Provision of Services Document

The following information is given in accordance with the Provision of Services Regulations 2009.

General

Devonshire Corporate Finance Limited is a limited company registered in England with registration number 01516845 whose registered office is situated at Devonshire House, 60 Goswell Road, London, England EC1M 7AD. Devonshire Corporate Finance Limited’s VAT number is 245 7623 49.

A letter of engagement detailing our terms and conditions will be provided prior to the commencement of any engagement we undertake.

FCA Regulated Activities

Devonshire Corporate Finance Limited is authorised and regulated by the Financial Conduct Authority (FCA) for investment business under the Financial Services and Markets Act 2000; details of our status can be viewed here  under firm reference number 198042. The FCA’s rules and code of conduct can be accessed at www.fca.org.uk.

UK Stewardship Code Disclosure Statement – July 2013

Rule 2.2.3 of the Conduct of Business Sourcebook of the FCA Handbook requires Devonshire Corporate Finance Limited to make a public disclosure in relation to the nature of our commitment to the UK Stewardship Code (Code) published by the Financial Reporting Council (FRC).

The Code aims to enhance the quality of engagement between institutional investors and UK companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with UK investee companies and is to be applied by firms on a “comply or explain” basis.

The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

(i) Publicly disclose their policy on how they will discharge their stewardship responsibilities;
(ii) Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
(iii) Monitor their investee companies;
(iv) Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
(v) Be willing to act collectively with other investors where appropriate;
(vi) Have a clear policy on voting and disclosure of voting activity; and
(vii) Report periodically on their stewardship and voting activities.

Devonshire Corporate Finance Limited does not comply with the Code as it does not currently invest in listed companies in the UK. Should this change, we will review our commitment to the Code at that time and make appropriate disclosure.

Data protection

Devonshire Corporate Finance Limited is registered with the Information Commissioner as a data controller; details about our registration can be viewed here  under registration number Z8284139.

Quality of Service

If you are not satisfied with any contractual services received, or if you have any suggestions for improvement of our services, please contact either the engagement director or Steven Neal, who is the director responsible for quality and who is located at our registered office. We will look carefully and promptly at any issues raised and if we do not answer it to your satisfaction you may of course take the matter up with the FCA. You may also contact the Information Commissioner if your complaint relates to the way in which we have handled your personal data.

Professional Indemnity Insurance

Our professional indemnity insurer is Markel Insurance Company Ltd, The Markel Building, 49 Leadenhall Street, London EC3A 2EA. The territorial coverage is worldwide.

Employer’s and public liability claims

For employer’s and public liability claims, our insurer’s details are: Allianz, 60 Saint Helen’s Place, City of London, EC3V, UK. The policy number is SZ14861295.