BennBridge is a multi-boutique investment firm which strategically partners with specialist fund managers.
BennBridge Ltd (‘BennBridge’) is a multi-boutique investment firm which strategically partners with specialist fund managers. BennBridge provides a structure that gives our boutiques the same quality support offered by large institutional firms, but enables them to operate in a more personalised and entrepreneurial environment. As a minority equity partner to each boutique, BennBridge offers access to a global distribution network and a wide range of high quality investors, whilst also providing a holistic range of non-investment functions, enabling each boutique to focus solely on their own investment performance.
As a 100% owned subsidiary of the Bennelong Funds Management Group, a successful Australian based multi-boutique investment firm established in 2006 and currently managing approximately $8 billion USD/£6 billion GBP, BennBridge benefits from a powerful global distribution footprint and the ability to drive the scalability of boutiques’ success.
Bennelong and BennBridge are wholly owned by the Bangarra Group, a privately owned family office with a philanthropic agenda, demonstrated by their ongoing support of and alignment with the Group’s charitable arm, the Bennelong Foundation.
Managers – Why Partner with BennBridge?
We’re committed to sourcing and developing world-class boutiques.
The structure we provide gives our boutiques the same quality support offered by large institutional firms, but enables them to operate in a more personalised and entrepreneurial environment.
We offer a holistic range of services to each boutique, allowing them to focus on aiming to deliver strong investment performance.
We strive to develop long-term strategic partnerships where our culture and interests are closely aligned.
Co-locating our boutiques into our office gives them access to support services when they need it, and also allows them to mix with other high-calibre investment professionals in a non-competitive, collaborative environment within a robust control framework.
Operations & Compliance
- Compliance and risk management
- Investment operations
- Introduction and negotiation with third party institutions (i.e. Brokers, Fund Administration, Legal)
- IT infrastructure
- Human resources
- Company secretarial
Long-Term Strategic Partner
- Provision of working capital for at least three years
- Access to a network of investors
- Business planning, budgeting, strategic development and succession planning
- Access to BennBridge’s regulatory licence
- Meaningful equity participation
Marketing and Distribution
- Access to UK, European and US investors
- Sales strategy and implementation
- Brand development and management
- Event management
- Production and distribution of collateral
- Website management
- PR and social media
- Investor reporting
Investors – Why Invest in BennBridge Boutiques?
By managing all of the business and non-investment functions centrally we believe we are in a strong position to ensure each of our boutiques benefits from our top quality and robust investment infrastructure, operations and marketing.
We look to partner with high-alpha managers, with concentrated portfolios and high conviction positions.
We have a minority equity stake in each boutique and remain committed long-term partners.
We foster our boutiques’ entrepreneurial spirit while ensuring an institutional quality business.
By partnering with specialist boutiques we offer access to a wide range of investment opportunities across asset classes.
We work with a diverse investor base including endowments, pension funds, asset managers, fund of funds, multi-manager, private banks, family offices and financial intermediaries.
Bennelong has successfully partnered with eight managers across a range of investment strategies.
Since our launch in 2017, BennBridge has partnered with two boutique fund management teams.
Our first boutique, Tellworth Investments launched in October 2017. Led by Paul Marriage and John Warren, with BennBridge appointed as the investment manager, the strategy is focused on UK equities with a small and mid-cap bias and has US$599 million/GBP£462 million in AUM as at 31 August 2018.
Our second boutique, Pembroke launched in April 2018. Led by Sanjiv Bhatia, with BennBridge appointed as the investment manager, the strategy is focused on global emerging markets long/short equities.
Chief Executive Officer
Bennelong Funds Management
Craig is a highly regarded financial services executive with extensive experience in Australian and international markets. Along with Greg, Craig sits on the governing body at BennBridge. Craig joined Bennelong from Federated Investors Asia Pacific where he was CEO. Prior to that, he was CEO at Portfolio Partners which later became Aviva Investors Asia Pacific, where he was responsible for establishing and developing licensed asset management businesses in Australia, Singapore and China, and expanding Aviva’s presence in Asia and the Middle East.
Under Craig’s leadership, he built the strong-performing, award-winning Aviva Investors brand in the Australian market, opened distribution offices in Taiwan and the Middle East, and created an enviable corporate culture.
Chief Operating Officer
Greg joined BennBridge in November 2016 to establish BennBridge’s London office. He has 19 years’ experience in financial services, the last 12 of which as a hedge fund Chief Operating Officer (COO). Greg is responsible for managing all non-investment activities at BennBridge including Operations, Risk, Compliance, Finance, IT, HR & IR.
