Baron & Grant Investment Management Limited (“B&G”) is authorised and regulated by the Financial Conduct Authority (“FCA”) under Firm Reference Number 930300. You can verify these details on the Financial Services Register.

The information contained within our website is subject to the UK regulatory regime and is therefore targeted at customers in the UK.

Treating Customers Fairly

Treating our clients fairly is at the heart of our business. We always aim to put our clients’ interests above our own and we have built the business from the ground up with this aim.

Our Complaints Procedure

We pride ourselves on our high levels of personal service and we hope that you will be delighted by the service you receive from B&G. Please see our Complaints Procedure to explain how we handle any complaints we receive. We give priority to resolving any matter as quickly as possible and that your concerns are handled fairly and within reasonable timescales. We value all feedback in helping us to improve our service to clients. Complaints should be addressed to:

Christopher Grant
Baron & Grant Investment Management Limited
66 Lincoln’s Inn Fields
London
WC2A 3LH
Email: chris.grant@baronandgrant.com
Telephone: +44 (0)1283 387070

If we are unable to resolve your complaint, you may be able to refer the matter to the Financial Ombudsman Service. The Financial Ombudsman Service is free to use and you can read more about the service they provide on The Financial Ombudsman website.

Client Identification

We have responsibilities to verify the identity and permanent address of our clients under UK anti-money laundering legislation. We use electronic verification systems, such as SmartSearch to establish our clients’ identity. SmartSearch is an award-winning anti-money laundering solution which uses information obtained from Credit Reference agencies and other trusted sources. For more information, please contact us or visit their website.

Conflicts of Interest

B&G is required by the FCA to maintain a Conflicts of Interest Policy identifying the circumstances that constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more clients and specifying the procedures that we follow and measures that we adopt in order to manage such conflicts. A copy of our Conflicts of Interest Policy can be found here.

Best Execution

It is in the interests of our clients and B&G that we obtain the best possible result when placing orders with other firms for the execution of client orders or when transmitting orders on behalf of clients. We are required under the rules of the FCA to take all reasonable steps to provide Best Execution when carrying out transactions and have published our Best Execution Policy that we have adopted to achieve that objective. Each year we are required to publish a report on the third parties used to execute client orders.

Financial Resource Requirements (Pillar 3 Disclosure)

B&G publishes our Pillar 3 Disclosure Statement, in accordance with the UK FCA Prudential Sourcebook for Banks, Building Societies and Investment Firms (applicable to BIPRU firms prior to 1 January 2022).

Remuneration Code Statement

B&G is subject to the MIFIDPRU Remuneration Code provisions for SNI firms. A copy of our Remuneration Policy can be found here.

Stewardship Code Statement

B&G has a duty to act in the best long-term interests of its clients and is committed to achieving this. The UK Stewardship Code is overseen and published by the Financial Reporting Council, an independent regulator overseeing financial reporting, accounting and auditing and corporate governance. The Code sets the benchmark for institutional investors to meet ownership obligations in respect of UK companies.

The Code is addressed in the first instance to firms who manage assets on behalf of institutional shareholders such as pension funds, insurance companies, investment trusts and other collective investment vehicles. Although B&G primarily manages the assets of retail investors, as required by the rules of the FCA, this policy statement focuses instead on our professional clients where, under our terms of engagement, B&G is able to exercise voting rights on investments held on such professional clients’ behalf. For such clients, as appropriate, B&G may seek to engage and vote on any issue affecting the long-term value of a company in which we have invested on our clients’ behalf.

As a financial services organisation, our primary responsibilities are to ensure suitability and maximise investment returns to our clients in accordance with our contractual relationships, and in our view this is always best achieved through the consistent identification of quality investment opportunities for our clients’ funds, and to dispose of investment holdings where we are dissatisfied with that investment’s prospects for income or growth. In this way, we see stewardship of investee companies as an integral part of the wider investment process.

B&G recognises that the maximisation of client investment returns may sometimes require a greater level of engagement with investee companies, including entering into an active dialogue with investee company management, and the resources used for each such engagement will be managed according to the circumstances of each case. Where the holding controlled and voted by B&G is a small fraction of an investee company’s capital, for example, there will be proportionately less resource applied to engagement, if only to recognise that shareholders with a small fraction of a company’s share capital are less likely to have a material influence.

B&G has frequent opportunities to meet with the management of actual and prospective investee companies. Monitoring occurs around company financial reporting, in conjunction with news and announcements and when, for whatever reason, B&G might be conducting research into investment ideas. Where a company does not comply with the spirit of the UK Corporate Governance Code, in our opinion, we will consider its explanation and react accordingly.

Where it is identified that a greater level of engagement may be beneficial to our clients’ interests, we will vote at shareholders’ meetings as we deem appropriate and at our absolute discretion. Although we generally look to support management of investee companies, we may abstain or vote against resolutions where proposals are deemed inconsistent with the interests of shareholders.

Where we deem it appropriate and effective, we will seek to engage collectively with other investors, and to escalate our activities.

Our policy regarding conflicts of interest is set out in our Conflicts of Interest Policy, please find the link to our policy under the Conflicts of Interest section of this page.

It is not the current policy of B&G to report routinely to clients how we have discharged our responsibilities under the Code. Nor do we publish voting records, whether on this website or elsewhere, as we do not consider that making these records public would always serve our clients’ interests; were we to do so it would be at our discretion and after a suitably lengthy delay to ensure that the publication of voting would not influence the outcome of discussions. We are happy to disclose and report such matters in confidence directly to clients on request.

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