Regulatory

Regulatory

This Website is presented by Sustainable Development Capital LLP (“SDCL”), a limited liability partnership registered in England and Wales (company no. OC330266).  SDCL’s registered office is at 166 Piccadilly, London W1F 9EJ. If you would like to access the Companies House register please visit their website at www.companieshouse.gov.uk.

 

The information is published in accordance with SDCL’s position as Investment Adviser to Ireland Energy Efficiency Investments PLC. The information contained in this site should not be considered as advice or a recommendation to buy, sell or hold a particular investment. Investment markets and conditions can change rapidly and, as such, views expressed should not be taken as statements of fact, nor should reliance be placed on these views when making investment decisions.

 

The information contained in this site does not constitute an offer of, or an invitation to apply for, securities in any jurisdiction where such offer or invitation is unlawful or in which the person making such offer is not qualified to do so or to whom it is unlawful to make such offer or solicitation. Specifically, any funds described will not be registered under the U.S. Securities Act of 1933, as amended (the “Securities Act”) and, except in a transaction which does not violate the Securities Act or any other applicable U.S. Securities laws (including without limitation any applicable law of any of the States of the U.S.A.) may not be directly or indirectly sold or offered in the United States of America or any of its territories or possessions or areas subject to its jurisdiction or to or for the benefit of a U.S. person.

 

If you are in any doubt about any of the information on this website please consult your financial or other professional adviser.

 

United Kingdom and the rest of the European Union: SDCL is authorised and regulated in the United Kingdom by the Financial Conduct Authority (‘FCA’) to conduct investment business and is subject to the FCA rules.  SDCL is entered in the FCA’s register number 471124.  If you would like to access the FCA register please visit their website at www.fsa.gov.uk/register. The FCA regulates the financial services industry in the UK and is located at 25 The North Colonnade, Canary Wharf, London, E14 5HS.  If you would like further information about the FCA you can visit its website, www.fsa.gov.uk.

 

SDCL is registered for value added tax (VAT) purposes. Its VAT number is 135592209.

 

Asia:  Sustainable Development Capital (Asia) Limited is a joint venture between the SDCL Group and Hong Kong’s First Eastern Investment Group. Its office is at 25th Floor, The Centrium, 40 Wyndham Street, Central, Hong Kong.  It is registered as a private limited company in Hong Kong (company no 1697577).

 

Australia:  SDCL is exempt from the requirement to hold an Australian financial services licence (“AFSL”) under the Corporations Act 2001 (Cth) in respect of financial services, in reliance on ASIC Class Order 03/1099, a copy of which are on the website of the Australian Securities and Investments Commission, www.asic.gov.au.  The class order exempts bodies regulated by the UK Financial Services Authority (“FSA”), such as SDCL, from the requirement to hold an AFSL where they provide financial services to wholesale clients in Australia on certain conditions.  Financial services provided by SDCL are regulated by the FSA under the laws and regulatory requirements of the United Kingdom, which are different to the laws applying in Australia.

 

United States of America: SDCL does not intend to register with the U.S. Securities and Exchange Commission as a broker-dealer. SDCL has a wholly-owned subsidiary, Sustainable Development Capital LLC (“SDCL-US”), a limited liability company formed under the laws of the State of New York, whose place of business is at 75 Rockefeller Plaza, 18th Floor, New York, NY 10019. SDCL-US is a member firm of the Financial Industry Regulatory Authority, Inc. (FINRA) and the Securities Investor Protection Corporation and is authorized by FINRA to engage in private placements of securities, particularly for U.S.-resident clients. In light of the foregoing, SDCL-US is subject to the U.S. Securities Exchange Act of 1934, as amended, regulations promulgated thereunder by the U.S. Securities and Exchange Commission, FINRA rules, and the securities laws and regulations of the respective U.S. state securities authorities.

 

For important disclosures regarding SDCL-US’s Business Continuity Plan, Anti-Money Laundering Program and Privacy of Client Information, we direct you to click on the following link: CLICK HERE

 

This website is not operated, published or maintained by SDCL-US and should not be viewed as a solicitation of investment services and transactions by it.

 

Canada – Quebec:  IMPORTANT NOTICE TO POTENTIAL INVESTORS IN QUEBEC.  SDCL is not registered in Quebec to make trade and all of the assets of SDCL are situated outside of Canada.  SDCL’s head office is in London, United Kingdom and it also has places of business in New York, USA and Hong Kong.  As a result, it may be difficult to enforce legal rights against SDCL.  SDCL’s service agent in Quebec is Fasken Martineau DuMoulin LLP, the Stock Exchange Tower, PO Box 242, Suite 3700, 800 Victoria Square, Montreal, QC, H4Z 1E9.  SDCL is authorised and regulated in the United Kingdom by the Financial Services Authority as an investment adviser and may market “foreign securities” to “permitted clients” in reliance on the international dealers exemption contained in the Canadian Securities Administrators’ National Instrument 31-103 (Registration Requirements and Exemptions).

 

Canada – Ontario: IMPORTANT NOTICE TO POTENTIAL INVESTORS IN ONTARIO.  SDCL is not registered in Ontario to make trade and all of the assets of SDCL are situated outside of Canada.  SDCL’s head office is in London, United Kingdom and it also has places of business in New York, USA and Hong Kong.  As a result, it may be difficult to enforce legal rights against SDCL.  SDCL’s service agent in Ontario is FMD Service (Ontario) Inc., 333 Bay Street, Suite 2400, Bay Adelaide Centre, Box 20, Toronto, ON, M5H 2T6.  SDCL is authorised and regulated in the United Kingdom by the Financial Services Authority as an investment adviser and may market “foreign securities” to “permitted clients” in reliance on the international dealers exemption contained in the Canadian Securities Administrators’ National Instrument 31-103 (Registration Requirements and Exemptions).

