Regulatory Information

Market Soundings

The Market Abuse Regulation (MAR), which became effective on 3 July 2016, introduced new market soundings (or “pre-marketing”) safe harbours to the offence of unlawfully disclosing inside information. Market soundings communication of information, prior to the announcement of a transaction, in order to gauge the interest of potential investors in a possible transaction and the conditions relating to it such as its potential size or pricing, to one or more potential investors.

Should you wish to discuss market soundings with Chenavari, please email complaints@chenavari.com.

Pillar III Disclosures

As part of the Capital Requirements Directive, introduced by the European Union in 2007, regulated firms have a requirement to publish a document describing the risks they face in their normal course of business, alongside a description of the capital held to support the business.

Pillar 3 complements the minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2), and its aim is to encourage market discipline by developing a set of disclosure requirements. These allow market participants to assess key pieces of information on a firm’s capital, risk exposures and risk assessment processes. The third pillar greatly increases transparency and the disclosures firms must make, and is designed to allow the market and investors to have a better understanding of the overall firm risk.

Please find Chenavari Credit Partners LLP Pillar 3 Disclosure Report here.

Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Chenavari Credit Partners LLP (“Chenavari”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code published in July 2010 and updated in September 2012, and sets out a number of principles relating to engagement by investors with UK equity issuer to exercise their stewardship responsibilities. The Code is applied on a “comply or explain” basis.

Chenavari pursues a number of different investment strategies, including in particular Corporate Credit and Asset Back Securities. Some of the investment strategies have a very limited exposure to equities for which there is not any engagement with issuers in which the funds invest and their management. As a consequence the Code is not perceived as relevant to Chenavari’s trading and therefore Chenavari has chosen not to commit to the Code. We are considering Stewardship issues on a case-by-case basis when and if relevant, making bespoke decisions in the best interests of investors. Should an investment strategy change in such a manner that the provisions of the Code become relevant, Chenavari will reconsider its position under the Code.

Chenavari Slavery and Human Trafficking Statement

Chenavari Credit Partners LLP (“Chenavari” or the “Firm”) and its affiliates acknowledge the importance of compliance with UK the Modern Slavery Act 2015 (the “MSA”). Modern slavery as referred to in the MSA includes slavery, servitude and forced or compulsory labour, and human trafficking.

Although Chenavari does not meet the criteria to make a disclosure, the Firm is committed to conducting its business without modern slavery in either its business or its supply chains and to being transparent in its approach, consistent with the Firm’s obligations under the MSA. The Firm’s business model is not based on investments in companies with a view to actively intervening in their management.

As a result, the Firm considers its overall modern slavery risk is very low.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 in respect of the financial year ended 31 December 2018.

Chenavari AIFMD Complaints Policy

Chenavari Investment Managers (Luxembourg) S.a r.l is committed at all levels to addressing and resolving complaints in a fair and efficient manner.
Please click here to access the AIFMD Complaints Policy, as set out in accordance with Regulation 16-07.

Chenavari Complaints Policy

Chenavari Credit Partners LLP is committed at all levels to addressing and resolving complaints in a fair and efficient manner.
Please click here to access the Complaints Policy, as required by the UK Financial Conduct Authority DISP 1.

RTS28 Best Execution Report

The recast MIFID and Regulation (together, “MiFID2”), and Regulatory Technical Standard 28 (“RTS 28”) (Delegated Regulation (EU) 2017/576), as implemented in the UK, requires Chenavari Credit Partners LLP to publish on its website on an annual basis:

a list of the firm’s top 5 execution venues (including brokers) in terms of trading volumes for all executed client orders per class of financial instruments;
a list of the firm’s top 5 execution venues (including brokers) in terms of trading volumes for all executed client orders in securities financing transactions per class of financial instruments; and
for each class of financial instrument, a summary of the analysis and conclusions the firm draws from monitoring the quality of execution obtained on execution venues (including brokers) where Chenavari executed all client orders in the previous year.

Please find the Chenavari Credit Partners LLP 2020 RTS28 Report here.

Please find the Chenavari Credit Partners LLP 2019 RTS28 Report here.

Shareholder Rights Disclosure

Chenavari Credit Partners LLP is currently considering whether it will adopt an engagement policy pursuant to Article 3g of the amended EU Shareholder Rights Directive (Directive 2007/36/EC). When that decision has been made, this webpage will be updated accordingly.

Disclaimer

All persons using the www.chenavari.com (“Chenavari Website”) expressly agree to the foregoing disclaimer as a pre-condition to using the Chenavari Website for any purpose whatsoever. The Chenavari Website gathers information about Chenavari Financial Group and Chenavari Credit Partners LLP (the “Chenavari Companies”). The Chenavari Website has been provided for information purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to on this website. This website is not for retail investors and is directed only at investment professionals as defined in Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 or qualified investors within the meaning of Article 2(1)(e) of the Prospectus Directive (“Qualified Investors”). For the purposes of this provision, the expression “Prospectus Directive” means Directive 2003/71/EC (as amended by Directive 2010/73/EU).