Before joining BennBridge, Greg was Managing Director of Visium Asset UK LLP, the London office of Visium Asset Management, which managed assets of $8bn at its peak. Prior to Visium, Greg was COO at Gruss Capital Management LLP and Copenhagen Capital LLP and Deputy COO of Bailey Coates Asset Management. Greg started his career in Ernst & Young’s Audit division, where he qualified as an accountant.
Greg has a Bachelor of Science from University of Wales, Cardiff, in Banking & Finance.
Head of Compliance
Suzanne joined BennBridge in December 2016. Suzanne is an experienced financial services professional who has built and developed robust compliance frameworks previously and has a broad understanding of automated system solutions available to hedge funds. Before joining BennBridge, Suzanne ran the UK compliance monitoring programme at Visium Asset Management.
Prior to Visium, Suzanne spent two years at BAML as the LIBOR Compliance Officer and the Conflicts of Interest Officer for Europe. Prior to BAML, Suzanne worked at both COMAC Capital LLP and Balyasny Asset Management.
Suzanne has a Bachelor of Arts from University College London in Western Asiatic Archaeology.
Head of Operations
Ben joined BennBridge in May 2017 to help build out the Operations infrastructure. Ben has 18 years’ experience in financial services, all of which have been within Operations. Ben is responsible for managing all aspects of operational support for BennBridge including Trade Support, Middle Office, NAV oversight, P&L reporting and third party service provider relationships. Before joining BennBridge, Ben was Head of Operations at London based equity long/short alternatives specialist MSK Capital.
Prior to MSK, Ben held Operations roles at Ivaldi Capital, BlueBay Asset Management and JPMorgan.
Head of Business Development
Ryan joined Bennelong Funds Management in June 2015 and relocated back to London in late 2016, as part of the setup of BennBridge. Ryan has 11 years’ experience in financial services. His role encompasses building and maintaining the Firm’s client relationships across Europe, on behalf of BennBridge and Bennelong’s boutiques. He is also actively involved in BennBridge’s manager sourcing and evaluation process.
Before joining Bennelong as Head of Institutional Sales, Ryan worked as a Product Manager at Schroders PLC. Other roles included European Sales at Cazenove Capital Management, Barclays Wealth, Coutts & Co & Merchant Investors (now Sanlam).
Ryan has a Bachelor of Arts from Liverpool University in Modern History & Politics.
Director of Marketing & Investor Relations
Fay joined BennBridge in September 2017 and is responsible for Marketing and Investor Relations. Fay has 11 years’ experience in financial services, most recently as an Investment Director at Odey Asset Management, where she was responsible for asset raising and developing the firm’s intermediary relationships across the UK, Middle East and Asia. Prior to Odey, Fay spent 4 years as an Investment Specialist at Man Group/GLG Partners, where she focused on the equity hedge fund and long-only strategies, working closely with institutional and retail sales in the UK and Asia. Fay began her financial career in investment banking at Lehman Brothers, where she spent 2 years in the M&A division working up until the firm’s bankruptcy. Fay completed a Short Service (Gap Year) Commission in the British Army, as part of the Royal Artillery.
Fay graduated from the University of Oxford with a Masters (Hons) in Politics, Philosophy and Economics.
Director of Business Development
Helme joined BennBridge in September 2018 and is responsible for building and maintaining client relationships across the UK. Helme has 6 years’ experience in financial services, most recently at JO Hambro Capital Management, where she was responsible for asset raising and developing the firm’s intermediary relationships in London. Prior to JO Hambro, Helme spent 3 years as an Investment Director at BNY Mellon Investment Management, distributing funds on behalf of 13 partnership boutiques with a focus on UK financial institutions and private client wealth managers. Other roles have included UK sales at Blackrock (iShares) and Delta One risk at Credit Suisse.
Helme graduated from the University of Bristol with a degree in Aeronautical Engineering.
29 November 2017 - BennBridge
Bennelong to sponsor up-and-coming cycling team
Bennelong Funds Management is the new naming rights sponsor of Australia’s strongest domestic cycling team, to be known as Bennelong SwissWellness Cycling Team p/b Cervelo... read more
It is the top-ranked team in Australia’s National Road Series and has launched top-tier careers including Richie Porte.
Craig Bingham, CEO of Bennelong Funds Management, said the partnership was a great fit for the company, with the cycling team’s philosophy mirroring Bennelong’s.
“Our approach is to nurture and support the next big thing in investment management, and we have strong partnerships with a number of quality boutique asset managers.
