NORTH ROCK CAPITAL MANAGEMENT UK - ONLINE PRIVACY POLICY

​Last Revised: August 2023

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North Rock Capital Management (UK) LLP (“the Firm”) and LH NR UK Ltd (collectively, “we,” “us” or “our”) are committed to safeguarding your privacy rights and ensuring that your individually identifiable information (“Personal Data”) is protected. This Privacy Policy (the “Policy”) explains our use of your Personal Data when you visit our website (the “Site”) and/or interact with us. It applies to job applicants, other candidates for employment or consultancy, former employees, professional contacts, visitors to our website or offices and prospective members of the Firm.

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The Policy also explains your rights and options around how we use your Personal Data. We may amend this Policy from time-to-time without prior notification to intended recipients.

We are the controller of your Personal Data and our contact details are set out at the end of the Policy.

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Please ensure that you provide a copy of this Privacy Policy to any third parties whose Personal Data you provide to us.

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1. INFORMATION WE COLLECT ABOUT YOU

We collect various types of information when you visit our website, submit an application for employment, are considered for potential recruitment by the Firm or one of its parent group entities, or communicate with us in any way including pursuant to you (or any entity you represent) engaging in any commercial dealings with us.

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Information we may collect and the means of collection may include:

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• Applicants, recruitment and staff: we will collect Personal Data directly from you during your application / recruitment process, as well as periodically thereafter. This may include your CV and any information voluntarily disclosed by you. The Firm may also collect Personal Data about you from third parties, such as recruitment agencies, referees, background-check providers, disclosure and barring services, assessment platformproviders, any LinkedIn account that is maintained by you, and from other publicly available sources.

 

• Visitors to our website: we collect data including browser type, IP address, date and time of visit, and various cookies. Please see the Terms of Use for more information.

 

• General communications with us: we collect your contact details including name, title, e-mail address, telephone number and other information you voluntarily provide if you contact us by email, telephone or other means of electronic or personal communication. Personal Data included in any correspondence is also collected when communicating via letter.

 

• Any documents you send to us: we will record any Personal Data included in documents that you send to us, including application forms for potential employment or other contractual engagements. This may include special categories of Personal Data, such as sensitive data or criminal records data.

 

• Electronic communications, including telephone communications with recorded staff: we archive all written electronic communications received and sent by our staff, and record the telephone lines of certain of our staff, for regulatory purposes. Your communications and conversations with such staff through corporate recorded systems will also be recorded.

 

• Use of the Guest WiFi services: we collect information from the users of our guest WiFi at our London offices (48-49 Pall Mall, St James’s London SWY 5JG).

 

• CCTV images: we operate CCTV at our London offices (48-49 Pall Mall, St James’s London SWY 5JG).

 

Personal Data which may be collected, depending upon the nature of your relationship and means of communication with us, could include:

• Contact information, including name, email address, and residential address;

• personal information such as date of birth and marital status;

• employment and education history (including internal and external employment history, references and organizational data such as department, work location, job title and seniority);

• unique identifiers such as national insurance/social security number, tax details, IP address and information relating to that IP address;

• passport details;

• financial information, including bank account details and credit history;

• test results; and

• other categories of  Personal Data, which may include Special Categories of Personla Data such as details of your political affiliations or beliefs, details about your immediate family members, your ethnicity, your religious beliefs and sexual orientation, health information, and details about actual or alleged criminal convictions and offences.

If you provide Personal Data on behalf of another person, it is your responsibility to notify that individual that you have provided their information to us and direct them to this notice. You are not obliged to provide information when it is requested by us, but this may affect our ability to consider you for employment or otherwise initiate or continue dealings with you or your firm, see below. In particular, if you apply for a role with the Firm and fail to provide certain Personal Data when requested which is necessary for the Firm to comply with its legal or contractual obligations, or pursuant to the Firm’s legitimate interests to manage its business appropriately, the Firm will not be able to consider the application and/or process the application successfully.

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2. HOW INFORMATION IS USED

Your Personal Data will be used by us for the following purposes:

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Please note that you have a right to object to processing of your Personal Data where that processing is carried out for our legitimate interests or for direct marketing. However, please note that the Firm may not be able to fulfil this request in all instances.

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3. INFORMATION WE DISCLOSE

We may share your Personal Data with selected third-party business partners, affiliates, associates or subcontractors in order to achieve the purposes described in HOW INFORMATION IS USED, above.

