Ilex Capital Partners (UK) LLP is a London based investment management firm pursuing an equity market neutral strategy.
The approach places emphasis on alpha extraction, aiming to generate consistent, highly idiosyncratic returns. The strategy seeks to identify differentiated single-stock ideas within a framework of rigorous portfolio construction governed by exceptional risk management capabilities.
Liberty House, Suite 4.01, 222 Regent Street, W1B 5TR. United Kingdom
Ilex Capital Partners (UK) LLP is authorised and regulated by the Financial Conduct Authority (Firm Reference No. 989013).
© 2023 Ilex Capital Partners (UK) LLP. All Rights Reserved. Use of this Website is governed by the Terms and Conditions and is subject to the Privacy Policy.
Ilex Capital Partners (UK) LLP, incorporated in England and Wales. Company Number: OC444645.
Registered office: Liberty House 222 Regent Street, Suite 4.01, London, England, W1B 5TR.
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Ilex Capital Partners (UK) LLP (“Ilex Capital”) is a Full-scope UK AIFM, which employees an equity market neutral strategy.
Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2B.5, Ilex Capital is required to develop and publicly disclose an engagement policy, as described in the revised Shareholder Rights Directive (“SRD II”), or provide a clear and re asoned explanation as to why it has chosen not to develop and adopt a shareholder engagement policy at this time. Ilex Capital will review this on an ongoing basis.
Ilex Capital supports the objectives underlying SRD II and adheres to the highest standards of corporate governance and due diligence in respect of its investments. However, Ilex Capital believes that its investment strategies and operational structure are incompatible with shareholder engagement activities.
Where Ilex Capital invests in equities the relevant exposure is often held via swap positions, limiting the opportunities for engagement when compared with shareholdings. Furthermore, Ilex Capital pursues active investment strategies and shares are not typically held with a long-term view and so the concept of actively engaging with investee companies would serve no practical purpose.
Therefore, whilst Ilex Capital generally supports the objectives that underline the rationale for development of an engagement policy, the nature of its investment strategies is such that its provisions are not materially relevant.
June 2023
Under the Rules of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Ilex Capital Partners (UK) LLP (“Ilex Capital”) is required to make a public disclosure on its website in relation to the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code.
The Code was first published by the FRC in July 2010 and it was updated in September 2012. Subsequently, the FRC published the new UK Stewardship Code 2020 (“2020 Code”), which took effect from 1 January 2020, and consists of 12 principles for asse t managers and asset owners, and six principles for service providers.
The 2020 Code applies on a ‘comply or explain’ basis and is voluntary, aiming at enhancing the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.
The FRC defines ‘stewardship’ as ‘the responsible allocation, management and overs ight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.’
The 2020 Code principles for asset managers and asset owners are:
Ilex Capital supports the objectives underlying the 2020 Code and adheres to the highest standards of corporate governance and due diligence in respect of its investments. However, Ilex Capital believes that the 2020 Code is not applicable to its investment activities at this time. Ilex Capital will review its commitment to the 2020 Code at least annually and update this disclosure accordingly.
June 2023
Ilex Capital Partners (UK) LLP (“Ilex Capital”) is a Full-scope UK AIFM, which employees an equity market neutral strategy.
Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2B.5, Ilex Capital is required to develop and publicly disclose an engagement policy, as described in the revised Shareholder Rights Directive (“SRD II”), or provide a clear and re asoned explanation as to why it has chosen not to develop and adopt a shareholder engagement policy at this time. Ilex Capital will review this on an ongoing basis.
Ilex Capital supports the objectives underlying SRD II and adheres to the highest standards of corporate governance and due diligence in respect of its investments. However, Ilex Capital believes that its investment strategies and operational structure are incompatible with shareholder engagement activities.
Where Ilex Capital invests in equities the relevant exposure is often held via swap positions, limiting the opportunities for engagement when compared with shareholdings. Furthermore, Ilex Capital pursues active investment strategies and shares are not typically held with a long-term view and so the concept of actively engaging with investee companies would serve no practical purpose.
Therefore, whilst Ilex Capital generally supports the objectives that underline the rationale for development of an engagement policy, the nature of its investment strategies is such that its provisions are not materially relevant.
June 2023
Transparency Statement on Modern Slavery Act
This statement is made by Ilex Capital Partners (UK) LLP and Ilex Capital Services Limited (together, “Ilex Capital”) and is published pursuant to the Modern Slavery Act, 2015.
This statement outlines the steps that Ilex Capital has committed to take to help detect and prevent modern slavery during the 2022/2023 financial year, ending 31 March 2023.
Business Overview and Risk Assessment of Supply Chain
Founded in 2022, Ilex Capital is a London based investment management firm pursuing an equity market neutral strategy. The approach places emphasis on alpha extraction, aiming to generate consistent, highly idiosyncratic returns. The strategy seeks to identify differentiated single-stock ideas within a framework of rigorous portfolio construction governed by exceptional risk management capabilities. Ilex Capital has over 10 employees.