“Similarly, the Bennelong SwissWellness Cycling Team focuses on identifying and developing talent, and we are looking forward to building a successful partnership together.”
Steve Price, team manager of the cycling team, said: “Bennelong’s support will be invaluable to the team as we prepare for the upcoming cycling season, starting with a series of races in Australia in early 2018. We look forward to a productive and successful partnership.
“Having a non-industry partner increases our reach and adds value to our whole sponsor group, and we are confident that with their help the team will step up another level over the coming year.”
The team recently won its eighth National Road Series crown in a row, and has also signed four new riders. They will be competing in the major Australian races at the start of 2018: the National Championships in Victoria; the Tour Down Under in South Australia; and the Herald Sun Tour in Victoria.
Read more about the team and Bennelong's sponsorship here.
9 October 2017 - BennBridge
BennBridge partners with emerging markets specialist Pembroke for second boutique launch
BennBridge, the multi-boutique investment firm which launched into the UK last year, has launched its second boutique after partnering with emerging markets manager Pembroke... read more
Sanjiv Bhatia, Founder of Pembroke is a specialist in emerging markets (EM) equities, having managed the EM portfolios within the Harvard Endowment from 2013 to 2017.
Bhatia and the team generated a high quality track record* during the period, generating alpha by identifying high conviction ideas derived from top-down themes and bottom-up fundamental analysis, with a low net exposure.
Bhatia has spent the last quarter of a century investing in Asian and Emerging Markets. He spent 12 years at Goldman Sachs where he was Head of Asian Equity Trading in Hong Kong, before then building the Asian business at Deephaven Capital Management and Isometric Capital. He joined the Harvard Endowment in 2012 as a Managing Director.
Pembroke will be launching as a BennBridge boutique in Q1 2018, offering a range of investors access to Bhatia and his team’s expertise.
Ryan Durance, Head of Business Development at BennBridge, said “We believe it is the optimal time in the emerging markets equity cycle to launch a specialist emerging market boutique. We continue to see robust client demand globally and expect the asset class will continue to provide a consistent source of alpha for skilled managers over the long-term. Sanjiv stood out because of his extensive experience investing in Asian and emerging markets equities and his proven and long track record. ”
Sanjiv Bhatia, Chief Investment Officer at Pembroke, said “Having managed a successful emerging markets long/short strategy since 2005, I am pleased to now launch my business in partnership with BennBridge and pursue this strategy for the benefit of a greater audience. We aim to continue to capture the alpha opportunity in global emerging markets equities and hope to continue delivering strong uncorrelated returns to clients. We look forward to opening the fund up to a wide range of external investors in Q1 2018 as a BennBridge boutique.”
The launch of Pembroke follows the recent launch of Tellworth, a BennBridge boutique led by Paul Marriage and John Warren, with a focus on UK small and mid-cap equities, which started trading earlier this month with £385m.
2 October 2017 - Tellworth Investments
BennBridge launches first boutique partner Tellworth Investments with £385m
Multi-boutique investment firm BennBridge Ltd (“BennBridge”) is pleased to announce the launch of its first long-term strategic partner, boutique firm Tellworth Investments (‘Tellworth’), which will be led by experienced investment duo Paul Marriage and John Warren... read more
As part of the partnership with Tellworth, BennBridge has been appointed investment manager of both the Schroders’ SARFCO UK Dynamic Absolute Return Fund and the Schroders’ SAS UK Dynamic Absolute Return Fund, managing £385m of assets at launch.
Commenting on the launch, Paul Marriage, Co-Founder of Tellworth, said “Having managed these funds since 2005 at both Cazenove and Schroders, we are delighted to continue running the strategy and to continue our relationship with Schroders. We remain fully committed to our clients and look forward to working with them, Schroders and the team at BennBridge.”
The award-winning UK equity long-short strategy has a long track record with an annualised return of +10.1% since launch*. As specialists in UK small and mid-cap stock picking, the Tellworth team will aim to continue to capture the alpha opportunity in small cap markets and strive deliver superior returns to their clients.
As part of the launch, Tellworth has expanded its existing team, with three new members of staff joining to work alongside Paul Marriage and John Warren.
Stephen Nash joins as Head of Trading with over 20 years’ experience in equity trading for investment firms and expertise in trading UK small to mid-cap stocks. Seb Jory will join as Head of Data Driven Strategies, while James Gerlis joins as an Equity Analyst focusing on researching stock specific investment opportunities. Seb was previously at Liberum Capital and brings his macro-economic and quantitative expertise to the team, while James has seven years’ investment experience at Blackrock where he specialised in UK and Emerging Market equities.
