Disclaimer & Regulatory Information

This communication has been issued in the United Kingdom by Affirmative Investment Management Partners Limited (“the Firm”) which is authorised and regulated by the Financial Conduct Authority of the United Kingdom and is made to and directed solely at

  • existing customers of the Firm and/or
  • persons who would be classified as a professional client or eligible counterparty under the FCA Handbook of Rules and Guidance if taken on as customers by the Firm and/or
  • persons who would come within Article 19 (investment professionals) or Article 49 (high net worth companies, trusts and associations) of the Financial Services and Markets Act 2000 (Financial Promotions) Order 2001 and/or
  • persons to whom this communication could otherwise be lawfully made in the United Kingdom.

Any recipient of this communication who is not one of the intended recipients as set out above should disregard the communication and may not rely on or take any action in relation to the communication. Recipients of this communication in jurisdictions outside the United Kingdom should inform themselves about and observe all applicable legal or regulatory requirements.

Whilst the Firm has taken reasonable care to ensure that the information in this communication is accurate at the time of its preparation, it should not be construed as the giving of advice or the making of a recommendation. In particular, actual results and developments may be materially different from any forecast, opinion or expectation expressed in this communication.

Affirmative Investment Management Partners Limited Annual Best Execution Disclosure 2021

On an annual basis, the Firm is required to provide additional disclosures around the execution venues utilised for each asset class and certain information on the quality of execution in line with the requirements of Regulatory Technical Standard 28 of the MiFID II regulation.

The Firm takes into consideration various execution factors, which are detailed within its best execution policy, when placing an order. The Firm takes into account each client’s objectives, the specific financial instruments to which the order relates, the execution venues or counterparties available for such orders and the prevailing market conditions.

The Firm has categorised all its clients as professional under Article 4 (1)(11) of Directive 2004/39/EC.

During the period January 2020 to December 2021, the Firm confirms that there were no material close links, common ownership or conflicts of interest between us and the execution venues/brokers used by the Firm.

AIM places orders to be executed with approved counterparties. The list of approved counterparties is reviewed regularly and may change over time. Amendments to the approved counterparties list will be made taking into account a number of factors, including the creditworthiness of the counterparty and the execution performance of the counterparty. The Firm does not receive payments, discounts, rebates or non-monetary benefits in its trading arrangements.

There is no preferential treatment across clients in relation to execution and/or allocation arrangements, with the exception of where venues are dictated by the client.

A governing body meeting is held on a quarterly basis in order to review adherence to the best execution policy. It is attended by Senior Management, Compliance and Risk, who review the management information available for all traded instrument types and discuss any concerns or issues.

During the year ending December 2021, the Firm has met its obligation to achieve the best possible results for its clients on a consistent basis.

Class of Instrument Debt Instruments
Notification if <1 average trade per business day in the previous year N
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
TD LEI: PT3QB789TSUIDF371261 18.79% 17.95% N/A N/A N/A
HSBC LEI: MP6I5ZYZBEU3UXPYFY54 17.99% 15.20% N/A N/A N/A
MS LEI: VLR6T6E60GH5GUS0XX16 13.42% 9.68% N/A N/A N/A
CITI LEI: E57ODZWZ7FF32TWEFA76 9.93% 11.79% N/A N/A N/A

Stewardship Code Disclosure
Affirmative Investment Management Partners Limited

Under chapters 2.2B and 2.2.3R of the FCA’s Conduct of Business Sourcebook, Affirmative Investment Management Partners Limited (the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code and the Shareholders Rights Directive.

Stewardship Code (the “Code”)

The Code sets out a number of principles relating to engagement by investors with UK equity issuers, as follows:

The twelve principles of the Code for Asset owners and Asset Managers (in our case, Asset Managers) are as follows:

Purpose and Governance:

1. Purpose, strategy and culture

Asset Managers’ investment beliefs, strategy, and culture to facilitate long term value, via stewardship, for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.

2. Governance, resources and incentives

Asset Managers’ governance, resources and incentives support stewardship.

3. Conflicts of Interest

Asset Managers should manage conflicts of interest to put the best interests of clients and beneficiaries first.

4. Promoting well-functioning markets

Asset Managers should identify and respond to market-wide and systemic risks to promote a well-functioning financial system.

5. Review and assurance

Asset Managers should review their policies, assure their processes and assess the effectiveness of their activities.

Investment Approach:

6. Client and beneficiary needs

Asset Managers should take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.

7. Stewardship, investment and ESG integration

Asset Managers should systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.

8. Monitoring managers and service providers

Asset Managers should monitor and hold to account third-party managers/proxy advisors/research or other service providers.


9. Engagement

Asset Managers should engage with issuers to maintain or enhance the value of assets.

10. Collaboration

Asset Managers, where necessary, should participate in collaborative engagement to influence issuers.

11. Escalation

Asset Managers, where necessary, should escalate stewardship activities to influence issuers.

Exercising rights and responsibilities:

12. Exercising rights and responsibilities

Asset Managers should actively exercise their rights and responsibilities across all asset classes.



Shareholders Rights Directive (the “Directive”)

Similarly, the Directive requires firms that invest in shares that trade on an EU regulated market to develop and publicly disclose an engagement policy or publicly disclose a clear and reasoned explanation of why it has chosen not to comply with this requirement.

The Firm pursues an investment strategy to which the aims of the Code and the Directive are not relevant.

The Firm follows a new approach to fixed income and cash management that gives ultimate power back to the end investor. The Firm focuses on bonds and cash instruments that both generate mainstream market returns and achieve positive externalities to benefit the local and global community. As such, its strategy does not result in it trading in single equities.

Consequently, while the Firm supports the general objectives that underlie the Code and the Directive, the provisions of both are not relevant to the type of trading currently undertaken by the Firm.  If the Firm’s investment strategy changes in such a manner that the provisions of either the Code and the Directive become relevant, the Firm will amend this disclosure accordingly.

For further information on the Firm’s approach contact:  Michelle Smith, michelle.smith@affirmativeim.com; tel:  +44 (0)203 949 6901

Morningstar disclaimer

©2022 Morningstar, Inc. All rights reserved. Neither Morningstar, its affiliates, nor the content providers guarantee the data or content contained herein to be accurate, complete or timely nor will they have any liability for its use or distribution. Any general advice or ‘class service’ have been prepared by Morningstar Australasia Pty Ltd (ABN: 95 090 665 544, AFSL: 240892) and/or Morningstar Research Ltd, subsidiaries of Morningstar, Inc, without reference to your objectives, financial situation or needs. Refer to our Financial Services Guide (FSG) for more information atwww.morningstar.com.au/s/fsg.pdf. You should consider the advice in light of these matters and if applicable, the relevant Product Disclosure Statement before making any decision to invest. Our publications, ratings and products should be viewed as an additional investment resource, not as your sole source of information. Past performance does not necessarily indicate a financial product’s future performance. To obtain advice tailored to your situation, contact a professional financial adviser.

Source: The Morningstar ESG Commitment Level – May 2021 

SFDR: Sustainability Related Disclosures

To read about our SFDR disclosure, please click here.