This page contains details of important policies for Church House Investment Management.
Church House is authorised and regulated by the Financial Conduct Authority to conduct investment business, including the ability to deal in investments on behalf of clients.
We have a duty under the FCA Conduct of Business rules to take all sufficient steps to obtain the best possible results for clients when executing orders. Please refer to our Order Execution Policy, which outlines our methodology for achieving the best possible outcomes for our clients when executing trades on their behalf.
Modern Slavery Policy
Modern slavery is a serious and often hidden crime. It can include slavery, servitude, forced and compulsory labour and human trafficking. The common factors are that a victim is, or is intended to be, used or exploited for someone else’s gain (usually financial), without respect for their human rights. Church House prohibits the use of modern slavery and human trafficking in its operations and supply chain. We have a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all of our investment and business relationships. We have established systems and controls to ensure that modern slavery is not taking place anywhere within our organisation.
We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our business counterparts and suppliers.
This policy applies to all persons working for Church House or on behalf of us in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
UK Stewardship Code
Church House has developed a stewardship policy in accordance with the UK Stewardship Code on how it integrates shareholder engagement in our investment strategy.
Our policy outlines the principles upon which Church House engages with shareholders in its investment strategy, monitors the companies with which it has invested, how it conducts dialogue with them, its policy for exercising voting rights and how it communicates with relevant stakeholders and other shareholders.
Obligations relating to shareholder engagement and transparency under the EU Shareholder Rights Directive II was implemented in the UK from 10 June 2019 and specific rules relating to UK asset management firms are included in the Financial Conduct Authority's Conduct of Business Rules. Church House is required to develop and publicly disclose an engagement policy that complies with these requirements. We are currently in the process of developing an engagement policy and will update our website in due course.
Environmental, Social & Governance Policy
In addition to complying with the Stewardship Code, and in support of our investment activity in both the CH funds and our clients' discretionary portfolios, we have an Environmental, Social and Governance (ESG) Policy. This helps to identify our approach to investment activity in the companies we select to meet the associated investment mandates. This policy supports our overall approach to investment in companies with sustainable business practices and operating models, run by people with integrity, using sound governance structures.