John Warren, Co-Founder of Tellworth said, “This is an exciting time for Tellworth. We aim to continue delivering strong investment returns for our clients through BennBridge and in order to do that it is important we have a first class investment team”.
“We have worked with Stephen since the outset in 2005. We are confident his experience and expertise will continue to bring great benefits to the team. Meanwhile, Seb and James will add an additional dimension to our investment process giving us potential to launch further funds in the future and widen our product offering through BennBridge.”
Commenting on the launch of Tellworth, Greg Thomas, Chief Operating Officer at BennBridge said, “We are excited to launch our first boutique with managers of such high calibre. Our strategic long-term partnerships are key to our business and we are confident Paul, John and the team will build on their success at Schroders and continue to grow”.
*Refers to Schroders UK Dynamic Absolute Return strategy which launched in 2005.
1 June 2017 - Tellworth Investments
BennBridge to be appointed investment manager on Schroders’ UK Dynamic Absolute Return strategy
BennBridge today announces it has agreed in principle with Schroders to become investment manager of both SARFCO* UK Dynamic Absolute Return Fund and SAS** UK Dynamic Absolute Return Fund, subject to regulatory approval and due diligence... read more
Fund managers Paul Marriage and John Warren would transition to BennBridge in the fourth quarter of 2017 where they would continue to manage both strategies. The investment objectives of the funds would not change as a result.
Branded as Tellworth Investments LLP, Paul Marriage and John Warren would cease to be employees of Schroders at that time.
It is anticipated that SAS UK Dynamic Absolute Return Fund will migrate onto the Schroder GAIA platform in the future. The Schroder GAIA platform consists of alternatives funds whereby Schroders acts as distributor with a third party as investment manager.
For further information please read the media release.
14 May 2017 - BennBridge
BennBridge opens London office
Newly established BennBridge has opened its London office at Jermyn Street. It will provide operational and infrastructure support for boutique funds management teams and distribute their funds across global markets... read more
BennBridge was launched in December last year and is led by Greg Thomas as Chief Operating Officer, supported by Ryan Durance (Head of Business Development), Robert Gough (Director of Business Development), Ben Battye (Head of Operations), and Suzanne Porter (Senior Compliance Manager).
BennBridge is part of Bennelong Funds Management (Bennelong), an Australian-based business which has almost AUD$8 billion in funds under management and eight boutique funds management partners.
Greg said: “Our business model is to provide a holistic range of services to our boutique partners, allowing them to focus on what they do best – managing clients’ assets.
“This model has proven a successful one in Australia, where Bennelong has been operating since 2006.
“Beyond the functional support we provide, the real value of our offering is the entrepreneurial culture which nurtures innovation. This, coupled with BennBridge’s backing and business support, is what helps drive the scalability of our asset managers’ success,” said Greg.
Best Execution Disclosures
BennBridge Ltd - Top 5 Execution Venues Report for 2017
|Class of Instrument
||Equities – Cash
|< 1 Average trade per business day
||Volume Traded (%)
||Proportion of Orders Executed
||Directed Trade (% Volume)
|ITG POSIT ALGO DESK
|Class of Instrument
||Equities – Derivatives
|< 1 Average trade per business day
||Volume Traded (%)
||Proportion of Orders Executed
||Directed Trade (% Volume)
|ITG POSIT ALGO DESK
|UBS AG HT DESK
|BANK OF AMERICA MERRILL LYNCH ALGO DESK
|BANK OF AMERICA MERRILL LYNCH HT DESK
Best Execution Qualitative Information
|A summary of the analysis and conclusions the Firm draws from its detailed
monitoring of the quality of execution obtained on the execution venues where it
executed all client orders in the previous year
||As part of BennBridge Ltd’s (“BennBridge” or the “Firm”) analysis of best execution in relation to
equities, Transaction Cost Analysis (“TCA”) reports were obtained from a third party vendor. The
Firm analysed the trades during the relevant period to determine whether any of the trades were
greater than 100 bps from the VWAP. The reports cover slippage analysis as well as details of the
Firm’s percentage of average daily volume traded.