This may include sharing your information with (i) other entities in the North Rock Capital Management and Lighthouse Investment Partners group; (ii) financial institutions, pension plan institutions, insurance companies, consultant and professional advisors (including law firms); (iii) compliance solution providers, including electronic communications and trade surveillance platforms; (iv) other service providers such as, payroll administrators, benefits providers, background check vendors, assessment platform providers, and administrators and information technology systems providers involved in the provision of services to the Firm and/or its personnel; (v) independent public accountants and auditors, authorized representatives of internal control functions such as, audit, legal and/or corporate security; or (vi) financial services regulators, local tax authorities and any governmental or administrative body where the Firm determines that it is necessary or desirable in order to comply with applicable laws, court orders, or government regulations or to protect the rights or property of the Firm or any of its employees.
 

We also reserve the right to share your Personal Data with a third party that is looking to acquire, or does acquire, all or part of the assets of the Firm, or that succeeds the Firm in carrying on all or a part of the Firm or services provided to or by it whether by merger, acquisition, re-organization, outsourcing, insourcing or otherwise.

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4. NON-UK PROCESSING AND INTERNATIONAL TRANSFERS

The global nature of our business means that we may contract with service providers, or otherwise transfer your information to recipients, outside of the UK. This may include a recipient located in a country which may not be subject to the same data protection laws as companies based in the UK. In these circumstances, we will take steps to make sure the Personal Data is provided an adequate level of protection, and will implement appropriate safeguards.

The Firm ensures its data processors provide sufficient safeguards for all Personal Data processed, regardless of each provider’s location. Where we transfer Personal Data outside of the UK, we will ensure that the Personal Data is transferred to a recipient:

• established in a country which has been deemed to have adequate data protection laws by the UK (an adequacy decision);

• with which we have entered Standard Contractual Clauses (SCCs), as relevant, which oblige the recipient to protect your Personal Data per the principles of UK GDPR;

• from which we have sought assurances from the recipient that they have Binding Corporate Rules (BCRs) in place; or

• in relation to which we can rely on a derogation for the transfer (e.g., where the transfer is necessary for the defence of legal claims, or otherwise obtain consent).

The Firm has entered into SCCs for transfers of Personal Data to its affiliates outside of the UK.

For further information in relation to these safeguards, please contact us using the contact details below.

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5. RETENTION OF YOUR INFORMATION

We retain Personal Data as long as it is necessary and relevant for us. We determine the retention period based upon the longest of the following:

• as long as the Personal Data is necessary for the relevant services and activities that we undertake with you, or period set out in any relevant agreement that you enter with us;

• the length of time required or is otherwise reasonable to meet our legal and regulatory obligations; or

• any period in which investigations or litigation may arise in respect of our relationship with you.

In particular, further to the Firm’s recruitment process, where an application is unsuccessful your Personal Data will be securely destroyed 12 months after the end of the application / recruitment process, unless you request otherwise.

Where an application is successful, the Personal Data gathered during the recruitment / application process will be transferred to your personnel file and retained during the course of your relationship with the Firm. The periods for which your Personal Data will be held in these circumstances will be provided to you in a separate data protection notice.

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6. YOUR RIGHTS

You have certain rights in relation to your Personal Data, including the right to:

• request access to Personal Data we hold about you;

• the correction of your Personal Data when incorrect, out of date or incomplete;

• request that we erase your Personal Data;

• object to us using / holding your Personal Data if we have no legitimate reason to do so;

• request that we restrict the processing of your Personal Data – i.e., we would need to secure and retain the data for your benefit but not otherwise use it; 

• withdraw your consent at any time; and

• the portability of Personal Data – i.e., ask for a copy of your Personal Data to be provided to you, or a third party, in a digital format.

 

We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months, and we will tell you why. We may request proof of identification to verify your request. These rights are not absolute, they do not always apply, and exemptions may be applicable and we may request additional information to better understand your request. For more details in relation to your rights, including how to exercise them, please contact us using the contact details below.

 

You also have the right to lodge a complaint about the processing of your Personal Data with the data protection authority – in the UK, this is the Information Commissioner’s Office (ICO) whose website is available at https://ico.org.uk.

 

7. CONSEQUENCES OF NOT PROVIDING PERSONAL DATA

Where we require your Personal Data necessary for a legal or contractual requirement, failure to provide this information means we may not be able to provide the requested services to you, enter a business relationship with you (or your firm) or to consider you for prospective employment. We will tell you upon request whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.

