Index Definitions and Disclosures
Index returns that we believe are reasonably reflective of our specific strategies are provided to offer greater context to the investment environment that existed during specific time periods. Indices are not intended to imply an advisor’s past or future performance. The volatility and holdings of each index is materially different from that of the referenced 1607 Capital composite. Indices are always fully invested, are unmanaged, and reflect the reinvestment of income, dividends and capital gain distributions, if any, but do not reflect fees, brokerage commissions, or other common expenses of investing. Investors cannot directly invest in an index. Individual indices have been selected in 1607 Capital’s discretion to represent what we believe are appropriate benchmarks that will allow for comparison of the 1607 Capital composite strategies.
The MSCI EAFE Index is an equity index which captures large and mid-cap representation across 21 Developed Markets countries around the world, excluding the US and Canada. Developed Markets countries in the MSCI EAFE Index include: Australia, Austria, Belgium, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, the Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland and the UK. The index covers approximately 85% of the free float-adjusted market capitalization in each country.
The MSCI All Country World Index is designed to measure global developed and emerging market equity performance. The benchmark is composed of the full opportunity set of large- and mid-cap stocks across 23 developed and 24 emerging markets. The index covers approximately 85% of the free float-adjusted market capitalization in each market.
The MSCI All Country World x US Index is designed to measure global developed and emerging market equity performance, excluding the United States of America. The benchmark captures large and mid-cap representation across 22 of 23 Developed Markets (DM) countries (excluding the US) and 24 Emerging Markets (EM) countries. DM countries include: Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland and the UK. EM countries include: Brazil, Chile, China, Colombia, Czech Republic, Egypt, Greece, Hungary, India, Indonesia, Korea, Kuwait, Malaysia, Mexico, Peru, Philippines, Poland, Qatar, Saudi Arabia, South Africa, Taiwan, Thailand, Turkey and United Arab Emirates. The index covers approximately 85% of the global equity opportunity set outside the US.
The MSCI Emerging Markets Index is designed to measure equity market performance of emerging markets. The MSCI Emerging Markets Index captures large and mid-cap representation across 24 Emerging Markets (EM) countries. EM countries include: Brazil, Chile, China, Colombia, Czech Republic, Egypt, Greece, Hungary, India, Indonesia, Korea, Kuwait, Malaysia, Mexico, Peru, Philippines, Poland, Qatar, Saudi Arabia, South Africa, Taiwan, Thailand, Turkey and United Arab Emirates. With 1,380 constituents, the index covers approximately 85% of the free float-adjusted market capitalization in each country.
The Russell 3000® Index is a market capitalization-weighted equity index that seeks to be a benchmark for the entire U.S. stock market. The index encompasses the 3,000 largest U.S.-traded stocks, in which the underlying companies are all incorporated in the U.S.
The Russell 2000® Index is a market capitalization-weighted equity index that seeks to measure the performance of the 2,000 smallest publicly traded U.S. companies in the Russell 3000 index.
The Russell 1000® Index is a market capitalization-weighted equity index that seeks to measure the performance of the 1,000 largest publicly traded U.S. companies in the Russell 3000 index.
The Bloomberg U.S. Aggregate Bond Index is designed to measure the investment grade, U.S. dollar denominated, fixed-rate taxable bond market, including Treasuries, government-related and corporate securities, MBS (agency fixed-rate and hybrid ARM pass-throughs), ABS, and CMBS. The benchmark is a market capitalization and intermediate term index.
The Bloomberg Municipal Bond Index is designed to cover the USD-denominated long-term tax exempt bond market. The index has four main sectors: state and local general obligation bonds, revenue bonds, insured bonds and pre-refunded bonds.
The Bloomberg Barclays Municipal Bond Index is an unmanaged index composed of long-term tax-exempt bonds with a minimum credit rating of Baa.
The Bloomberg Barclays Municipal High Yield Bond Index is a measure of the non-investment grade and nonrated USD-denominated tax exempt bond market. Included in the index are securities from all 50 US States and four other qualifying regions (Washington DC, Puerto Rico, Guam, and the Virgin Islands). The index includes state and local general obligation bonds and revenue bonds. All bonds in the Municipal High Yield Bond Index are tax exempt, and hence are not eligible for other indices that include taxable high yield bonds, such as the US High Yield Index and EM USD Aggregate Index.