The monitoring completed confirmed that best execution was obtained consistently on the
approved execution venues throughout the period.
|An explanation of the relative importance the Firm gave to the execution factors
of price, costs, speed, likelihood of execution or any other consideration
including qualitative factors when assessing the quality of execution
||BennBridge’s delivery of best execution is a key element in its commitment to act in the best
interests of its clients, as well as being a regulatory requirement. The Firm prioritises ensuring that
all sufficient steps are taken to obtain the best possible result for its clients when it executes, places
or transmits orders on their behalf. This means taking into account the ‘execution factors’ such as
price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration
relevant to the execution of the order.
|A description of any close links, conflicts of interests, and common ownerships
with respect to any execution venues used to execute orders
||The Firm does not have any close links, conflicts of interests or common ownerships with respect
to the execution venues it uses to execute orders.
|A description of any specific arrangements with any execution venues regarding
payments made or received, discounts, rebates or non-monetary benefits
||BennBridge has not entered into any arrangements with its execution venues regarding payments
made or received, discounts or non-monetary benefits that would compromise its ability to meet its
obligations in regards to best execution, conflicts of interest or inducements.
When selecting execution venues for inclusion in the execution policy, the Firm does not take into
account the fees and commissions that it will charge its clients, but focuses on the potential of the
venues to enable the Firm to obtain on a consistent basis the best possible result for the execution
of its client orders. However, the Firm does take into account the effect of its own fees and
commission when choosing a venue for the execution of a particular client order.
|An explanation of the factors that led to a change in the list of execution venues
listed in the firm’s execution policy, if such a change occurred
||Execution venues were added as appropriate, following the necessary onboarding due diligence.
Such changes occur due to a number of factors, including the scope of financial instruments traded,
consideration of commercial terms, determination of performance and providing additional venues
through which to execute.
|An explanation of how order execution differs according to client categorisation,
where the Firm treats categories of clients differently and where it may affect the
order execution arrangements
||While BennBridge does take the characteristics of its clients into account when judging the relative
importance of the execution factors, the Firm’s clients are exclusively professional clients and so
are treated with a consistent approach.
|An explanation of whether other criteria were given precedence over immediate
price and cost when executing retail client orders and how these other criteria
were instrumental in delivering the best possible result in terms of the total
consideration to the client
||The Firm does not execute retail client orders.
|An explanation of how the Firm has used any data or tools relating to the quality
of execution, including any data published under Commission Delegated
Regulation (EU) 2017/575
||BennBridge compares and analyses relevant data to obtain best execution for a client, including
execution quality data. The Firm transmits or places orders with other entities for execution and
when the order relates to OTC products including bespoke products, checks the fairness of the
price proposed to the client, by gathering market data used in the estimation of the price of such
product and, where possible, by comparing with similar or comparable products.
|Where applicable, an explanation of how the investment firm has used output of
a consolidated tape provider established under Article 65 of Directive 2014/65/EU.
||This is not currently applicable.
With effect from 25 May 2018, the EU General Data Protection Regulation (Regulation (EU) 2016/679)
(together with applicable implementing laws, (“GDPR”) will apply, to the extent relevant, to the
processing of personal data by BennBridge Ltd (“BennBridge”) in the course of their businesses, and
certain other persons. This notice sets out information relating to those activities.
BennBridge is a controller of personal data for the purposes of the GDPR and will, in the course of its
business, process personal data. Information regarding such processing is set out herein.
Any person seeking information with respect to control or processing of personal data by BennBridge
or seeking to exercise any rights afforded to them under GDPR should contact BennBridge (FAO Head
of Compliance) at email@example.com.
Under GDPR, any person wishing to is entitled to make a complaint with respect to BennBridge’s control
or processing of personal data directly to the relevant supervisory authority for data protection issues.
In the UK this is the Information Commissioner’s Office (“ICO”). Contact details for the ICO may be
found at www.ico.org.uk.
The policies and procedures adopted by BennBridge with respect to the control or processing of
personal data may be amended from time to time. Similarly, the purposes for which BennBridge may
control or process personal data may change from time to time. If any changes would require a material
amendment to the information set out herein, details of such changes will be made available in the
current version of this document from time to time.
Summary of Personal Data
For the purposes of GDPR, personal data means any information about an individual from which that
person can be identified. In the course of its business, BennBridge may collect, use, store and transfer
personal information from individuals that are employees, directors, officers or other representatives or
agents of market counterparties, professional services and other service providers, trade associations,
public bodies and other entities or undertakings. Such personal data is typically limited in scope, and
includes, for example, the name and contact details of such individuals, as well as some technical data
(such as internet protocol addresses), usage data and information about marketing and communication
Collection of Personal Data
BennBridge may collect personal data through a range of means. These may include direct interactions
(where a person provides personal data to BennBridge through correspondence or other direct methods
of communication), through third-party service providers (for example, recruitment agents) or publicly
available sources (where BennBridge receives personal data through a publicly available source such
as a website or publicly-available registry).