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8. OTHER IMPORTANT INFORMATION

Changes to the Policy

We may change this Privacy Policy from time to time by posting a new version of the policy on our Site. We will notify you of any material changes via e-mail or through a notification on our Site. Any changes to the Privacy Policy will become effective immediately after being posted.

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9. CONTACT DETAILS

All enquiries, requests or concerns regarding this Notice or relating to the processing of your Personal Data, including any requests detailed in Section 6, above, should be sent to the Chief Compliance Officer, UK by email: oliver.robinson@northrockllc.com or by post: 2nd Floor, 48-49 Pall Mall, St James’s, London, SW1Y 5JG.

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North Rock Capital Management (UK) LLP

Shareholder Rights Directive (SRD) Disclosure Statement

 

Rule 2.2B.5R of the FCA Conduct of Business Sourcebook (“COBS”) requires North Rock Capital Management (UK) (“the Firm”) to:

• develop and publicly disclose on its website, a copy of its engagement policy which includes the content specified in the amended EU Shareholder Rights Directive (Directive 2007/36/EC); and

• publicly disclose on an annual basis how its engagement policy has been implemented, including a general description of its voting behaviour, an explanation of its most significant votes and details of its use of the services of proxy advisors.

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• publicly disclose a clear and reasoned explanation of why it has chosen not to comply with those requirements.

The Firm has considered its SRD obligations and has decided not to adopt and maintain an engagement policy. The Firm supports the general principles of shareholder engagement, however, it does not consider it appropriate to adopt an engagement policy or make the relevant public disclosures at this point in time.

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The Firm operates a multi-team, multi-strategy model of investment management across a wide range of jurisdictions and timeframes, primarily in relative-value strategies. The Firm does not pursue an activist approach. Exposure to European equities is typically gained through swap positions, rather than holding cash equities, thus opportunities to the Firm for shareholder engagement are fewer than for buy-and-hold cash shareholdings.

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Where the Firm does hold cash shares with a listing on a UK or EEA market, or on a comparable market outside the EEA, the level of shareholder engagement is dependent on a number of factors. The Firm is a sub-advisor to a US-based investment manager and while the Firm may, in certain limited circumstances, engage with an issuer’s management on strategy, performance, risk, corporate governance, or other issues, typically the level of its shareholder engagement is limited to the responsible exercise of voting rights in accordance with the North Rock Group’s Proxy Voting Policy.

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The Firm will keep its position under review and will update this section of its website, accordingly, if there is a change in its approach.

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North Rock Capital Management (UK) LLP

UK Financial Reporting Council’s Stewardship Code - Statement

 

Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook (“COBS”) requires North Rock Capital Management (UK) LLP (“the Firm”) to disclose on its website or in another accessible form:

• the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (“the Code”), or

• where it does not commit to the Code, its alternative investment strategy.

The Code was re-published in October 2019 and sets out a number of principles relating to investor engagement with the companies and other assets in which they are invested. Compliance with the Code is voluntary in nature on a “comply or explain” basis.

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The Firm is supportive of the policy objectives of the Code, however has not decided to commit to the Code.

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The Firm pursues a multi-strategy approach across multiple independent investment teams across multiple jurisdictions and timeframes, focusing on relative value strategies. The Firm does not take an activist approach to investing. In particular, the Firm does not typically pursue buy-and-hold strategies of UK equities and undertakes all UK equity investment through swap and CFD which offer a restricted ability to undertake shareholder engagement. The Firm is also a Sub-Advisor to a US investment manager, and any proxy engagement is subject to a group-wide approach.

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The Firm periodically reviews its position regarding the Code and, if the Firm’s strategies change such that the Code becomes more relevant, the Firm will amend its approach accordingly.

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North Rock Capital Management (UK) LLP

MIFIDPRU 8 Disclosure for the period 1
July 2023 - 30 June 2024

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North Rock Capital Management (UK) LLP (“the Firm”) is an investment management firm authorised and regulated by the Financial Conduct Authority (“FCA”) as a MIFIDPRU investment firm. The Firm is categorised under the FCA prudential regime for MiFID investment firms (“MIFIDPRU”) as a Small Non-Interconnected Firm (“SNI”).

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The Firm has produced this disclosure in relation to its remuneration policies and practices, per its obligations under Chapter 8 of MIFIDPRU. It has been prepared based on the Firm’s audited financial statements covering the accounting period 1 July 2023 to 30 June 2024.  This disclosure has been made according to the size and internal organization of the Firm’s business, and to the nature, scope and complexity of its activities.

