Diversity Policy

Board Diversity and Recruitment Policy

1.1 Introduction

Not only is it against the law to treat someone less favorably than someone else because of a personal characteristic, e.g. religion or age or sex, but such treatment can have a detrimental effect to the success of any organization.

The Firm believes that there is a strong business case for increasing boardroom diversity, which helps to promote good governance and challenge “group think” mentality. Diverse boards also act as a powerful driver for innovation, creativity, and provides a better reflection of a firm’s customer base. The Firm also believes an open and transparent recruitment policy is essential in remaining compliant with the relevant equality legislation within the UK and is ultimately fair for all applicants who wish to sit on the governing body of the Firm.

1.2 Purpose

Increased diversity in the composition of management bodies can facilitate independent opinions and critical challenge and therefore the Firm has implemented the following policy to ensure our management structure is sufficiently diverse as regards:

  • Age;
  • Gender;
  • Race;
  • Educational and professional background;
  • Religion or belief;
  • Disability;
  • Regional background.

Gender balance is of particular importance to ensure adequate representation of population. Whilst there is no legal requirement to review the governing structure of the Board when considering diversity, the Firm is aware of the recommendations made by the UK Corporate Governance Code and the CBI (Confederation of British Industry). The Firm is also aware of the rules in the Systems and Controls Sourcebook (SYSC) 4.3A.R and the relevant requirements contained in MiFID Art.9 the Capital Requirements Directive (CRD) and Capital Requirements Regulation (CRR) including those only applicable to significant organisations. Whilst some of these rules do not apply to the Firm, we have ensured that our diversity policy follows the spirit of these requirements but have disapplied the specific requirements (such as setting quota’s or ratios for gender diversity) as this would not be proportionate for a Firm of the Firm’s size and structure. For the avoidance of doubt, this is the Firm’s diversity and recruitment policy required by SYSC 4.3A.10R and CRR article 435(2)(b) and (c).

When appointing members of the management body, the Firm will consider whether the candidates have the knowledge, qualifications and skills necessary to safeguard proper and prudent management of the institution. These principles will be exercised and manifested through our transparent and open recruitment procedures.

1.3 Policy Statement

The Firm recognizes and embraces the benefits of having a diverse Board and sees increasing diversity within our managing structure as boosting our competitive advantage. A truly diverse governing structure will include and make good use of differences in the skills, regional and industry experience, background, race, gender and other qualities of those within the governing body responsible for the management of the Firm. Whilst these differences will be considered in determining the optimum composition of the Board all appointments are made on merit against objective criteria, within the context of the skills, background and experience the management team as a whole requires to be effective. We will ensure that we adequately set out and describe the role and capabilities required for any given appointment to the governing body.

The selection procedure and recruitment process will remain independent in nature, in so far as this is possible given the size and structure of the Firm and in consideration as to who ultimately has the necessary authority to make decisions regarding recruitment into the governing body of the Firm. Adequate notes and records will be maintained throughout the process so compliance with this policy can be reviewed.

It would not be proportionate for a Firm with the size and structure of the Firm to have an independent body to review and assess the composition of the governing structure of the Firm; nor would it be proportionate to create an independent body to review applicants within this context. The Firm have therefore implemented the following relevant processes and procedures in order to ensure compliance with this diversity and recruitment policy:

  • Considering the benefits of all aspects of diversity including, but not limited to, those described above, in order to maintain an appropriate range and balance of skills, experience and background on the Board.
  • In identifying suitable candidates, the Firm will consider candidates on merit against objective criteria and with due regard for the benefits of diversity on the Board.
  • Create or update a job description which is concise and includes: the title of the job, the aim of the job, and the main tasks as part of these criteria. A person specification will link the job description and state the skills, experience and knowledge a person needs to satisfy the role.
  • Job adverts will state that we welcome applications from all sections of the community and we will actively encourage candidates to apply who will enhance the diversity of the governing body.
  • Ensure the Firm operates a transparent and open recruitment process by disclosing our recruitment and diversity policy, and clearly stating the purpose of the recruitment undertaken and the role to be undertaken.
  • Adequate records of the process will be kept (including advertisements, job descriptions and specifications, the selection process and decision-making process in so far as certain details will be required to remain confidential).

At least annually the governing body of the Firm will consider the diversity of its governing arrangements within the Firm and determine whether the make-up of the Board satisfies our diversity and recruitment policy. The Firm will determine if any changes need to take place within the processes and procedures laid down within this policy to ensure we meet our objectives.

