Legal and Regulatory Notices
Legal Notice
The information contained on this website (the "Site") has been prepared by Triton Investment Management Limited ("Triton"), registered in Jersey with Company Registration Number 120654 and whose registered office is at 5/6 Esplanade, 1st Floor, St. Helier, Jersey, JE2 3QA. The information contained on this Site is for informational purposes only. It should not be regarded as an offer, invitation, inducement or general solicitation to buy or sell any investments or securities, engage in investment activity (including providing advisory services), to engage in any transaction or to otherwise do business with Triton and should not be relied upon for any reason whatsoever. The Site is believed by Triton to be accurate and correct but Triton does not accept responsibility for any such information and accordingly Triton accepts no responsibility to any person for the accuracy of the information contained on the Site or for the consequences of any person placing reliance on the content of the Site for any purpose. .Any reference to any product or service which has been or may be provided by Triton, West Park or any other company does not amount to a promise that such product or service will be available at any time. Changes to or improvements in such products or services may be made at any time without notice.
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Updates
Triton may revise this legal notice at any time by updating this posting. You should check this Site from time to time to review the current legal notice because it is binding on you.
Access
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Acceptable Use
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While Triton takes reasonable care to minimise the risk of viruses and technological harmful material existing on our Site, use of this Site is made at your own risk. Accordingly, Triton 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 Site or to your downloading of any material posted on the Site, or on any website linked to it.
Without prejudice to its other rights or remedies, Triton 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 Triton reasonably believes is necessary.
Accuracy of Information
Although Triton endeavours to ensure that the information contained within this Site is accurate at the time of publication, no representation or warranty is made as to its accuracy or completeness or fitness for any purpose. Statements contained on this Site are based on expectations, estimates, projections, opinions and/or beliefs of Triton as of the date of such information or as of the specific date(s) noted therein (as applicable). The Site may contain typographical errors or other inaccuracies, or information that is out of date. None of Triton or its affiliates, members, partners, stockholders, managers, directors, officers, employees or agents is under any obligation to update such material. The information and opinions contained in this Site are provided by the Triton for personal use and informational purposes only. You are solely liable for any use you may make of this information. The information is inherently subject to change without notice and may become outdated. You, therefore, should verify any information obtained from this Site before you use it.
The material on this Site is provided "as is", without any conditions, warranties or other terms of any kind. Accordingly, to the maximum extent permitted by law, Triton provides you with this Site on the basis that Triton excludes all representations, express or implied warranties, conditions and other terms which but for this legal notice might have effect in relation to this Site.
No Advice
You should not rely on any information or opinions contained in this Site in making an investment or other decision; rather, you should obtain relevant and specific professional advice. Nothing contained on this Site constitutes or should be construed to constitute investment, legal, tax or other advice, and you should consult your own attorney, business advisor or tax advisor, as applicable. The information contained on this Site shall in no way be construed to constitute a recommendation with respect to the purchase or sale of any investment.
Liability
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Nothing in this legal notice shall exclude or limit Triton'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 Site may contain or be linked to websites, advice or statements of third parties and such links are for convenience and informational purposes only. Triton is not responsible for the content of any linked websites and, therefore, 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. Triton does not guarantee that any linked websites on this Site will be free from infection, viruses or worms or other code which may have contaminating or destructive properties. You are fully responsible for ensuring protective steps are taken such as virus checking. You should be aware that the Internet, being an open network, is not secure. Triton does not take responsibility for the contents of such other websites and any use of such websites is made at your own risk.
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If you breach any of the terms in this legal notice, your permission to use this Site automatically terminates and you must immediately destroy any downloaded or printed extracts from this Site.
Communications
As part of our compliance with applicable laws and regulations, we reserve the right to record, monitor and store all electronic communication, including certain telephone and video conversations, with Triton Debt Opportunities personnel. Please note that telephone or video recordings may be made without the use of a spoken warning, tone or similar notification.
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 Jersey. The courts of Jersey shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this legal notice.
The Jersey Financial Services Commission is protected by the Collective Investment Funds (Jersey) Law 1988 and the Financial Services (Jersey) Law 1998 against liability arising from the discharge of its functions under those Laws. For more information about the Commission and regulation in Jersey please see http://www.jerseyfsc.org.
Triton Administration (Jersey) Limited is regulated by the Jersey Financial Services Commission in the conduct of trust company business under the Financial Services (Jersey) Law 1998. Company Registration Number: 102111.
Triton Investment Management Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 120654.
Triton Managers II Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 89128
Triton Managers III Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 98417
Triton Managers IV Limited as general partner of Triton Fund IV General Partner L.P. is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 108796
Triton Debt Opportunities Managers Limited as general partner of Triton Debt Opportunities Fund I General Partner L.P. is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 106165
Triton Smaller Mid-Cap General Partner Limited as general partner of Triton Smaller Mid-Cap General Partner, L.P. is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 121832.
Triton Value Fund Managers Limited as general partner of Triton Value Fund General Partner L.P. is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 116793.
TFF Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 99107.
TFF (TSM) Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 124691.
TFF III Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 101339.
TFF IV Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 110817.
TFF V Limited is regulated by the Jersey Financial Services Commission in the conduct of fund services business under the Financial Services (Jersey) Law 1998. Company Registration Number: 125816.
Triton Investments Advisers LLP is authorised and regulated by the Financial Conduct Authority. Company Registration Number: OC374555, Firm Reference Number 586570.
Legal notice 2
The number of institutional investors refers to the number of investment organizations with which Triton has a relationship and not the actual number of investment vehicles that invest in the Triton funds. An investment organization may invest in Triton funds through more than one investment vehicle.