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Significant changes since the prior disclosure period

There have been no significant changes to the information disclosed since the Firm’s last disclosure period.

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Remuneration policy and practices

The Firm is subject to the MIFIDRPRU Remuneration Code contained within SYSC 19G of the FCA Handbook (“the Remuneration Code”). The overall aim of the Remuneration Code, and the Firm’s implementation thereof, is to:

• promote effective risk management in the long‑term interests of the firm and its customers,

• ensure alignment between risk and individual reward,

• support positive behaviours and healthy firm cultures, and

• discourage behaviours that can lead to misconduct and poor customer outcomes.

Per SYSC 19G.2 the Firm maintains remuneration policies and practices that:

• are aligned with the business strategy, objectives and long-term interests of the firm,

• are consistent with and promote sound and effective risk management, and

• contain measures to avoid conflicts of interest, encourage responsible business conduct and promote risk awareness and prudent risk taking.

The Firm’s Senior Managers Committee is the governing body responsible for the development and adoption of the Firm’s Remuneration Policy. The Senior Managers Committee is also responsible for overseeing the implementation of the Remuneration Policy. Remuneration is set by the Designated Members. The Firm does not have a Remuneration Committee. All staff are eligible to receive variable remuneration.

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The Firm remunerates its staff in a manner designed to attract the best possible candidates, and to incentivise staff in a way that supports the Firm’s strategy and objectives of maximising persistent risk-adjusted investment returns for its client and for underlying investors, whilst ensuring high standards of compliance and conduct consistent with the Firm’s culture and values. The Firm also pays fixed and variable remuneration to staff in a manner designed not to introduce liquidity or other prudential risks to the Firm.  The long-term success of the Firm is supported by meeting these objectives.

Remuneration awarded by the Firm can be broken out into the following components:

• base salary for members or monthly draw for members. These are fixed remuneration.

• pension contributions by the Firm. This is fixed remuneration.

• discretionary bonuses and investment performance awards. These are variable remuneration.

 

Variable remuneration is a key part of the Firm’s remuneration structuring, and fixed to variable remuneration metrics are tailored to individual staff members’ roles. An individual’s performance is important to the level of variable remuneration awarded, with separate qualitative and quantitative performance metrics applying as relevant to different roles. The Firm in practice operates a single business unit - portfolio management - however, individual teams’ performances within the business unit are relevant. This is the case especially for portfolio management staff for whom the pool of variable remuneration is based on positive investment performance by their specific portfolio management team against the Firm’s relevant risk-management metrics. The Firm’s overall performance is also relevant to total variable remuneration and directly affects the amount of variable remuneration available to be paid to staff.

For the financial year 1 July 2023 to 30 June 2024, the total amount of remuneration awarded to all staff was GBP 21,793,105, of which GBP 11,914,796 was fixed remuneration and GBP 9,878,309 was variable remuneration. “Staff” was interpreted to include all employees and members of the Firm.

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Beware of Fraudulent Schemes Using Our Name and Brands​

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In a rapidly changing technological landscape, cybercriminals are becoming increasingly sophisticated. North Rock Capital takes attempted fraud and the misuse of our brand names very seriously. Investors must exercise caution and remain vigilant to avoid falling victim to these fraudulent schemes.

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Please be alert to scams and frauds that leverage the use of North Rock Capital’s names, publicly available information, and trademarks to give the appearance of authenticity. These schemes are conducted across various instant messaging platforms (e.g. WhatsApp, Telegram, WeChat) or other third-party applications.

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In particular, beware of scams purportedly affiliated with North Rock Capital that promise extraordinary returns on your investment at little to no risk. These “high-yield investment programs” are frauds and are quite common. At times, such schemes involve fraudulent websites, email addresses, third-party applications, social media profiles, and instant messaging chat groups claiming to have ties to North Rock Capital, its employees, affiliates, or counterparties. Such activity is illegal, and unaffiliated with North Rock Capital. For more information on high-yield investment programs and how to avoid them, visit the U.S. Securities and Exchange Commission webpage at http://www.sec.gov/answers/highyield.htm.

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If you become aware of these schemes, please immediately contact the legal department at legal_notices@lighthousepartners.com.   If you feel that you were targeted by or invested in a fraudulent scheme with a company purported to be associated with North Rock Capital or any of its businesses, brands, or names, we suggest that you immediately report the individuals to your local law enforcement agency, which is best placed to investigate such crimes.​​

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