Disclosure Document

Disclosures pertinent to all Clients

RAW Capital Partners Limited (the “Manager”) was incorporated in September 2012 and has been licensed and regulated by the Guernsey Financial Services Commission under the Protection of Investors Law since January 2013. GFSC Reference: 2101792. 

Financial Advice

The Manager does not provide financial advice to Retail Investors as defined in the Licensees (Conduct of Business) Rules (2021).

Data Protection

The Manager will share client data with other group companies and third-party contractors as required for those parties to perform their duties. We do not share data with external marketing companies or organisations. See detailed Privacy Statement.

Investment Risks

Neither RAW Capital Partners nor the RAW Mortgage Fund are deposit taking institutions or offer a capital guarantee. Any investment in the Fund is not covered by the Guernsey Banking Deposit Compensation Scheme.

Past performance is not necessarily a guide to future performance and may not be repeated. Target returns cannot be guaranteed and the value of an investment may go down as well as up. The information contained in this document does not constitute an offer to sell or a solicitation to buy an investment, nor should it be construed as investment advice. It is recommended that potential investors take appropriate professional tax and/or investment advice before making any investment.

Currency Risk

Investments assets of the RAW Mortgage Fund are GBP denominated. Foreign currency investments may be accepted but, depending on share class, will be converted to sterling investment or hedged using appropriate instruments. Further details may be found in the Fund Prospectus.

Suitability

Investments may not be appropriate for everybody.  The risks of investing in the RAW Mortgage Fund are outlined here.

Technology Risks and Business Continuity

The Manager is reliant on access to systems and the internet to operate normally. Disruption to communications may cause delays which may impact on performance. The Manager has various contingencies in place to mitigate such risks but it is impossible to eliminate all such risks. The investment industry is seeing an increasing incidence of cyber-attacks on business. It is possible that such an attack on the Manager could disrupt our ability to manage assets in the way it would otherwise wish.

The Manager seeks to mitigate the technology risks through the outsourcing of its IT support requirements to a specialist company that implements industry standard firewalls, virus protection and data back-up.

Fraud Risk

The Manager and other counterparties may be the subject of attempted fraud. Such fraud could potentially occur against the Manager or other service provider impacting on the ability of that company to operate or even remain solvent.

The Manager has financial controls in place to help prevent fraud which include having a limited number of authorised signatories to its accounts and every transaction requiring two authorised signatories to be approved. The accounts of the Manager are audited each year.

Conflicts of Interest

From time to time it is possible that the manager has conflicts of interest. The Manager’s policy on dealing with conflicts of interest is “that the Company and staff must seek to avoid or manage conflicts of interest. Where a conflict arises, staff should ensure fair treatment to all its Clients by disclosure, internal rules of confidentiality, declining to act, or otherwise. Staff should not unfairly place its interests above those of its Clients and, where a properly informed Client would reasonably expect that the firm would place his interests above its own, the Company should live up to that expectation.”

Client Monies

Client Monies may be held in a designated Fund or client account when not invested. Clients will not receive interest or investment returns on any balance held in the Fund or client account before dealing or after redemption/maturity.

Where client transactions result in an amount of £20 or less remaining on the client account, for example after the purchase of shares, this amount (or higher if relevant bank charges would negate the benefit) will not be returned to the client and will be for the benefit of The Manager.

Where funds are being returned to a client, they will only be returned to an account in the name of the client. No third-party payments will be made.

Collection of Fees

Fees will be calculated in accordance with the Fund Prospectus or client agreement. 

Complaints Procedure

Client complaints should be made in writing and sent by email to [email protected]. All complaints should include the Client name and Account number. All Client complaints will be referred to the Compliance Officer and Clients should receive an initial response within 2 working days.

Definitions

Client – a person entering in to an agreement with the Manager.

Eligible Counterparties - any entity licensed for Dealing, Managing or Advising under POI Law; a bank, insurance company or collective investment scheme; a pension scheme or its management company; other similar entity.

Professional Investors – a person who - regularly invests in collective investment schemes, company shares or other private investments of such size that they can reasonably be expected to understand the risks involved of such transactions; provides a certificate from a financial advisor indicating that he has obtained independent financial advice; has been a non-clerical employee of a professional investor firm for more than 3 years.

Retail Investors - a client who is not a Professional Client or an Eligible Counterparty.

Terms – Terms and Conditions outlined for example in the Fund Prospectus, term sheet or other agreement.

March 2023