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 firstname.lastname@example.org.
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.
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.
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 Chenavari Credit Partners LLP 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.