Use of Personal Data
BennBridge will only process personal data in circumstances where it has established a lawful basis
under GDPR to do so. These circumstances include where the processing of the relevant data relates
to a legitimate interest of BennBridge, further described below. In such circumstances BennBridge will
have established that the processing is necessary for the relevant purpose, and not inconsistent with
the interests, rights or freedoms of a relevant data subject.
In accordance with the above, BennBridge has determined that the lawful bases for its processing of
personal data are the legitimate interests of BennBridge to undertake activities necessary and ancillary
to the carrying on of an investment management business, including where necessary for the purposes
of BennBridge carrying out its activities relating to any fund, vehicle or account in respect of which
BennBridge acts as manager, investment manager, sub-investment manager, investment adviser or
sub-investment adviser (the “Funds”), the administration of the Funds, the investment activities of the
Funds, otherwise in furtherance of any contract entered into with respect to the activities of the Funds,
to exercise and comply with the relevant Fund’s or BennBridge’s rights and obligations at law or under
regulation where such obligations are not set out under the laws of any member state of the European
Economic Area (“EEA”), to establish, exercise or defend legal claims and in order to protect and enforce
its (or another person’s) rights, property, or safety, or to assist others to do the same, and in order to
provide information about its services and any investment products it offers.
In addition, BennBridge may also control or process personal data where necessary to comply with
legal or regulatory obligations applicable to them under the laws of the European Union or any member
state of the EEA, or in order to give effect to a contract, or to take necessary pre-contractual steps with
a view to potentially entering into a contract (including in its capacity as an employer or a prospective
employer), to the extent applicable.
BennBridge may from time to time control or process personal data for the purposes of operating their
business, entering into contractual arrangements in the context of their investment management
business, including in respect of the Funds marketing, and advertising the Funds and/or other
investment vehicles and/or services related to BennBridge. Any person subject to GDPR who does not
wish their personal data to be processed for marketing purposes may opt out of such processing by
notifying the Head of Compliance of BennBridge at firstname.lastname@example.org.
BennBridge will only use personal data for the purposes that it has been collected for, unless it
reasonably considers that it needs to use it for another reason and that reason is compatible with the
original purpose of the control or processing. Any person requiring information with respect to any
additional purpose for which personal data may be controlled or processed may obtain such information
from the Head of Compliance of BennBridge at email@example.com. If BennBridge needs to
control or process personal data for an unrelated purpose, it will use its reasonable endeavours to notify
affected persons and to explain the basis on which it is permitted to undertake the same.
Disclosure of Personal Data
BennBridge may share personal data with certain third parties for the purposes set out above. The
relevant third parties with whom such personal data may be shared include entities appointed to provide
services to the Funds, BennBridge and their affiliates, and regulatory, legal and tax authorities. Further
details of the third parties with whom personal data may be shared are available on request from the
Head of Compliance of BennBridge at firstname.lastname@example.org. Wherever possible, personal data
will only be disclosed by BennBridge to a third party in circumstances where that third party has agreed
to respect the security of personal data and treat it in accordance with applicable law. BennBridge will
seek to ensure that third parties to whom any personal data may be disclosed will not use personal data
for their own purposes and only process personal data for specified purposes and otherwise in
accordance with the instructions of BennBridge and/or with the GDPR.
Transfer of Personal Data outside the European Economic Area
The activities of BennBridge are such that it may be necessary for personal data to be transferred and/or
processed outside the EEA.
In circumstances where BennBridge transfers personal data outside the EEA, it will seek to ensure a
similar degree of protection is afforded to it by ensuring that personal data is generally transferred only
to persons in countries outside the EEA in one of the following circumstances.
- To persons and undertakings in countries that have been deemed to provide an adequate level
of protection for personal data by the European Commission.
- To persons and undertakings to whom the transfer of such personal data is made pursuant to
a contract that is compliant with the model contracts for the transfer of personal data to third
countries from time to time approved by the European Commission.
- To persons and undertakings based in the United States if they are part of the EU-U.S. Privacy
Shield which requires them to provide similar protection to personal data shared between
Europe and the United States.
Further information on specific mechanisms utilised by BennBridge transferring personal data outside
the EEA and the countries to which such transfer may be made may be obtained from the Head of
Compliance of BennBridge at email@example.com upon reques.
BennBridge will retain personal data for as long as necessary to fulfil the purposes for which it has been
collected. This will include any period of retention required to satisfy any legal, regulatory, taxation,
accounting, regulatory or reporting requirement applicable to BennBridge.
