Last updated August 2026
1. Purpose
This policy sets out how Capel Asset Management (Capel) meets its obligations under the FCA's Consumer Duty (the "Duty"), set out in PRIN 2A of the FCA Handbook, in its capacity as delegated Investment Manager and, where appointed, Sponsor to Authorised Corporate Director ("ACD") of authorised funds.
Capel exercises day-to-day discretionary investment management and, in its capacity as Sponsor, contributes to the design, structure, distribution, and marketing of the funds, it is treated as having a degree of influence over retail customer outcomes, and therefore has its own obligations under the Duty, exercised in coordination with the ACD.
This policy should be read alongside Capel's Risk Management Policy and the Investment Management Agreement and Sponsor arrangements it has entered into with each ACD, which set out the respective responsibilities of Capel and the ACD in more detail.
2. Scope and Application
This policy applies to all authorised funds for which Capel acts as Investment Manager and/or Sponsor, and to all staff involved in investment decision-making, product design input, and communication with the relevant ACD / AIFM.
Capel supports the ACD in meeting consumer duty obligations by providing the investment expertise, data, and analysis the ACD needs, and by escalating any concerns it identifies about the outcomes investors are receiving.
Where Capel acts as Sponsor, it works with the ACD on the manufacture, design, structure, distribution, and marketing of each sub-fund, and its own conduct in that capacity is subject to the Duty as a co-manufacturer alongside the ACD.
3. Cross-Cutting Rules
In everything it does in connection with its retail funds, the Capel is guided by three overarching standards:
• acting in good faith towards investors;
• avoiding causing foreseeable harm to investors; and
• enabling and supporting investors to pursue their financial objectives.
These cross-cutting rules inform every decision on product design, pricing, disclosure, and investor support, and are considered explicitly as part of the governance and reporting arrangements described in Section 6.
4. The Four Outcomes
The Duty is built around four outcomes that between them cover the key elements of Capel-investor relationship.
Outcome
What it requires of Capel
Products and Services
• Provides the ACD with the investment expertise and analysis it needs to define and approve the target market for each fund
• Ensures investment decisions remain consistent with the agreed investment objective, policy, and target market
• Notifies the ACD promptly of any change to strategy, risk profile, or other factors that may affect the target market's continued suitability
Price and Value
• Ensures Capel's own fees are reasonable relative to the value of the services it provides
• Provides the ACD with the information it needs to complete its Assessment of Value under COLL 6.6.20R, including data on trading costs and the value derived from Capel's investment approach
• Supports any remedial action the ACD determines is necessary following an Assessment of Value, including a review of Capel's own fees where appropriate
Consumer Understanding
• Ensures that any investment content Capel prepares or contributes to (for example, commentary, factsheets, or strategy documentation) is clear, fair, and not misleading
• Works with the ACD, in its capacity as Sponsor, to ensure fund documentation properly reflects the fund's strategy and risks
• Flags to the ACD where communications may need to be tailored for investors with characteristics of vulnerability, where reasonably identifiable
Consumer Support
• Responds promptly and helpfully to queries raised by the ACD or by distributors regarding the fund's strategy or holdings
• Ensures that any direct investor-facing activity Capel undertakes, in its capacity as Sponsor, is consistent with the standard of support the ACD expects
• Escalates to the ACD any pattern in queries or complaints that suggests investors are not receiving good outcomes
5. Target Market and Fair Value
5.1 Target Market
The target market for each fund is set and approved by the ACD. Capel contributes to this process by providing its assessment of the fund's likely risk/return profile, complexity, and the type of investor for whom the strategy is designed, drawing on its expertise as Investment Manager and, where relevant, Sponsor. Capel reviews this input at least annually, or sooner if it becomes aware of a material change to the fund's strategy or risk profile and notifies the ACD accordingly so the ACD can consider whether the approved target market remains appropriate.
5.2 Fair Value
The ACD is responsible for carrying out the Assessment of Value for each fund under COLL 6.6.20R. Capel supports this process by providing the ACD with data on the costs of managing the fund, the rationale for its own fees, and any other information the ACD reasonably requests. Where an Assessment of Value identifies concerns relating to Capel's own fees or services, Capel works with the ACD to agree and implement appropriate remedial action within a reasonable timeframe.
6. Governance and Coordination with the ACD
Primary Board-level responsibility for Consumer Duty outcomes on each scheme rests with the ACD's Board, which receives the annual Consumer Duty report for that scheme. Capel's own Board receives regular updates on the outcomes being delivered to investors in the funds it manages and sponsors, and reviews whether Capel is meeting its own obligations under the Duty as a delegate and co-manufacturer.
Capel has designated a senior member of Compliance as the Consumer Duty Lead, acting as the primary point of contact for Consumer Duty matters with each ACD. Internal review is supplemented by the following minimum cadence of monitoring activity and reporting to the ACD:
Activity
Frequency / Trigger
Internal Consumer Duty review (Firm Board)
At least annually, and following any significant change to the funds Capel manages or sponsors
Information provided to the ACD for its Assessment of Value
At least annually, ahead of the ACD's Assessment of Value cycle for each fund
Target market input provided to the ACD
At least annually, and on any material change to a fund's strategy or risk profile
Outcomes monitoring MI shared with the ACD
Quarterly, or more frequently where risks are identified
Complaint and query themes shared with the ACD
Quarterly
7. Investors with Characteristics of Vulnerability
Capel recognises that, although it does not typically deal directly with retail investors, its role as Sponsor means the content it produces or contributes to should remain suitable for investors who may be in vulnerable circumstances. Where Capel becomes aware, through distributor feedback or otherwise, that vulnerability may not be adequately addressed in fund documentation or communications, it raises this with the ACD so the ACD can consider what action, if any, is appropriate.
8. Monitoring, Management Information, and Outcomes Testing
Capel collects and reviews management information to test whether investors are receiving the outcomes the Duty requires and shares relevant findings with each ACD. This includes fund performance against target market expectations, distributor feedback, redemption patterns, and, where available, data on investor understanding of key disclosures. Findings that suggest an outcome is not being met are escalated internally to the relevant investment committee and, where material, to Capel's Partners and to the ACD.
9. Record-Keeping
Capel keeps records sufficient to evidence how it has met its own obligations under the Duty as a delegate and co-manufacturer, including the target market input and fair value information it has provided to each ACD, records of escalations raised with an ACD, and the management information reviewed in support of outcomes monitoring. Records are retained in line with Capel's general record-retention requirements and are made available to the FCA, and to the relevant ACD, on request.
10. Forthcoming Regulatory Developments
Capel monitors ongoing regulatory developments affecting delegated investment managers and co-manufacturers under the Duty, including the FCA's statement clarifying its expectations for firms that jointly manufacture products or services, and its planned consultation on how the Duty applies across distribution chains and to non-UK business. Capel also monitors the phased introduction of the Consumer Composite Investments (CCI) disclosure regime, which will progressively replace the UCITS KIID over the transitional period. This policy will be reviewed and updated as these developments are finalised, and as the allocation of responsibilities between Capel and each ACD is confirmed or revised.