 

Canada – British Columbia: IMPORTANT NOTICE TO POTENTIAL INVESTORS IN BRITISH COLUMBIA.  SDCL is not registered in British Columbia to make trade and all of the assets of SDCL are situated outside of Canada.  SDCL’s head office is in London, United Kingdom and it also has places of business in New York, USA and Hong Kong.  As a result, it may be difficult to enforce legal rights against SDCL.  SDCL’s service agent in British Columbia is FMD Service (B.C.) Inc., 2900 – 500 Burrard Street, Vancouver, BC, V6C 0A3.  SDCL is authorised and regulated in the United Kingdom by the Financial Services Authority as an investment adviser and may market “foreign securities” to “permitted clients” in reliance on the international dealers exemption contained in the Canadian Securities Administrators’ National Instrument 31-103 (Registration Requirements and Exemptions).

 

Other jurisdictions: The use of these web-pages in certain jurisdictions may be restricted by law. Persons using these web-pages are required to inform themselves about, and to observe, any such restrictions. These web-pages are not authorised for use in a jurisdiction: (i) where the material herein would be considered an offer to sell or the solicitation of an offer to purchase any securities and where such offer or invitation is not authorised; (ii) where SDCL is not qualified to present this material; or (iii) where the use of these web-pages would result in a requirement for SDCL to register or file with local authorities.

 

Bribery and Corruption:  We recognise the adverse effects that bribery and corruption can have on national economies and society and have taken steps reasonably designed to eliminate bribery of any kind wherever SDCL operates. SDCL Group entities are committed to conducting their businesses fairly, honestly and openly, without the use of corrupt practices or acts of bribery to obtain an unfair advantage.

 

A bribe is any form of inducement made with the intention of influencing any party to do something which is dishonest, illegal or unethical. Bribes can take many forms and include business practices which, depending on the circumstances, may otherwise appear legitimate, including the offer or acceptance of direct or indirect payments, services, gifts, charitable donations, sponsorships or preferential treatment.

 

We have zero tolerance to bribery and corruption and have developed policies and procedures reasonably designed to prevent them, these include:

 

Prohibiting staff from paying or accepting any fee or commission or non-monetary benefit in relation to business carried out for a client if this is likely to impair the Group’s duty to act in the best interests of its client.

 

Investigating all instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution.

 

Prohibiting payments either directly or through any third party that might be interpreted as a bribe.

 

UNITED NATIONS ENVIRONMENT PROGRAM – FINANCE INITIATIVE (UNEP FI)

 

Sustainable Development Capital LLP is a member of the UNEP FI Property Working Group (PWG). Its purpose is to encourage property investment and management practices that achieve the best possible environmental, social and financial results.

 

SDCL aims to comply with the recommendations of the PWG in all its activities.

 

The Property Working Group strives to encourage sustainability in property finance.

 

Aims of the Property Working Group:

 

  • Promoting and encouraging Responsible Property Investment by assembling evidence to show how it can protect or enhance financial returns throughout the lifecycle of buildings while simultaneously reducing negative environmental and social impacts;
  • Demonstrating clearly how the principles of Responsible Property Investment can be applied to property assets, portfolios and financing;
  • Working autonomously or with others to develop tools and mechanisms, such as appropriate measurement regimes, or ‘how to’ toolkits, etc. to develop and promote best practice in property investment organizations;
  • Liaising with policy-makers in establishing the appropriate policy and regulatory environments for Responsible Property Investment practices to flourish; and
  • Being a centre of excellence on Responsible Property Investment by facilitating access to, relevant information, best practice and expertise.

 

Assisting property investors and property fund and asset managers in adopting Responsible Property Investment (RPI) practices is an ongoing area of PWG work. PWG has recently finished a ‘toolkit’ series that informs concerned managers who wish to pursue RPI practices about the next best things they can do. The group will continue to assemble and share best practices from across the globe on all manner of responsible property investment and asset and property management.

 

PWG will also enforce the involvement in policy development and explore public and private financing mechanisms for energy efficiency (EE) retrofit market: PWG are set to undertake a project with a view to explore drivers and barriers of capital into commercial and residential EE retrofit market.

 

The group will continue to focus on the field of common metrics for property ESG performance: Main areas of work will include furthering the debate around property environmental analysis, identifying approaches to integrating environmental metrics into investment performance analysis, and promoting active engagement of property investment industry in the design of environmental metrics.

 

Bribery & Corruption: SDCL (the “Firm”) is committed to ensuring that it, its partners, employees, agents and anyone contracted to it comply with the requirements of the UK Bribery Act 2010.

 

The Firm is committed to conducting its business fairly, honestly and openly, and has a zero-tolerance approach towards bribery and corruption.

 

The Firm has implemented a risk-based approach to identify areas where it may be at risk to bribery and has put in place systems and procedures to reduce and manage this risk. It reserves the right not to deal with other entities that do not make the same commitment.

 

The Firm has adopted and implemented a number of policies and procedures which are intended to prevent the Firm, its partners, staff or agents being involved in bribery. These are reviewed regularly to ensure they remain effective.

 

For further information on the Firm’s bribery risk policies and procedures please contact the Compliance Officer, to whom the partners have given day-to-day responsibility for ensuring that the Firm’s anti-bribery policies and procedures are adhered to.