The Morningstar LSTA US Leveraged Loan Index (formerly S&P Leveraged Loan Indexes) are capitalization-weighted syndicated loan indexes based upon market weightings, spreads and interest payments. The index seeks to mirror the market-weighted performance of the largest institutional leveraged loans, as determined by criteria.
The Dow Jones Industrial Average is a price-weighted index of 30 blue-chip industrial U.S. stocks.
The Standard & Poor’s 500 Index consists of 500 stocks chosen for market size, liquidity, and industry group representation. It is a market-value-weighted index with each stock’s weight in the index proportionate to its market value.
You cannon invest directly in an index. All index providers referenced in 1607 Capital materials make no express or implied warranties or representations and shall have no liability whatsoever with respect to any index data contained in 1607 Capital’s reports. The index data may not be further redistributed or used as a basis for other indices or any securities or financial products. Reports compiled by 1607 Capital are not approved, reviewed, or produced by any index provider.
Frank Russell Company (“Russell”) is the source and owner of the trademarks, service marks and copyrights related to the Russell Indexes. Russell® is a trademark of Frank Russell Company. Neither Russell nor its licensors accept any liability for any errors or omissions in the Russell Indexes and/or Russell ratings or underlying data and no party may rely on any Russell Indexes and/or Russell ratings and/or underlying data contained in this communication. No further distribution of Russell Data is permitted without Russell’s express written consent. Russell does not promote, sponsor or endorse the content of this communication.
MSCI makes no express or implied warranties or representations and shall have no liability whatsoever with respect to any MSCI data contained herein. The MSCI data may not be further redistributed or used as a basis for other indexes or any securities or financial products. This report is not approved, endorsed, reviewed or produced by MSCI. None of the MSCI data is intended to constitute investment advice or a recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such.
“Bloomberg®” and the Bloomberg indices are service marks of Bloomberg Finance L.P. and its affiliates, including Bloomberg Index Services Limited (“BISL”), the administrator of the index (collectively, “Bloomberg”). Bloomberg is not affiliated with 1607 Capital Partners, LLC, and Bloomberg does not approve, endorse, review, or recommend their material. Bloomberg does not guarantee the timeliness, accurateness, or completeness of any data or information relating to the information therewith.
MIFIDPRU 8 Public Disclosure
Introduction
The Financial Conduct Authority (“FCA” or “regulator”) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to 1607 Capital Partners Limited (“1607 UK” / the “Firm”). In particular, Chapter 8 of MIFIDPRU (“MIFIDPRU 8” or the “public disclosures requirements”) sets out public disclosure obligations with which the Firm must comply, further to those prudential obligations.
1607 UK is classified under MIFIDPRU as a small and non-interconnected investment firm (“SNI MIFIDPRU investment firm”). As such, MIFIDPRU 8 requires 1607 UK to disclose information regarding the Firm’s remuneration policy and practices.
The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture, and to assist stakeholders in making more informed decisions about their relationship with the Firm.
This document has been prepared by 1607 UK in accordance with the requirements of MIFPRU 8 and is verified by 1607 Capital Partners Limited Governance Committee (“the “Governance Committee”). Unless otherwise stated, all figures are as at the most recent year-end.
Remuneration Policy and Practices
Overview
As an SNI MIFIDPRU investment firm, 1607 UK is subject to the basic requirements of the MIFIDPRU Remuneration code. The purpose of the requirements on remuneration are to:
- Promote effective risk management in the long-term interests of the Firm and its clients;
- Ensure alignment between risk and individual reward;
- Support positive behaviours and healthy firm cultures; and
- Discourage behaviours that can lead to misconduct and poor customer outcomes.
The objective of 1607 UK’s remuneration policies and practices are to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.
In addition, 1607 UK recognises that remuneration is a key component in how the Firm attracts, motivates and retains quality staff and sustains consistently high levels of performance, productivity and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and greatest competitive advantage.
1607 UK is committed to excellence, teamwork, ethical behaviour and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude and results.