As a financial services business, Ilex Capital employs highly skilled labour, and has a supply chain predominantly limited to reputable counterparties and service providers. Accordingly, it is believed that the risk of exposure to modern slavery is relatively low. Ilex Capital is nonetheless committed to adopting appropriate measures to continuously assess, identify and alleviate the risk of modern slavery occurring within the business and wider supply chains.
Addressing Modern Slavery Internal Policies
Ilex Capital has a number of internal policies relevant to combating modern slavery (not exhaustive):
Due Diligence Procedures
Ilex Capital carries out appropriate due diligence on all third party providers prior to engagement. Modern slavery is one of the key criteria to this process, with Ilex Capital requesting to see a copy of the supplier’s modern slavery statement, where relevant. In addition, Ilex Capital carries out thorough ‘Know Your Customer’ checks, key to identifying human trafficking activities.
Training
All staff are equipped with the knowledge to help identify human trafficking risks through regular Compliance training which covers relevant area including financial crime, whistleblowing, and the FCA Conduct Rules.
Ilex Capital will continue to review internal policies and practices each financial year to further ensure modern slavery is not occurring in the business and supply chain.
This statement is approved by the Executive Committee / Management & Risk Committee of Ilex Capital in June 2023.
Terms & Conditions of Use
This website (the “Website”) is provided by Ilex Capital Partners (UK) LLP (“Ilex” and hereinafter also referred to as “we” or “our”). Ilex is registered as a limited liability partnership under Company number OC444645 with its registered office at Liberty House 222 Regent Street, Suite 4.01, London, England, W1B 5TR.
By accessing or using this Website, you accept and agree to comply with these Terms and Conditions of Use (“Terms”) and have read and accepted the terms of our Privacy Notice1. These Terms are a binding agreement between you and Ilex, and govern your access and use of this Website, which includes any text, graphics, user interfaces, information, data, tools, products, services and other content (collectively, the “Content”) available on or through this Website. You may contact information@ilexcapital.com with any questions about these Terms.
1. Use of this Website
Ilex grants you a limited right to use this Website. Your right to use this Website is subject to your agreement to abide by these Terms in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of this Website. We may revoke your right to use all or any portion of this Website at any time and for any reason. You may not violate or attempt to violate the security of this Website.
If for any reason any part of these Terms is deemed to be unenforceable then the validity of the remaining terms shall not be affected. All disclaimers, terms, conditions as set out in this Website shall form part of these Terms.
2. Intended Recipients
This Website is not directed at, or intended for use by, any person in any jurisdiction or country where such communication or use would be contrary to local law or regulation.
In the United Kingdom (the “UK”), this Website is directed only at persons who are, as applicable: (i) investment professionals within the meaning of Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (“FP Order”) or Article 14 of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “PCIS Order”); (ii) high net worth companies and certain other entities falling within Article 49 of the FP Order or Article 22 of the PCIS Order; (iii) capable of being categorised as professional clients meeting the criteria laid down in Annex II of the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) as it forms part of the law of the UK; or (iv) any other persons to whom such communication may lawfully be made. It must not be used, or relied upon, by any other persons.
The Website is not intended for distribution in the United States or for the account of US persons (as defined in Regulation S under the United States Securities Act of 1933, as amended (the “Securities Act”)) other than to persons who are “qualified purchasers” (as defined in the United States Investment Company Act of 1940, as amended (the “Company Act”)) and/or “accredited investors” (as defined in Rule 501(a) under the Securities Act).
3. No Offer or Solicitation
This Website is not intended and must not be construed as an offer or solicitation to purchase, or an offer to sell, shares of any fund or another investment product mentioned on this Website
(“Investment”) in any jurisdiction. In particular, this Website is not intended as marketing of any alternative investment fund in the UK or any member state of the European Economic Area (“EEA”) for the purposes of the EU Directive 2011/61/EU on Alternative Investment Fund Managers, as amended and implemented in the EEA and the same as it forms part of the law of the UK.
Any offer of Investment will only be made on the basis of the prospectus or offering memorandum relating to the relevant Investment. PROSPECTIVE INVESTORS SHOULD REVIEW THE PROSPECTUS OR OFFERING MEMORANDUM, INCLUDING THE RISK FACTORS, BEFORE MAKING A DECISION TO INVEST. Prospective investors should rely only on the prospectus or offering memorandum in making a decision to invest, even if certain descriptions contained on this Website may be more detailed than those contained in the relevant prospectus or offering memorandum. Subscriptions may only be made on the terms of the relevant prospectus or offering memorandum and subject to completion of a subscription agreement. In addition, any Investment or transaction will be subject to applicable legal and regulatory restrictions, including the prospective investor meeting applicable eligibility criteria.
4. Nature of the Content
The Content is intended only for information purposes and convenient reference and is not intended to be complete. It is not intended to provide, and should not be relied upon, for investment, accounting, legal or tax advice. You should consult your own financial, tax, legal, accounting or other advisors about the issues discussed on this Website. The Content may not be suitable for all investors.
