Legal Notice / Disclosures

The information on this site is issued by CORDET Capital Partners LLP (“CORDET”), an Alternative Investment Fund Manager (AIFM), whose registered office is at 4th Floor, Reading Bridge House, George Street, Reading, Berkshire, RG1 8LS. CORDET is registered in England and Wales with company number OC385212.

The information contained on (the “Website”) is not intended to be construed as an offer, inducement, invitation to engage in investment activity, or investment advice or recommendation, in respect of any funds, managed accounts or any similar investment products which may be managed or advised by CORDET, and should not be relied upon as such by any person. You are encouraged to seek individual advice from your personal, financial, legal and other advisers before making any investment decision.

The information contained on the Website is provided for general information for persons in the UK, is not comprehensive and has not been prepared for any other purpose.

Please read the terms below carefully before using this Website. By using or visiting this Website you accept and agree to the terms of this legal notice. If you do not accept these terms, do not use this Website.

Updates CORDET may revise this legal notice at any time by updating this posting. You should check this Website from time to time to review the current legal notice because it is binding on you.

Risk Considerations

You should remember that the value of investments, and the income from them, may go down as well as up, and is not guaranteed, and investors may not get back the amount of money invested. Past performance cannot be relied on as a guide to future performance. Exchange rate changes may cause the value of overseas investments or investments denominated in different currencies to rise or fall.

These are not all the risks of an investment in CORDET. Investors should take advice from their own independent, professional financial advisers before making an investment decision and are responsible for ascertaining any income tax or other tax consequences which may affect their acquisition of any investment.

Access CORDET shall not be liable if for any reason this Website is unavailable at any time or for any period. CORDET reserves the right to make changes or corrections, alter, suspend or discontinue any aspect of the Website including, but not limited to, the content available through the Website and your access to it.

Acceptable Use You must not use the Website for any unlawful or fraudulent purposes. You must not misuse the Website by introducing viruses, Trojans, worms, logic bombs or other material which is malicious or technologically harmful. In particular, you must not interfere with, damage or disrupt the Website or any part of it, any equipment or network on which the Website is stored or any software used in connection with the provision of the Website. You must not attack the Website via a denial-of-service attack.

While CORDET takes reasonable care to minimise the risk of viruses and technological harmful material existing on our Website, use of this Website is made at your own risk. Accordingly, CORDET will not be liable for any loss or damage caused by viruses, a distributed denial-of-service attack or any other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Website or to your downloading of any material posted on the Website, or on any website linked to it.

Without prejudice to its other rights or remedies, CORDET reserves the right to take legal proceedings against you for reimbursement of all costs and losses (on an indemnity basis) resulting from your breach of the obligations in this “Acceptable Use” section, and to disclose such information to law enforcement agencies as CORDET reasonably believes is necessary.

Accuracy of Information CORDET and its employees and affiliates shall not be liable for any direct or indirect loss of revenue, profit, business, data, goodwill or anticipated savings, or for any indirect, special or consequential loss or damages, suffered as a result of reliance on any information or omission on, or the use of, this Website, or for the risks inherent in financial markets.

To the maximum extent permitted by applicable law and regulatory requirements, CORDET specifically disclaims liability for any errors, inaccuracies and omissions on the Website and for any loss or damage resulting from its use, whether caused by negligence or otherwise. You agree to assume responsibility for determining whether any legal or regulatory considerations limit access to or use of information, services or products described on the Website and for the use of any information on the Website.

Nothing in this legal notice shall exclude or limit CORDET’s liability for a) death or personal injury caused by negligence (as such term is defined by the Unfair Contract Terms Act 1977); or b) fraud or fraudulent misrepresentation; or c) any liability which cannot be excluded or limited under applicable law.

