governance);
  • Conducts dialogues with investee companies;
  • Exercises voting and any other shareholder rights;
  • Cooperates with other shareholders;
  • Communicates with relevant stakeholders of investee companies;
  • Manages actual and potential conflicts of interests in relation to Arbion's engagement.

Arbion Limited does not currently comply with the Code or SRD II on the basis that it does not trade in listed companies on behalf of its discretionary clients or fund range. Should any of the above factors change, we will review our commitment to the Code and our obligations under SRD II at that time and make appropriate disclosure. We will also monitor communications from the FCA on its work with FRC as the communications from the FCA on its work with FRC as the Stewardship Code 2020 is introduced and take any further actions required as the new Code takes effect.

IFPR DISCLOSURE

Arbion Limited and subsidiary Squared Limited ("Arbion") are subject to the FCA Rules of remuneration as they apply to a small and non-interconnected (SNI) MIFIDPRU investment firm. Our Disclosure can be found here.

ESG POLICY

Arbion's ESG Policy can be found here.

TERMS OF BUSINESS

Arbion's Terms of Business can be found here.

PRIVACY POLICY

Arbion's Privacy Policy can be found here.

COMPLAINTS

Arbion believe that all clients deserve a high quality service. If you are unhappy with our service you are entitled to express your dissatisfaction with any member of staff or contact us in writing. We undertake to deal with your complaint fairly and effectively. We will act in accordance with the rules and regulations set out by the Financial Conduct Authority (FCA). You should address your complaint as follows:

The Compliance Officer

Arbion Limited

One Connaught Place

London, W2 2ET

Email: info@arbion.com

The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services businesses aren't able to resolve themselves.

To contact the Financial Ombudsman Service please visit

www.financial-ombudsman.org.uk