In determining the appropriate retention period for any personal data, BennBridge will consider the
amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure
of the data, the purpose for which the relevant data is being processed, the extent to which the purposes
for which the relevant data is being processed can be achieved by other means and any applicable
legal requirements. Without prejudice to the generality of the forgoing, BennBridge have determined
that it will retain records for at least five years, in accordance with the rules, requirements and guidance
of the United Kingdom Financial Conduct Authority.
Details of retention periods applicable to personal data subject to GDPR are available upon request
from the Head of Compliance of BennBridge at firstname.lastname@example.org. In some circumstances,
a person may request that BennBridge delete any personal data retained by it. Further, in some
circumstances, BennBridge may anonymize personal data for research or statistical purposes, in which
case such information may be retained and utilised indefinitely without further notice.
Rights of Persons
Under GDPR, persons whose data is processed by BennBridge will have certain rights. These rights
include the right to access personal data, the right to require correction of personal data, the right to
require erasure of personal data in certain circumstances, the right to restrict processing of personal
data, and the right to require a transfer of personal data. In addition, if the processing of personal data
is based on a legitimate interest of BennBridge, a person will have the right to object to the processing
of that personal data.
Any person seeking to exercise any such right should contact the Head of Compliance of BennBridge
at email@example.com. In certain circumstances, BennBridge may charge reasonable fees if
any such request is clearly unfounded, repetitive or excessive.
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UK Stewardship Code
BennBridge Ltd (‘BennBridge’) is a multi-boutique investment firm which strategically partners with specialist investment teams which are then hosted within distinct boutiques under BennBridge. As such BennBridge will support certain non-UK investment strategies where it may not be appropriate to adhere to the UK Stewardship Code, however BennBridge recognises the emergence of Stewardship Codes in other jurisdictions and where appropriate will apply similar processes outlined within this disclosure to other such codes. BennBridge is the investment manager to the Funds and is regulated by the Financial Conduct Authority (“FCA”), Firm Reference Number 769109.
The UK Stewardship Code sets out, through 7 principles, the best practice in engaging with investee companies which the Financial Reporting Council (“FRC”) believes institutional investors, by which is meant asset owners and asset managers with equity holding in UK listed companies, should use as guidance.
Principle 1: Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
For strategies where it is relevant, the investment teams are actively engaged with company management. Consideration of a company’s ability to create, sustain and protect value is central to the investment process. Methods of engagement with a company vary, but typically involve at least one of the following:
- One-to-one meetings with company representatives
- Written correspondence;
- Phone calls;
- Discussions with company advisers and stakeholders; and
Principle 2: Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.
BennBridge recognises that conflicts of interest may arise in the normal course of business. Actual, perceived and potential conflicts are managed in accordance with our conflicts of interest policy. The policy is reviewed at least annually to ensure compliance with applicable regulatory and legal requirements.
Principle 3: Institutional investors should monitor their investee companies.
Where appropriate to strategy, the investment team(s) maintain(s) regular dialogue with companies to enable the investment team(s) to monitor the development of companies’ businesses. In addition, the investment team(s) may engage with other stakeholders in certain circumstances to enhance those views.
Principle 4: Institutional investors should establish clear guidelines on when and how they will escalate their stewardship activities.
The individual investment teams are responsible for considering each vote based on their understanding of the circumstances at the investee company. Escalation of our engagement activities will depend upon the investee company’s individual circumstances.
Principle 5: Institutional investors should be willing to act collectively with other investors where appropriate.
In considering a collaborative engagement, BennBridge takes into account potential conflicts of interest, concert party rules and our policy on insider information.
Principle 6: Institutional investors should have a clear policy on voting and disclosure of voting activity.
It is the policy of BennBridge to vote proxies in the interest of maximising value for its clients. Consideration will be given to both the short and long term implications of the proposal to be voted on when considering the optimal vote.
Principle 7: Institutional investors should report periodically on their stewardship and voting activities.
BennBridge maintains a database of voting activities. However, due to underlying client confidentiality and investment strategy reasons, it may not always be appropriate to disclose voting actions at a detailed level.
Pillar 3 Disclosure
The following Pillar 3 disclosures have been prepared by BennBridge in accordance with the requirements of BIPRU 11. Pillar 3 disclosures will be made available annually on the Firm’s website following publication of its Financial Statements.
Due to the nature, size and complexity of the Firm, BennBridge does not have a fully independent risk management function. The Governing Body is responsible for the management of risk within the Firm. The Governing Body meets periodically and receives input from the relevant business areas. BennBridge has clearly documented policies and procedures, which are designed to minimise risks to the Firm and all staff are required to confirm that they have read and understood them.