Linked Websites The Website may contain or be linked to websites, advice or statements of third parties and such links are for information purposes only. CORDET makes no representation as to the accuracy or timeliness of such information, and has not reviewed and will not review such information. Any use of such information is made at your own risk. The inclusion of a link to a third party website does not constitute an endorsement of that third party’s website or an endorsement of any products or services that may be advertised on that third party’s website. CORDET does not take responsibility for the contents of such other websites and any use of such websites is made at your own risk.

Sales Restrictions Access to the information contained within this Website may be restricted by laws and regulations applicable to the user. The information in this Website does not constitute either an offer to sell or a solicitation or an offer to buy in a country in which this type of offer or solicitation is unlawful, or in which a person making such an offer or solicitation does not hold the necessary authorisation to do so, or at all. Accordingly, persons accessing the information on this Website are responsible themselves for ascertaining the legal requirements which would affect their acquisition of any investment, including any foreign exchange control requirements.

Financial Promotion Restrictions This Website has not been approved for the purpose of Section 21 of The Financial Services and Markets Act 2000 (”FSMA 2000”). This Website is directed in the UK only at persons to whom financial promotions can be made under the FSMA 2000 (Financial Promotion) Order 2005 (“the Financial Promotions Order”), such as:

(a) persons who have professional experience in matters relating to investments and who are investment professionals as specified in article 19(5) of the Financial Promotions Order;

(b) high net worth companies, unincorporated associations and other persons who fall within the provisions of article 49 of the Financial Promotions Order; and

(c) persons who can be classified as Professional Clients under FCA rules.

If you are not such a person, you should not read the content of this Site, rely on it or take any other action in consequence of it.

If you are a person located in any jurisdiction where there are restrictions on the type of person who may access information which relates to investments then, in accessing this site, you will be representing and warranting to CORDET that you are not causing CORDET to breach any of those restrictions by you accessing this site. CORDET will rely on your representations and warranties.
Intellectual Property Rights Copyright CORDET 2014. The contents of this Website are protected by international copyright laws and other intellectual property rights. All copyright, trade marks, designs, patents, intellectual and other property rights in the information contained herein or otherwise on this Website, are owned by CORDET, its affiliates or their respective third party licensors. No rights of any kind are licensed or assigned or shall otherwise pass to persons accessing this information. You are permitted to print and download extracts from this Website only for your personal reference in connection with use anticipated by this Website, and only provided that:

no documents or related graphics on this Website are modified or copied in any way;
no graphics on this Website are used separately from accompanying text; and
the status of CORDET (and that of any identified contributors) as the author of any material on this Website is always acknowledged.
Otherwise, no part of this Website may be reproduced or stored, modified, copied, republished, uploaded, posted, transmitted or distributed, by any means or in any manner, or included in any other website or in any public or private electronic retrieval system or service including but not limited to text, graphics, video, messages, code and/or software without our express prior written consent. Any commercial use or exploitation of this Website or its content is strictly prohibited. If you breach any of the terms in this legal notice, your permission to use this Website automatically terminates and you must immediately destroy any downloaded or printed extracts from this Website.

Governing Law and Jurisdiction This legal notice and any dispute or claim arising out of or in connection with it or its subject matter, whether of a contractual or non-contractual nature, shall be governed by and construed in accordance with the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this legal notice.

UK Stewardship Code and Shareholder Rights Directive Disclosure

The FCA’s Conduct of Business Sourcebook rule 2.2.3R requires CORDET Capital Partners LLP (”CORDET”) to make a disclosure regarding the nature of its commitment to the UK Stewardship Code 2020 (“the Code”) issued by the Financial Reporting Council. Similarly COBS 2.2B.5R requires CODET to make a disclosure regarding its approach to its engagement policy under the EU Shareholder Rights Directive (“SRDII Code”). Both codes are voluntary and set out a number of principles relating to stewardship and engagement by firms over asset classes invested in. Where firms do not commit to these codes then a disclosure on why it has chosen not to comply along with its alternative strategy should be made.