Users of this Website should be aware that Ilex is not acting for, or advising them, and is not responsible for providing them with the protections available under the UK regulatory system. Compensation will not be available from the UK’s Financial Services Compensation Scheme.
The information contained on this Website has not be verified independently. Although the Content is believed to be correct and accurate at the time of publication, Ilex makes no representation or warranty as to the accuracy or completeness of any such information or content. Any analysis contained on this Website is based upon a number of assumptions. Changes in such assumptions could produce materially different results. The Content is not intended to forecast or predict future events. All opinions, projections and estimates constitute the judgment of the author as of the date on which this Website was last updated. Ilex assumes no duty or responsibility to update this Website, and any views, forecasts, estimates or opinions expressed on this Website may change without notice.
5. Certain Risks
Investing entails certain risks, including the possible loss of the entire capital invested. The Investments and services of Ilex may entail substantial risks and may not be suitable for certain or all investors. An Investment may expose you to a significant risk of losing all of the property or other assets invested. Some, but not all, of these risks will be contained in the relevant prospectus or offering memorandum. Potential investors should familiarize themselves with these risks and obtain advice from their own financial, accounting, legal, tax and other advisors and only make investment decisions based on the investor’s own objectives, experience and resources.
6. Limitations of Liability
Ilex assumes no responsibility or liability for the correctness, accuracy, timeliness or completeness of the Content, for any viruses contained in, or attached to, this Website or for any loss, damage or lost opportunities resulting from the use of the Content.
To the maximum extent permitted by applicable law or regulatory requirements, neither Ilex nor any of its affiliates, members, directors, employees or other representatives shall be liable for any errors, inaccuracies or omissions on this Website or for any loss or damage resulting from its use, whether caused by negligence or otherwise. This limitation of liability includes any damages, losses, costs, claims, liabilities or expenses arising out of or in connection with the use of this Website howsoever arising (whether under contract, tort, statute or otherwise arising). This limitation of liability shall apply to all damages, losses, costs, claims, liabilities and expenses of any kind whether direct or indirect and consequential, including (but without limitation) any indirect, special, indirect or consequential damages arising out of or in connection with the access of, use of, performance of, browsing in or linking to other sites from the Website, legal costs or expenses, direct loss of profit, direct loss of anticipated savings, loss of data, indirect loss of profit, indirect loss of anticipated savings, loss of revenue, loss of business, loss of use of money, loss of opportunity or loss of or damage to property and/or any wasted expenditure and third-party claims.
7. Indemnification
As a condition of your use of this Website, you agree to indemnify and hold Ilex harmless from and against any and all claims, losses, liability, costs and expenses (including but not limited to legal fees) arising from your use of this Website, or from your violation of these Terms.
8. Third Party Websites
Any links to third-party websites are provided solely for your convenience and do not constitute any endorsement, partnership, joint-venture, sponsorship or approval of the materials appearing in such sites. Ilex accepts no responsibility for the content of such third-party websites.
9. Intellectual Property and Copyright
The entire content of this Website is subject to copyright and intellectual property rights of Ilex with all rights reserved. The Content may not be redistributed in whole or in part, stored in a retrieval system, modified, linked into, republished, uploaded, transmitted in any form or by any means electronic or mechanical, or by photocopying, recording or otherwise without the express prior written permission of Ilex.
The names, logos, or identifying marks relating to the products and services of Ilex are proprietary trademarks/ service marks and may not be used in any way without express prior written consent of Ilex. If you download or print out a hard copy of individual pages and/or sections of the Website, you may not remove any copyright or other proprietary notices.
10. Amendments to these Terms
We may update and modify these Terms from time to time. Such modifications shall be effective immediately upon posting to this Website. You should review this page from time to time to take notice of any modifications we make.
11. Law and Jurisdiction
These Terms and any and all disputes or claims arising out of or in connection with them (whether contractual or non-contractual) shall be governed by and shall be construed in accordance with English law. All disputes arising out of or in connection with these Terms (whether contractual or non-contractual) shall be subject to the exclusive jurisdiction of the English courts. A condition of using this Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.
Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Ilex Capital Partners (UK) LLP (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.
How we collect information about you
We may collect personal data about you through:
We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.
Why we collect information about you
We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.
We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.
The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.
What are the consequences of failing to provide your personal information?
As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).
We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.
A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.
The types of personal data we may collect and use
The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials.
Do we use automated decision-making processes?
No.
Do we share your personal information with third parties?
We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:
Transfers of personal information to countries outside of the United Kingdom (UK)
Due to the international nature of our business, your personal data may be transferred to countries outside of the UK, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the UK General Data Protection Regulation or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.
For how long do we keep your personal information?
We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.
The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.
We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.
What are your rights?
You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:
How to contact us
If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Compliance Officer by email at compliance@ilexcapital.com or by writing to Compliance Officer, Ilex Capital Partners (UK) LLP, Liberty House, 222 Regent Street, London, W1B 5TR.
Complaining to ICO
You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.
Use of cookies
We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies.
If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.
Recording and monitoring of communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of:
Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.
June 2023