BennBridge has developed systems and controls to manage the risk that the Firm cannot meet its liabilities as they fall due. The Governing Body has allocated responsibilities to certain individuals to ensure the effective on-going monitoring and management of liquidity risk. The Head of Compliance has been allocated responsibility for the management of portfolio risk. The COO is responsible for business and capital funding risks and he is part of and reports within the Firm’s governing body on a frequent basis. The Governing Body formally reviews and signs off the liquidity assessment at least annually.
Operational risk is defined as the risk of loss due to system breakdowns, internal and operational control failures, staff fraud or misconduct, and catastrophes. Responsibility for the day to day performance of a significant portion of BennBridge’s functions have been outsourced under service level agreements, such as IT, accounting, and legal etc. Given the nature, scale and complexities of the Firm’s current business, the risk management structure is relatively simple. The Firm’s Governing Body manages the risks of the Firm through periodic receipt of management information on e.g. the Firm’s financial position, capital adequacy and compliance with the various rules and regulations to which the Firm is subject.
A considerable part of the Firm’s risk is the risk of a downturn in business performance by the underlying boutiques or an inability to attract additional boutiques to grow the business. The main concerns of the Firm relate to poor performance of the boutiques and their underlying fund / mandate and redemptions, but also their market conduct and investment processes.
Reputational risk is defined as the risk of damage to the Firm’s reputation that could lead to negative publicity, costly litigation, a decline in the customer base or the exit of key staff members and therefore
directly or indirectly leading to a loss of revenue. There is some overlap between reputational risks and business risks, since both can result in the loss of clients and a reduction in income.
Capital Resources Requirement
BennBridge, as CPMI firm, has an initial capital requirement of €125k and an ongoing capital resource requirement which comprises the greater of:
- The funds under management requirement (the sum of the Firm’s base own funds requirements of €125k plus 0.02% of the amount by which the Firm’s funds under management (related to the Fund) exceed €250m); and
- The own funds based on fixed overheads requirement; and
- The sum of market risk and credit risk (for non-AIFM business); plus
Whichever is the applicable of:
- The professional negligence capital requirement (“additional own funds requirement”); or
- The professional indemnity insurance (“PII”) capital requirement.
BennBridge calculates the credit risk applicable to its non-AIFM activities under the simplified approach.
For the period ended 5 April 2018, BennBridge’s capital resource requirement under Pillar 1 was £251k.
The Pillar 2 capital requirement is calculated as part of the ICAAP and represents additional capital to be maintained against any risk not adequately covered by Pillar 1.The ICAAP involves consideration of a range of risks faced by BennBridge and determines the level of capital needed to cover these risks.
In the Firm’s latest ICAAP, BennBridge concluded that its capital requirement under Pillar 1 (£251k) was sufficient to withstand unexpected losses arising from the operational, business and reputational risks identified and no additional capital was required to be held under Pillar 2. Scenario analysis and stress testing supports the conclusion that the Pillar 1 capital requirement is sufficient.
BennBridge’s remuneration policy complies with the requirements set out in Article 14 of the Alternative Investment Fund Managers Directive (“AIFMD”) and chapter 19B (the “AIFM Remuneration Code”) of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”).
BennBridge has a Remuneration Committee comprising the Governing Body. In accordance with the AIFM Remuneration Code BennBridge reports annually on the remuneration policy for “Code Staff”, defined as senior management, risk takers, control functions and any employees receiving total remuneration that takes them into the same remuneration bracket as senior management or risk takers.
The Remuneration Committee is responsible for setting the Remuneration Policy for all staff. The Remuneration Policy is designed to:
- Promote sound and effective risk management;
- Not encourage risk-taking which is inconsistent with the risk profile of the instrument constituting the fund of the AIFs the Firm manages;
- Be in line with the business strategy, objectives, values and interests of the Firm alongside the AIFs the Firm manages
- Include measures to avoid conflicts of interest
All employees are paid a fixed, base salary which is commensurate with market rates for those of their seniority, experience and qualifications. Any variable element of remuneration is performance-related, based on the results of the Firm and performance of the individual.
BennBridge has one “business area” being its investment management business. The number of current Code Staff has been established as 14. The total remuneration to Code Staff for the period ended 5 April 2018 was £1,339,062.
The information contained set out in this disclosure has not been audited by BennBridge’s external auditors and does not constitute any form of financial statement and should not be relied upon in making any judgement about the Firm.