You should contact us immediately if you are dissatisfied with any aspect of the investment services provided to you by Aleph Capital Partners Limited (“Aleph” or “the Firm”). Please write to the Compliance Officer, 14 St George Street, London W1S 1FE. We take every complaint seriously and your complaint will be handled in accordance with the relevant FCA rules, which may differ depending upon your status although note that it is Aleph’s policy to aim to resolve every complaint fairly and in a timely manner. Aleph has a written internal complaints handling policy, as required by the FCA rules. You can obtain a copy of this on request, and in the event you should have cause for complaint about the investment services which Aleph provides to you, a copy of the policy will be sent to you. 

In the event we fail to resolve a complaint to your satisfaction, or if we fail to do so within eight weeks of receiving your complaint, you may also be entitled to refer your complaint to the Financial Ombudsman Service at Exchange Tower, Harbour Exchange Square, London, E14 9SR. Telephone: 0800 023 4 567 or at


UK Stewardship Code (2020) Disclosure Statement

Effective from 1 January 2020, the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”) has been substantially updated to be applicable to a broader range of investment strategies, other than purely listed equity, such as fixed income bonds, real estate and infrastructure.  It also reflects the growth of environmental factors, particularly climate change, as well as social and governance factors (together, “ESG”) as material issues for asset managers to consider when making investment decisions and undertaking stewardship.

In the 2020 version, the Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society”.

The Principles of the Code
There are twelve Principles of the Code that apply to asset owners and asset managers. These are grouped under four headings:

Purpose and governance

  1. Purpose, strategy and culture
  2. Governance, resources and incentives
  3. Conflicts of interest
  4. Promoting well-functioning markets
  5. Review and assurance

Investment approach

  1. Client and beneficiary needs
  2. Stewardship, investment and ESG integration
  3. Monitoring managers and service providers


  1. Engagement
  2. Collaboration
  3. Escalation

Exercising rights and responsibilities

  1. Exercising rights and responsibilities

The FRC requires that firms aiming to be signatories to the Code must produce an annual Stewardship Report explaining how they have applied the Code in the previous 12 months. The FRC will evaluate Reports against an assessment framework and those meeting the reporting expectations will be listed as signatories to the Code.

FCA Regulatory Disclosure on the Stewardship Code 

Rule 2.2.3R of the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (“COBS”) requires an FCA authorised firm to disclose the nature of its commitment to the FRC’s UK Stewardship Code or, where it does not commit to the code, its alternative investment strategy. 

Adherence to the Code is voluntary. 

The Firm has chosen not to commit to the code because:

  • The Firm has chosen an alternative approach to stewardship consistent with its overall approach to ESG/sustainable finance/responsible investment
  • The Firm determines its approach to stewardship on a case by case basis taking into account the best approach to optimising the returns on its investments

Consequently, while Aleph generally supports the objectives that underlie the Code, the provisions of the Code are not considered to be relevant to the activities currently undertaken by the Firm. If Aleph’s activities change in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.

For further details on any of the above information, please contact the Compliance Officer.


MIFIDPRU 8 Disclosure

July 2023


The Financial Conduct Authority (“FCA” or “regulator”) in the Prudential sourcebook for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Aleph. Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which the Firm must comply, further to those prudential requirements. 

Aleph is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.

The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture and to assist stakeholders in making more informed decisions about their relationship with the Firm.

This document has been prepared by Aleph in accordance with the requirements of MIFIDPRU 8 and is verified by the Governing Body. Unless otherwise stated, all figures are as at the Firm’s 31 December financial year-end.

Remuneration Policy and Practices Overview

As an SNI MIFIDPRU Investment Firm, Aleph is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of the remuneration requirements is to:

  • Promote effective risk management in the long-term interests of the Firm and its clients;
  • Ensure alignment between risk and individual reward;
  • Support positive behaviours and healthy firm cultures; and
  • Discourage behaviours that can lead to misconduct and poor customer outcomes.

The objective of Aleph’s remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients. 

In addition, Aleph recognises that remuneration is a key component in how the Firm attracts, motivates, and retains quality staff and sustains consistently high levels of performance, productivity, and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and provide its greatest competitive advantage.

Aleph is committed to excellence, teamwork, ethical behaviour, and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude, and results. 

Characteristics of the Firm’s Remuneration Policy and Practices

Remuneration at Aleph is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance and the financial and non-financial performance of the individual in contributing to the Firm’s success. All staff members are eligible to receive variable remuneration.

The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.

Governance and Oversight

The Governing Body is responsible for setting and overseeing the implementation of Aleph’s remuneration policy and practices. In order to fulfil its responsibilities, the Governing Body: 

  • Exercises competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital, and liquidity.
  • Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm
  • Ensures that the Firm’s remuneration policy and practices take into account the long-term interests of shareholders, investors, and other stakeholders in the Firm
  • Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of the Firm and of its clients.

Aleph’s remuneration policy and practices are reviewed annually by the Governing Body.

Quantitative Remuneration Disclosure

For the financial year ended 31 December 2022, the total amount of remuneration awarded to all staff was £3,386,000, of which £1,462,000 comprised the fixed component of remuneration, and £1,924,000 comprised the variable component. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the Firm itself, directors and employees of other entities in the group.