Characteristics of the remuneration policy and practices
Remuneration at 1607 UK is made up of fixed and variable components. 1607 UK’s incentive compensation plans play an important role in aligning the interests of our portfolio managers, investment team members, clients and shareholders. In addition to fixed compensation (salary) that is set in line with market competitiveness at a level to attract and retain skilled staff, incentive awards for Investment personnel are determined based on a review of relative investment and business/team performance along with other risk-aligned criteria. Embedded in investment performance is a disciplined investment risk management framework. 1607 Capital calculates remuneration with non-financial targets and performance indicators, including collaboration, dedication, relationship building with prospective and existing investors, and compliance with firm policies on corporate governance, diversity, training, and reporting procedures, in addition to traditional financial metrics. Variable compensation may include cash payments, non-cash remittances, as well as direct or indirect equity in 1607 Capital and resulting distributions/appreciation of this equity. All staff members are eligible to receive variable remuneration.
The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.
Governance and Oversight
The Governance Committee is responsible for setting and overseeing the implementation of 1607 UK’s remuneration policy and practices. The Governance Committee reports to the 1607 Capital Partners, LLC Board of Directors (the parent company of 1607 UK) who has final decision making authority. In order to fulfil its responsibilities, the Governance Committee:
- Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital and liquidity;
- Prepares decisions regarding remuneration, including decisions which have implications for the risk and risk management of the Firm;
- Ensures that the remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors and other stakeholders in the Firm; and
- Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of the Firm and of its clients.
1607 UK’s remuneration policy and practices are reviewed annually by the Governance Committee.
Quantitative Remuneration Disclosures
Remuneration awarded to staff is comprised fixed and variable components. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the Firm itself, directors, employees of other entities in the group, employees of joint service companies, and secondees. More information is available at https://find-and-update.company-information.service.gov.uk/company/10980587
ESG Factors
1607 Capital believes that environmental, social, and governance (“ESG”) issues can have a significant impact on investment performance. Thus, 1607 Capital has adopted an ESG Policy which is available by request. 1607 Capital considers ESG factors and sustainability risks in the course of its due diligence, its investment decisions, and investment monitoring, to the extent reasonably practicable under the circumstances and where consistent with our fiduciary responsibilities. While 1607 Capital seeks to employ ESG factors in its decision making and encourages underlying Closed-End Fund investment managers to do so as well, 1607 Capital does not control the investment decisions made by the Closed-End Fund investment managers. Thus, 1607 Capital’s ability to consider the adverse impact of its investment decisions on sustainability factors is limited, as 1607 Capital is an investor in pooled investment funds and ETFs managed by unaffiliated sponsors, and accordingly, 1607 Capital generally only has the ability to encourage underlying investment managers/sponsors to consider relevant material ESG related principles with respect to such investments. Additionally, as a fiduciary and a registered investment adviser with the US Securities and Exchange Commission, 1607 Capital has a duty to act in the best interest of its advisory clients. As always, notwithstanding the objectives of 1607 Capital’s ESG Policy, no activity will be required, or investment decision made, that would be adverse to, or inconsistent with, the fiduciary and contractual duties owed by 1607 Capital to its advisory clients. 1607 Capital’s funds do not have sustainable investments as their objective and/or promote environmental or social characteristics. The investments of 1607 Capital’s funds do not take into account the EU criteria for environmentally sustainable economic activities.
Other Disclosures
Actual performance results will differ from composite returns, depending on the size of the account, investment guidelines and/or restrictions, inception date and other factors. Performance for some accounts in an individual composite may be calculated by third-parties that use different security pricing and performance methodologies. Past performance is not indicative of future results. As with any investment strategy, there is always the potential for gains as well as the possibility of losses.
GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.
1607 Capital’s strategies are intended solely for professional clients, professional investors, institutional investors, investment professionals, eligible counterparties or qualified investors only. Not for retail use.
THIS MATERIAL DOES NOT CONSTITUTE AN OFFER OR SOLICITATION IN ANY JURISDICTION OR TO ANY PERSON WHERE IT WOULD BE UNAUTHORISED OR UNLAWFUL TO DO SO.
