Ethics Policy

Equal opportunity is about good employment practices and efficient use of our most valuable asset, our employees.
Ethics Policy

Lothbury Investment Management is an equal opportunity employer, so we operate under a strict Ethics Policy. In essence, it demands that we treat job applicants, employees and stakeholders in the same way, and that we do not discriminate on grounds of sex, marital status, religion, ethnic origin, colour, nationality, sexual orientation or age. The policy applies to all aspects of employment, including the advertisement of jobs, recruitment, training, conditions of work and pay.

Every manager and employee has a personal responsibility for implementing the policy and we closely monitor its strict implementation at all times. We redress any cases of inequality and any discriminatory conduct will be the subject of our disciplinary procedure.


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Important notice


This is the website of Lothbury Investment Management Limited of 155 Bishopsgate, London EC2M 3TQ, United Kingdom, a company registered in England with registered number 04185370. Lothbury Investment Management Limited (or “LIM”) is authorised and regulated by the Financial Conduct Authority in the United Kingdom.

Lothbury Investment Management Limited is the manager of the Lothbury Property Trust ("LPT") and the Lothbury Global Feeder LP ("LGF") (together, the “Funds”). LPT is a sub-fund of the Lothbury Global Institutional Funds, which is regulated by the Central Bank of Ireland. LGF was established as a limited partnership in Jersey under the Limited Partnerships (Jersey) Law 1994 through the filing of a declaration of limited partnership. The Funds are alternative investment funds (“AIFs”) for the purposes of the Alternative Investment Fund Managers Directive (2011/61/EU) (the “Directive”). LIM has been appointed and acts as alternative investment fund manager (“AIFM”) in respect of the AIFs. For these purposes, LIM is authorised and regulated in the United Kingdom by the Financial Conduct Authority for the purposes of managing unauthorised AIFs (and for various other activities). The Funds are also unregulated collective investment schemes for the purposes of the United Kingdom Financial Services and Markets Act 2000 (the “Act”).

Restrictions on Access

Certain jurisdictions may restrict by law access by their residents or nationals to the information on this website. The contents of this website are not intended to be accessed by, distributed to or used by residents or nationals of such jurisdictions. It is the responsibility of any person accessing this website to satisfy itself that its use of the website complies with the laws of any relevant jurisdiction. Under United Kingdom legislation, the promotion of units in the Funds by LIM is restricted by section 238 of the Act. The promotion of units by the Funds themselves or, in the case of LPT, by its trustees in the UK is restricted by section 21 of the Act. Accordingly, the information on this part of the website is directed only at and should only be acted on by:

  1. persons who are outside the UK;
  2. investment professionals within the meaning of Article 14(5) of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “CIS Exemptions Order”) and Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the “Financial Promotion Order”), which includes persons whose ordinary activities involve him in participating in unregulated schemes for the purposes of a business carried on by him; and/or
  3. high net worth organisations to whom Article 22 of the CIS Exemptions Order and Article 49 of the Financial Promotion Order apply. This includes companies or partnerships with net assets of GBP 5m or more and trustees of trusts with assets of GBP 10m or more); and
  4. others to whom it may lawfully be directed.

Purpose

The purpose of this website is to provide general information about Lothbury Investment Management Limited and the Funds. The Funds and Lothbury Global Feeder Limited but not any investors in these entities are clients of Lothbury Investment Management Limited. Nothing on this website is investment, tax or legal advice, nor is anything on this website a placement or offering to buy or sell units or any other investment. Tax treatment depends on individual circumstances and may be subject to change in the future. You should take your own independent investment, tax and legal advice as you think fit.

Please be aware that ultimately interests in the Funds may only be acquired by professional investors. A professional investor, for the purposes of LGF, is every investor that is considered, or may be treated, based on a request to LIM (as the AIFM), as a professional client or an eligible counterparty as those terms are used in exemption 7 of COB 4.12.4 of the Handbook of rules and guidance issued by the Financial Conduct Authority of the United Kingdom. A professional investor, for these purposes of LPT, is every investor that is considered, or may be treated based on a request to LIM (as the AIFM), as a professional client within the meaning of Annex II of the Markets in Financial Instruments Directive (2011/61/EC).

Subject to applicable law and satisfaction of any relevant notification or other requirement the Funds may be marketed (within the meaning of the Directive) within certain jurisdictions in the European Economic Area ("EEA"). Potential investors can request details of such jurisdictions from LIM. LGF is intended for persons who are not established or resident in the United Kingdom.

The information contained in this section does not constitute an offer or solicitation to any person or entity which is United Kingdom Resident for tax and investment purposes, to buy or sell shares or any other security whatsoever in other jurisdictions where it would be unlawful to do so, including but not limited to, Ireland and the United States of America.

Please tick that you have understood and accept the important notice set out above and agree to the matters addressed in it.