Statement on modern slavery and human trafficking

Introduction

This statement is made by Qube Research & Technologies Limited on behalf of itself and other relevant QRT group affiliates (“QRT”) pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”) and in respect of the financial year ended 31 December 2018.

Business and Organisational Structure

QRT is a quantitative and systematic investment manager with offices in Hong Kong, London, Mumbai and Paris. QRT is a technology driven firm implementing a scientific approach to financial investment. QRT’s market presence is global and expands across the largest liquid electronic venues. The ultimate holding company of QRT is controlled by Partners involved in the day-to-day activities of the group.

Qube Research & Technologies Limited is a UK limited company that is authorised and regulated by the UK Financial Conduct Authority.

Supply Chain and Staff Awareness

We have a robust recruitment and onboarding process with multiple checks built in to ensure all individuals employed by us have the right to work in the UK, are paid a fair salary in compliance with all relevant rules and regulations, and are not subjected to human trafficking or forced labour. Further, we maintain a reputation for conducting our business activities in the highest ethical and professional manner. All employees are expected to comply with our Code of Conduct which sets out basic principles designed to guide our employees, officers and directors. All employees, officers, and directors must conduct themselves in accordance with this Code and seek to avoid even the appearance of improper behaviour. Our employees have a personal responsibility to immediately report illegal or unethical behaviour.

We pride ourselves on our reputation for conducting our business activities in the highest ethical and professional manner and we expect all of our suppliers to adhere to these same standards and principles.

QRT expects all third party providers to adhere to all applicable laws in conducting their businesses and to operate a fair and ethical workplace for their staff. QRT will contact its key suppliers from time to time to reinforce the message that it will not tolerate modern slavery or human trafficking within its supply chain.

Approval

The Board of Directors of Qube Research & Technologies Limited approved this statement on 25 April 2019.

UK Stewardship code statement

As a UK authorised investment management firm, Qube Research and Technologies Limited (the “Firm”) is required under the FCA’s Conduct of Business Rules to include on its website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance and state in general terms its alternative investment strategy.

The seven principles of the Code are that institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
  • Monitor their investee companies;
  • Establish clear guidelines on when and how they will escalate their activities;
  • Be willing to act collectively with other investors where appropriate;
  • Have a clear policy on voting and disclosure of voting activity; and
  • Report periodically on their stewardship and voting activities.

The Firm provides investment management services to funds that pursue investment strategies that involve investing in a wide range of securities and instruments without limitation in various jurisdictions. If the Firm were to invest directly in UK single equities, these would represent only a small part of the Firm’s business. However, the Firm trades on algorithms which buy/sell equity positions rapidly and therefore does not typically hold positions for periods of time which would require engagement with issuers or their management. Hence, while the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The Firm takes a consistent approach in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. If the Firm’s approach changes in the future, the Firm will review its commitment to the Code and update this disclosure accordingly.

For further information on the Firm’s approach to the Code, please contact claire.jarrett@qube-rt.com


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