1.4 Disclosing this policy

This Policy will be published on the Firm’s website.

Welcome to the website of FQS Capital Partners

Please read the Terms below carefully which may be subject to change without notice.

Terms of Use and Legal Disclaimer

By accessing this site you signify your agreement with, and understanding of, the following Terms of Use and Legal Information pertaining to both this site and any material on it. This site is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of this site constitutes your agreement to all such terms, conditions and notices. FQS Capital Partners L.P & FQS Capital Partners LLP (together “FQS”), hereinafter defined, reserves the right to change the terms, conditions, and notices under which this site is offered.

General information and disclaimer

The information contained in this website has been prepared and is communicated by FQS Capital Partners L.P which is registered with the U.S Securities Exchange Commission as an Investment Adviser and whose registered address is 40 North Country Road, Port Jefferson, New York 11777 and FQS Capital Partners LLP, which is incorporated under the laws of England and Wales (company no. OC348870), is authorised and regulated by the Financial Conduct Authority (FCA registration number 513713 - the link to the FCA register is: https://register.fca.org.uk/), together both firms are described herein as 'FQS' and FQS Capital Management (Cayman) Limited, an exempted company registered in the Cayman Islands with registered number 236656 having its registered office at, 4th Floor, Harbour Place, 103 South Church Street Grand Cayman, KY1-1002.

FQS Alternatives Fund L.P is a Delaware Limited Partnership and FQS Alternatives Fund Limited is an open ended multi-class investment company incorporated with limited liability in the Cayman Islands (together the "Funds").

This website is published solely for informational purposes and does not constitute or form part of any offer or invitation to sell, or the solicitation of an offer to subscribe for or purchase any investment and is provided for information purposes only. Neither this website, nor the fact of its distribution form the basis of, nor may be relied on in connection with, any contract to subscribe for or purchase any investment. This website does not constitute an offer or solicitation by anyone in any jurisdiction in which such offer or solicitation is not authorised or to anyone to whom it is unlawful to make such a solicitation. Recipients should inform themselves of and observe all applicable laws and regulations including, without limitation, any taxation or exchange control legislation in the countries of their citizenship, residence, domicile or such other status as may be relevant in connection with any subscription of shares. FQS disclaims all responsibility in the event that you download any information from the website in breach of any law or regulation of the country in which you reside.

United States of America: In particular, the shares in the FQS Alternatives Fund Limited have not been registered under any United States securities legislation and they are not being offered, directly or indirectly in the United States of America or in any of the territories or possessions or areas subject to its jurisdiction or to its citizens or persons thereof. The FQS Alternatives Fund LP is not registered as an investment company by virtue of Section 3(c)(7) of the Investment Company Act of 1940, as amended (the "1940 Act"). It complies with Section 3(c)(7) of the 1940 Act which permits private investment companies (such as the Partnership) to sell their interests, on a private placement basis, to an unlimited number of "qualified purchasers", as that term is defined under the 1940 Act.

United Kingdom: Any financial promotion contained in this website is issued by FQS Capital Partners LLP which is authorised and regulated by the Financial Conduct Authority ("FCA"). The Funds are defined as "Unregulated Collective Investment Schemes" ("UCIS") and the promotion of a UCIS either within the UK or from the UK is severely restricted by statute. Consequently, relevant offerings are only made available to professional clients and eligible counterparties as defined by the FCA and also to persons of a kind to whom the Fund may lawfully be promoted by an authorised person by virtue of Section 238(5) of the Financial Services and Markets Act 2000 and COBS 4.12.4R. Shares in the Funds should only be purchased by persons with experience of participating in unregulated schemes and any other person who receives such documents should not rely upon them. Though FQS Capital Partners LLP is authorised and regulated by the FCA, most if not all of the protections provided by the United Kingdom regulatory system will not apply to investments in the products & services detailed within this website.

Legal and regulatory statements

Introduction

FQS Capital Partners L.P is registered with the U.S Securities Exchange Commission as an Investment Adviser. FQS Capital LLP is authorised and regulated in the UK by the Financial Conduct Authority ("FCA") and is therefore subject to the FCA's Prudential Sourcebook for Banks, Building Societies and Investment Firms ("BIPRU").

Confidentiality

Information is generally viewed as proprietary if sharing that information with the public would undermine a competitive position. Proprietary information may include information on products or systems that, if shared with competitors, would render the Company's investments therein less valuable. Further, the Company must regard information as confidential if there are obligations to customers or other counterparty relationships binding the Company to confidentiality. In the event that any such information is omitted, the Company shall disclose such and explain the grounds why it has not been disclosed.