CORDET is an alternative credit specialist offering responsible private capital to smaller mid-market companies in Northern Europe, and credit investment management for institutional investors. We note the contents of the 2020 Stewardship Code but do not believe it is appropriate to the Code at this time. CORDET is monitoring communications from our regulator, the FCA, on how they intend to impose further stewardship requirements on asset managers as the new Code takes effect. The FCA has confirmed it will not be imposing further stewardship related requirements on asset managers at this point. Therefore, whilst the firm readily supports the objectives of the Code, it believes that it is not appropriate to conform to the Code until such time as the FCA issues further guidance. The firm is currently in the process of implementing relevant aspects of the Sustainability Finance Disclosure Regulation (SFDR), which we believe is similar in scope and intent to the Stewardship Code. Further the firm already has in place a range of bespoke practices that result in effective stewardship which has been factored into its own investment due diligence and monitoring process to oversee investments.

In terms of the SRDII Code, CORDET does not comply with this since the focus is on investment managers who invest in shares traded on a regulated market.


Remuneration Disclosure – MIFIDPRU 8.6


CORDET is subject to the FCA Rules on remuneration as they apply to a small and non-interconnected (SNI) MIFIDPRU investment firm. These are contained in the FCA’s MIFIDPRU Remuneration Code located in SYSC19G of the FCA’s Handbook.

Approach to Remuneration for all staff

Employees have the opportunity to share in the success of the Company in years of good performance and also accept reduced levels of variable (bonus) pay in times of poor performance or losses.

CORDET does not remunerate or assess the performance of its staff in a way that conflicts with its duty to act in the best interests of its clients.

CORDET does not make any arrangement by way of remuneration, sales targets or otherwise that could provide an incentive to its staff to recommend a particular financial instrument to a client when the firm could offer an alternative financial instrument which would better suit the client’s needs.

CORDET is mindful of ensuring that its remuneration policy and practices do not lead to a conflict of interest or incentivise its staff to act in a manner that favours their own interests or the firm’s interests to the potential detriment of any client or potential client.

Objectives of financial incentives

CORDET’s Remuneration Policy provides a framework to ensure all staff are fairly and competitively rewarded in return for a high level of service to the firm and is clients. In setting remuneration levels CORDET recognises the importance of attracting and retaining experienced staff. The amount of fixed remuneration paid to an employee will be based on market rates relevant to the employee’s role and their knowledge, experience, and competencies. Discretionary bonuses are made to employees to reward them for good performance with a view to increasing and maintaining their productivity.

Decision Making

LLP Management Committee shall be responsible for the implementation of this policy as well as the monitoring of compliance risks associated with it. Additionally, the Compliance Officer conducts regular monitoring to assess the policy’s implementation within the firm’s operations.

Characteristics of Remuneration Policy and Practices

Remuneration typically comprises of fixed and variable elements. Fixed remuneration consists of base salary, pension contribution and other benefits such as defined contribution pension, private medical insurance, which constitutes the fixed payment made to an employee for their services.

CORDET has defined variable pay as annual discretionary bonus, which is awarded based on company performance, departmental performance and individual performance. CORDET’s policy on variable remuneration is to set aside a proportion of the firm’s profits to form a bonus pool out of which awards will be made. The total bonus pool amount is determined by reference to the Company’s risk-adjusted criteria, which include both quantitative and qualitative measures.

The firm will ensure that remuneration and similar incentives will not be solely or primarily based on quantitative commercial criteria. Consequently, the firm will take into account appropriate qualitative criteria (i.e., behavioural measures such as customer feedback) which shall encompass adherence with relevant regulations, fair treatment of clients and the quality of services provided to clients.

CORDET ensures it always maintains a balance between fixed and variable components of remuneration, so as to mitigate any conflicts of interest between the firm, its staff and its clients.

Remuneration for year ending 30 April 2023

Staff remuneration (GBP)

Fixed remuneration: 373,000

Variable remuneration: 339,000

Total remuneration: 712,000