De Lisle Partners LLP
3 Firs Lane
BH14 8JG

Tel: 020 7074 3572

LIPPER Fund Awards 2014 Winner UK. Money Observer Fund Awards 2014.

The Fund


Name of Fund

VT De Lisle America Fund

Investment Manager

De Lisle Partners LLP, UK

Inception of the Fund

6th August 2010

Constitutional Information

Domicile of the Fund


Legal Structure


Umbrella Fund

The Mulben Investment Funds

Authorised Corporate Director (ACD)/ Administrator

Valu-Trac Investment Management Limited


National Westminster Bank plc


BNY Mellon Trust & Depositary (UK) limited


Johnston Carmichael LLP

Legal Counsel UK

Dickson Minto


Valu-Trac Investment Management Limited


Investment Objectives & Policies

The investment objective of the fund is to achieve a long-term return by investing primarily in equities and other investments in America (and may also invest in Canada).


Borrowings must not exceed 10 per cent of the value of the scheme property.

Portfolio Investments & General Restrictions                     



The fund will invest in predominantly listed securities, typically common stock and American Depositary Receipts (ADRs) listed on US exchanges, including US exchange-traded funds which may invest wholly outside the US. The Fund may invest in collective investment schemes, transferable securities, cash deposits and money market funds as permitted by the FCA.

The investment policy is subject to the limitations set out in Appendix B of the prospectus, save in relation to derivatives.

The fund will not use derivatives.

Fund – Share Classes, Dealing, Fees

Base Currency of the Fund                                      

Pounds Sterling(£)

Classes of Share

There are two types of net accumulation shares available:

  • B Shares (£) denominated in pounds sterling (available to professional/institutional investors also available to retail investors via Independent Financial Advisers)
  • B Shares ($) denominated in United States dollars (available to professional/institutional investors also available to retail investors via Independent Financial Advisers)

Pricing Method

Single forward price

Valuation Point

Daily - 12 noon

Price Publication

Dealing Times

8.30am to 4.30pm






Valu-Trac Investment Management Limited

+44 (0)1343 880217

Minimum Holding



  • B Shares GBP - £100
  • B Shares USD - $100

Initial Charge


Annual Management Charge

  • B Shares GBP - 1%+£12,500
  • B Shares USD - 1%+£12,500

Performance Fee


Total Expense Ratio (TER)

(as at 30th September 2016)




  • B Shares GBP - B3QF3G6
  • B Shares USD - B4X7J42


  • B Shares GBP - GB00B3QF3G69
  • B Shares USD - GB00B4X7J424


The Stewardship Code & Pillar 3

De Lisle Partners LLP (DLP) provides investment management services to two professional clients.

This statement is intended to describe DLP’s approach to the Financial Reporting Council’s (“FRC”) UK Stewardship Code. The publication of this statement is being made in accordance with Rule 2.2.3 R of the FSA’s Conduct of Business Sourcebook.

The UK Stewardship Code (“the Code”) was published by the FRC, the United Kingdom’s independent regulator responsible for promoting high quality corporate governance.  The Code aims to enhance the quality of “engagement” between institutional investors and the companies they invest in.  “Engagement” includes pursuing purposeful dialogue on strategy, performance and the management of risk, as well as on issues that are the immediate subject of votes at general meetings.  In essence, the Code sets out good practice on engagement between institutional investors and investee companies.

The Code sets out seven principles. These are summarised below. 

Institutional investors should:

1. publicly disclose their policy on how they will discharge their stewardship responsibilities

2. have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed

3. monitor their investee companies

4. establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value

5. be willing to act collectively with other investors where appropriate

6. have a clear policy on voting and disclosure of voting activity

7. report periodically on their stewardship and voting activities

The nature of DLP’s business model is such that it does not invest sufficient in a single equity to warrant “engagement”. Accordingly, DLP has taken the view that the Code, and its principles, is not of direct relevance to its business. Consequently, while DLP supports the objectives underlying the Code, it has not committed to the Code on the grounds that it is not directly relevant to its business model.

If the investment strategy of DLP changes in such a manner that the provisions of the Code become relevant, this disclosure will be amended accordingly.

Should you require further information on DLP’s approach to the Code, please contact Richard de Lisle at or telephone 01202 972288.