The Chenavari Companies may change these conditions, at any time, which will be posted accordingly on the Chenavari Website. Your access to the Chenavari Website is governed by the relevant conditions in place at the time of browsing. To the maximum extent permitted by law, the Chenavari Companies disclaim all liability to you arising out of your use of the Chenavari Website. All disputes relating to these conditions or your use of the Chenavari Website are governed by the laws of England and Wales. The Chenavari Website is intended solely for the use of eligible counterparties or professional clients, for the purposes of the UK Financial Conduct Authority’s rules, who can afford the risks inherent in the instruments offered or managed by Chenavari Companies. All persons subscribing for an investment must be able to bear the risks involved and must meet the suitability requirements relating to such investments.

The Chenavari Website is not intended as, and is not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised to any person to whom it is unlawful to make such a solicitation or offer. None of the securities referred to in the website have been or will be registered under the US Securities Act of 1933 or the securities laws of any other jurisdiction, and may be offered and sold in the United States and elsewhere only in accordance with an applicable exemption from the registration requirements thereof. The funds have not been registered under the US Investment Company Act of 1940. Furthermore, Subject to certain exceptions, the securities referred to herein and on the pages that follow may not be offered, sold, resold, taken up, exercised, renounced, transferred, delivered or distributed, directly or indirectly, in Australia, Canada, or Japan or to any resident or citizen of Australia, Canada, or Japan. The offer and sale of the securities referred to herein and on the pages that follow have not been and will not be registered under the applicable securities laws of Australia, Canada, or Japan. or any other jurisdiction which would be prohibited by applicable law.

The following web pages contain information on foreign collective investment schemes which have not been approved by the Swiss Financial Market Supervisory Authority (FINMA) for distribution in or from Switzerland to non-qualified investors in accordance with Article 119 et seq of the Federal Act on Collective Investment Schemes of 23 June 2006 (“CISA”). The information contained in the following pages is only directed to “qualified investors” within the meaning of Article 10 CISA with domicile/registered seat in Switzerland.

By clicking on the “ACCEPT” button, you certify that you are a qualified investor, an institutional investor or a financial professional in your own Jurisdiction and that nothing prevents you from getting access to the information available on this website.

Whilst the information contained on the Chenavari Website has been given in good faith and every effort has been made to ensure its accuracy. The information and any opinions contained herein have been obtained from or are based on sources which are believed to be reliable. The Chenavari Companies expressly disclaim making any express or implied warranties with respect to the fitness of the information contained herein for any particular usage, its merchantability or its application or purpose. The Chenavari Website is not intended to constitute, and should not be construed as investment advice. Prior to making any investment or hiring any investment manager you should consult with a professional financial advisor, legal and tax advisor to assist in due diligence as may be appropriate and determining the appropriateness of the risk associated with a particular investment.

Furthermore, to the extent permitted by law, neither the funds managed by Chenavari Credit Partners LLP nor any of their agents, service providers or professional advisers assumes any liability or responsibility nor owes any duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in the Chenavari Website or for any decision based on it. In particular, neither of the Chenavari Companies shall be liable for any direct or indirect loss or damage to you, any loss of profits, loss of business, revenue, data, goodwill or anticipated servicing, or any consequential loss or damage.

Any of the Chenavari Companies’ instruments should review the prospectus of the funds and strategies before making an investment decision and should rely only on the information contained in the instrument offering documentation. Past performance is not necessarily indicative of future results. The actual performance realised by any given investor will depend on, amongst other things, the Fund invested into, the class of shares/interests subscribed for the period during which such shares/interests are held and in what currency such shares/interests are held. Prospective investors should take appropriate advice, on the legal requirements, possible tax consequences, foreign exchange restrictions or exchange control requirements that they may encounter under the laws of the countries of their citizenship, residence or domicile and that may be relevant to the subscription, purchase, holding, exchange, redemption or disposal of any investments. Chenavari Companies reserve the right to terminate, at any time, any User’s account without giving notice or a reason for such termination to the User.

Users of the Chenavari Website may view, download and print information and materials for its personal and internal business use provided that all hard copies contain all copyright and other applicable notices; all content on the Chenavari Website is protected by copyright. All Users may not reproduce, modify, copy, alter in any way, distribute, sell, resell, transmit, transfer, license, assign or publish any information obtained from the Chenavari Website. Users shall not use this site at any time for any purpose that is unlawful or prohibited and shall comply with any applicable local, state, national or international laws or regulations when using the Chenavari Website. We are concerned about the privacy of any personal information you may provide to us through this Website.

Chenavari Companies, and the logos and marks included on the Chenavari Website that identify the Chenavari Companies’ services and products are proprietary materials. The use of such terms and logos and marks without the express written consent of Chenavari Companies is strictly prohibited. Copyright in the pages and in the screens of the Chenavari Website, and in the information and material therein, is proprietary material owned by Chenavari Companies unless otherwise indicated. The unauthorized use of any material on the Chenavari Website may violate numerous statutes, regulations and laws, including, but not limited to, copyright, trademark, trade secret or patent laws.

If any provision in this Disclaimer Agreement is held to be invalid or unenforceable, then the remaining provisions shall continue in full force and effect.

Telephone communications or conversations between an Investor and the Investment Manager, the AIFM or the Administrator will be recorded to the extent that that they result or may result in activities in financial instruments (as defined in MIFID II).