P1 Investment Management Limited is authorised and regulated by the Financial Conduct Authority under registration number 752005. You can verify these details on the Financial Services Register.

The information contained within the website is subject to the UK regulatory regime and is therefore targeted at customers in the UK.

We would like to bring your attention to the following sections of this page:

Treating Customers Fairly
Client Identification
Conflicts of interest
Best Execution
Financial Resource Requirements
Remuneration Code
Stewardship Code
Shareholder Rights Directive II
Platform Information
Company Information

Treating Customers Fairly
Treating our clients fairly is at the heart of our business. We always aim to always put our clients’ interests above our own and our approach is explained in our statement on Treating Customers Fairly, which is approved and endorsed by the main board of P1 Investment Management.

Our Complaints Procedure
We truly hope that you will be delighted by the service you receive from P1 Investment Management, but explain how we will handle any complaints we receive in our Complaints Procedure document. We value all feedback in helping us to improve our service to clients.

You should address complaints to:
Paul White
Compliance Director
P1 Investment Management Limited
Senate Court
Southernhay Gardens
Email: [email protected]
Telephone: 01392 429683

If we are unable to resolve your complaint, you may be able to refer the matter to the Financial Ombudsman Service. The Financial Ombudsman Service is free to use and you can read more about the service they provide on The Financial Ombudsman website.

Where we have a direct relationship with you as our client (your financial adviser will tell you if this applies) and we deal with you only by electronic means, you can use the Online Dispute Resolution Platform as an alternative to using the Financial Ombudsman Service.

Client Identification
We have responsibilities to verify the identity and permanent address of our clients under UK anti-money laundering legislation. We use online verification systems, such as Smartsearch and Onfido to establish our clients’ identity, which uses information obtained from Credit Reference agencies and other trusted sources. You can read further information about electronic searches here.

Conflicts of Interest
P1 Investment Management is required by the Financial Conduct Authority to maintain a conflicts of interest policy identifying the circumstances that constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more clients, and specifying the procedures that we follow and measures that we adopt in order to manage such conflicts. You can read our Conflicts of Interest Policy and contact our Compliance Department if you have any questions.

Best Execution
It is in the interests of our clients and P1 Investment Management Limited that we obtain the best possible result when placing orders with other firms for the execution of client orders or when transmitting orders on behalf of clients. We are required under the Rules of the Financial Conduct Authority to take all reasonable steps to provide Best Execution when carrying out transactions and have published our Best Execution Policy that we have adopted to achieve that objective.

We are required to publish a report each year on the third-parties used to execute client orders. You can view our latest Annual Best Execution Report on this link.

You can review the Order Execution Policy for the P1 Platform here.

Financial Resource Requirements (Pillar 3 Disclosure)
P1 Investment Management publishes our Pillar 3 Disclosure Statement, in accordance with the UK Financial Conduct Authority (FCA) Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’).

Remuneration Code Statement
P1 Investment Management is subject to the BIPRU Remuneration Code. The Remuneration Code Statement provides further information on our remuneration policy.

Stewardship Code Statement
As a UK-based asset manager, P1 Investment Management has a duty to act in the best long-term interests of its clients and is committed to achieving this. The Stewardship Code is overseen and published by the Financial Reporting Council, an independent regulator overseeing financial reporting, accounting and auditing and corporate governance. The Code sets the benchmark for institutional investors to meet ownership obligations in respect of UK companies. P1 Investment Management is reviewing current practice against the requirements of the 2020 Code. P1 Investment Management manages the assets of retail investors; we have a limited number of institutional investor clients. However, we think it is in the interests of our clients that we disclose our policy in terms of how we exercise voting rights relating to investments held on their behalf. For such clients, as appropriate, P1 Investment Management may seek to engage and vote on any issue affecting the long-term value of a company in which we have invested on our clients’ behalf. However, as explained in the section below, the extent to which we have the opportunity to engage with investee companies is limited.

Shareholder Rights Directive II
The Shareholder Rights Directive II (SRDII) is a European Union directive, which sets out to strengthen the position of shareholders and to ensure that decisions are made for the long-term stability of a company. P1 Investment Management Limited are required by this Directive to explain whether or not we have an engagement policy in relation to the companies we invest in, where the companies’ shares are admitted to trading on a regulated market. As the proportion of shares we hold in investee companies is much lower than those held by large institutional investors, we do not have the opportunity to engage with investee companies to the extent envisaged by SRD II. Accordingly, we do not have an engagement policy.

Platform Information
P1 Investment Management is the operator of the P1 Investment Platform. Important information regarding the Platform can be found here.

Company Information
P1 Investment Management is registered in England, registration number 09810560. Registered Office: Senate Court, Southernhay Gardens, Exeter, Devon, EX1 1NT.

A list of directors is available for inspection at the Registered Office. Please refer to the Who we are section of this website.
VAT No. 231 9416 20