Pillar 3 Disclosure

This is the Pillar 3 disclosure made in accordance with the UK Financial Conduct Authority (FCA) Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’).

The European Capital Requirements Directive (CRD) created a regulatory capital framework consisting of three ‘pillars’, namely;

  • Pillar 1 – which sets out the minimum capital requirements that firms are required to meet for;
  • Pillar 2 – which requires firms to take a view on whether additional capital should be held against capital risks not covered by Pillar 1; and
  • Pillar 3 - which requires firms to publish certain details of its risks, capital and risk management process.

Disclosure Policy

The rules in BIPRU 11 provide that the firm may omit one or more of the required disclosures if it believes that the information is immaterial. Materiality is based on the criteria that the omission or misstatement of material information would be likely to change or influence the assessment or decision of a user relying on that information for the purposes of making economic decisions. Where the firm considers a disclosure to be immaterial, this will be stated in the relevant section.
The firm is also permitted to omit one or more of the required disclosures where it believes that the information is regarded as proprietary or confidential. Proprietary information is that which, if it were shared, would undermine the firm’s competitive position. Information is considered to be confidential where there are obligations binding the firm to confidentiality with its clients and counterparties.

Where the firm has omitted information for any of the above reasons, a statement explaining this will be provided in the relevant section.

Unless stated as otherwise, all figures contained in this disclosure are based on the firm’s audited annual reports for the year ending January 2016.


These Pillar 3 Disclosures will be reviewed on an annual basis as a minimum. The disclosures will be published as soon as is practical following the finalisation of the firm’s Internal Capital Adequacy Assessment Process (ICAAP) and the publication of its annual reports.


The information contained in this disclosure has not been audited by our firm’s external auditors and does not constitute any form of financial statement.


Our firm’s Pillar 3 Disclosure reports are published on our website.

Scope and Application of Directive Requirements

The disclosures in this document are made in respect of DLP which provides discretionary investment management services.

The firm is a BIPRU firm.

Risk Management Objectives and Policies

Our risk management policy reflects the FCA requirement that we must manage a number of different categories of risk. These include: liquidity, credit, market, interest rate, business and operational risks.

1. Liquidity risk
The firm manages all cash and borrowing requirements to maximise potential interest income whilst ensuring the firm has sufficient liquid resources to meet the continued operating needs of the business.

2. Credit risk
The main credit risk for the firm relates to receipt of fees, being the risk that a client does not pay amounts due for services provided.
The firm’s revenues are annual management charges based on a percentage of assets under management made monthly. These charges are made directly to the funds, and therefore the credit risk relating to this income is minimal.

3. Interest rate risk
The firm has no borrowings and no exposure to interest rate risk.

4. Business risk
The firm’s Pillar 2 business risk assessment principally takes the form of a fall in assets under management following a market downturn that leads to lower management fees, although other risks such as loss of personnel and systems failures are also considered. To mitigate our business risk, we regularly analyse various different economic scenarios to model the impact of economic downturns on our financial position.

5. Operational risk
Operational risk is defined as the potential risk of financial loss or impairment to reputation resulting from inadequate or failed internal processes and systems, from the actions of people or from external events.
Major sources of operation risk include: outsourcing of operations, IT security, internal and external fraud, implementation of strategic change and regulatory non-compliance.

6.Other risks
The firm operates a simple business model.  Accordingly, many of the specific risks identified by the FCA do not apply.

Capital Resources
Pillar 1 Requirement

As a BIPRU Limited Licence Firm, the base capital requirement is Euro 50,000.

Pillar 2

DLP has considered the risks to which it may be exposed and whether additional capital needs to be held to meet those risks.  DLP has taken the view that the base capital requirement of Euros 50,000 is adequate and that no additional capital is required. This is because DLP will be exposed to very few risks.

Regulatory Capital

The main features of DLP’s capital resources for regulatory purposes, as at 31.01.16 are as follows:

Capital item: £000s
Tier 1 capital (called up share capital, share premium account, profit and loss account, externally verified net profits) £107,000
Total of Tier 2 and Tier 3 capital (broadly long and short term subordinated loans) 0
Deductions from Tier 1 and Tier 2 capital 0
Total capital resources, net of deductions £107,000

The firm holds regulatory capital in accordance with the Capital Requirements Directive. All such
capital is classified as Tier 1 capital and is therefore of the highest quality.


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