Background of FQS Capital Partners L.P & FQS Capital Partners LLP ("FQS")

FQS is an independent fund of hedge fund manager with offices in the US and the UK. FQS looks to offer bespoke investment management solutions and advisory to clients, applying amongst other things its bespoke quantitative technologies.

FQS Capital Partners LLP – Stewardship Code

FQS Capital Partners LLP fully supports the UK Stewardship Code (“The Code”) which sets out good practice for institutional investors (and investment managers) when engaging with the UK listed companies in which they invest, and is intended to enhance this relationship.

However, as an investment manager that manages investments in hedge funds there are no investee companies for the firm to interact with or shareholder value to protect. Therefore, The Code does not currently apply to the firm’s activities as an investment manager.

FQS Capital Partners LLP will keep the position under review and should it consider expanding its range of operations it will determine whether the Code is likely to become applicable to its investment management activities.

Shareholder Rights Directive (SRD II)

SRD II aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on EEA regulated markets and comparable regulated markets outside the EEA. It came into effect on 10 June 2019.

The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:

Publish their shareholder engagement policy (or explain why they don't have one) – COBS 2.2B.5R.
Make annual public disclosures relating to the implementation of their shareholder engagement policy, from 10 June 2020 – COBS 2.2B.5R.
Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R.
FQS Capital Partners LLP does not manage investments in shares which are traded on an EEA regulated market, or on a comparable regulated market outside the EEA, and so the SRD II rules do not apply to it. Therefore, we have not developed a shareholder engagement policy and nor are we required to make the disclosures outlined above.

These policy positions are reassessed by the Partners on an annual basis or ad hoc as needs be.

For further information on the Firm’s approach contact: Keith O’Callaghan, +44 207 614 9600, compliance@fqscapital.com.

Privacy Notice

This notice (the Privacy Notice) provides information about how FQS Capital Partners LLP and any affiliated companies within the FQS Group (“FQS”, “we”, “us”, “our”) gather and uses personal information. We are committed to respecting the confidentiality of the personal information you supply to us and all data will be processed in accordance with data privacy laws.

This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read and understand this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect from you

We will collect and use the following personal data about you and your representatives:

Information you give us

This is information about you (and your financial adviser/representative, if applicable,) that you (and/or your financial adviser/representative, if applicable) give us by filling in forms or by corresponding with us by phone, e-mail or otherwise. The information you give us may include name, address, e-mail, address, phone number and identification records.
Details of your company directors, shareholders, authorised signatories and identification documents.
Banking details.
Records of all communications including electronic communications with our staff and meeting notes.
If you have not disabled your cookies, analytic information such as how you use our site, the time and duration of your visit, and how you located our website is collected.

Information we receive from other sources

Verifying your identity – We may use information provided by third parties (e.g. fraud prevention agencies) when verifying your identity and when carrying out anti money laundering checks. Such information may include some details about any criminal convictions and any allegations regarding criminal activity that relate to you, as well as details of your status as a politically exposed person. It may also include your nationality and identification records (e.g. passport information).

Public databases – We may obtain information about you from public databases.

How we use your personal data

Your personal data may be used by us in the following ways:

General uses of information

The information which we collect and what we use it for will depend on the nature of our business relationship with you. We use your information:

To provide you with services which you have requested and to fulfil our contractual obligation towards you;
For our internal business administration and record keeping purposes;
For legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests;

Background checks

To verify your identity as part of our client onboarding process;
In order to detect and prevent fraud and money laundering;
In order to identify politically exposed persons;
In order to assess your risk profile;
Sharing of information with third parties
The company may share your personal data with selected third parties for the purposes of contracts entered into with suppliers, sub-contractors and administrators or to fulfil any legal or regulatory obligations.

It is our duty to ensure all our third parties abide by GDPR protocol.

What are your rights?

Under GDPR your rights as a data subject includes;

Subject to certain circumstances, legal and contractual conditions and the legitimate interests of FQS, you have

The right to request a copy of the personal data about you, which we hold.
To have any inaccurate personal data corrected.
To have your personal data deleted.
To withdraw your consent to processing.
To object to or restrict our use of your personal data.
You may also make a complaint to us or to the relevant data protection authority if you have a concern about our handling of your personal data.

If you wish to do any of the above, please send an email to compliance@fqscapital.com. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.