Legal Notice 3
Triton Investment Management Limited is regulated by the Jersey Financial Services Commission as a fund services business. Registered in Jersey No 120654. The registered address is 5/6 Esplanade, 1st Floor St. Helier, Jersey, JE2 3QA.
Legal Notice 4
Triton Investments Advisers LLP - Best Execution Disclosure - 2020
MORETriton Investments Advisers LLP (“Triton”) is required on an annual basis to provide additional disclosures around the execution venues utilised for each in scope asset class as well as certain information on the quality of execution, as detailed in the Regulatory Technical Standard 28 detailed in the Commission delegated regulation (EU) 2017/576 of 8 June 2016. As a MiFID advisory firm and in accordance with the FCA Policy Statement 17/14, Triton is required to provide these disclosures in relation to clients for which it provides the services listed in Annex I, Section A of the Directive 2014/65/EU.
When determining the strategy for placing orders for execution in the market, Triton took into account a number of execution factors, including, but not limited to, price, cost, speed, likelihood of execution and settlement, size, nature and any other consideration relevant to the execution of orders as appropriate for the characteristics of each order and the prevailing market conditions. In determining the relative importance of the execution factors Triton took into account the characteristics of the client order, the characteristic of the financial instrument including its liquidity and the available counterparties. These factors may differ from one order to another
Triton has no close links or common ownership with any counterparties used to execute trades.
Triton maintains policies designed to identify and mitigate any potential conflicts of interest, which may affect execution quality and are designed to safeguard Triton’s obligations to take all sufficient steps to achieve best execution
For the year ending 31 December 2020 Triton confirms that it considers it took all sufficient steps to achieve the best possible result when executing trades for its client.
Debt Instruments
Bonds
On average, there has been less than one trade per day in 2020.
|
Top five execution venues ranked in terms of trading volumes (descending order)
|
Proportion of volume traded as a % of total in that class
|
Proportion of orders executed as % of total in that class
|
% of Passive orders
|
% of Aggressive orders
|
% of Directed orders
|
|
Pareto Securities AS (Norway)
|
46% |
51% |
N/A |
N/A |
0% |
|
Jefferies International Limited |
25% |
19% |
N/A |
N/A |
0% |
|
Deutsche Bank AG, London Branch |
7% |
7% |
N/A |
N/A |
0% |
|
Goldman Sachs International |
7% |
6% |
N/A |
N/A |
0% |
|
Morgan Stanley Bank International Limited |
5% |
6% |
N/A |
N/A |
0% |
Please click here to download table as csv.
This relates to trades in corporate debt. Size of order, price and cost were significant factors. However, likelihood of execution is also a factor where liquidity in an instrument was limited.
Triton Investments Advisers LLP - Best Execution Disclosure - 2019
MORETriton Investments Advisers LLP (“Triton”) is required on an annual basis to provide additional disclosures around the execution venues utilised for each in scope asset class as well as certain information on the quality of execution, as detailed in the Regulatory Technical Standard 28 detailed in the Commission delegated regulation (EU) 2017/576 of 8 June 2016. As a MiFID advisory firm and in accordance with the FCA Policy Statement 17/14, Triton is required to provide these disclosures in relation to clients for which it provides the services listed in Annex I, Section A of the Directive 2014/65/EU.
When determining the strategy for placing orders for execution in the market, Triton took into account a number of execution factors, including, but not limited to, price, cost, speed, likelihood of execution and settlement, size, nature and any other consideration relevant to the execution of orders as appropriate for the characteristics of each order and the prevailing market conditions. In determining the relative importance of the execution factors Triton took into account the characteristics of the client order, the characteristic of the financial instrument including its liquidity and the available counterparties. These factors may differ from one order to another
Triton has no close links or common ownership with any counterparties used to execute trades.
Triton maintains policies designed to identify and mitigate any potential conflicts of interest which may affect execution quality and are designed to safeguard Triton’s obligations to take all sufficient steps to achieve best execution
For the year ending 31 December 2019 Triton confirms that it considers it took all sufficient steps to achieve the best possible result when executing trades for its client.
Debt Instruments Bonds
On average there has been less than one trade per day in 2019.
|
Top five execution venues ranked in terms of trading volumes (descending order) |
Proportion of volume traded as a % of total in that class | Proportion of orders executed as % of total in that class | % of Passive orders | % of Aggressive orders | % of Directed orders |
|---|---|---|---|---|---|
| Pareto Securities | 27% | 45% | N/A | N/A | 0% |
| Barclays Bank PLC | 10% | 17% | N/A | N/A | 0% |
| JP Morgan Securities PLC | 9% | 15% | N/A | N/A | 0% |
| Citibank Global Markets Ltd | 4% | 7% | N/A | N/A | 0% |
|
Goldman Sachs International |
3% | 5% | N/A | N/A | 0% |
CDS
|
Top five execution venues ranked in terms of trading volumes (descending order)
|
Proportion of volume traded as a % of total in that class
|
Proportion of orders executed as % of total in that class
|
% of Passive orders
|
% of Aggressive orders
|
% of Directed orders
|
|
JP Morgan Securities PLC
|
100% |
100% |
N/A |
N/A |
0% |
Please click here to download table as csv.
This relates to trades in corporate debt. Size of order, price and cost were significant factors. However, likelihood of execution is also a factor where liquidity in an instrument was limited.
Triton Investments Advisers LLP - Best Execution Disclosure - 2018
MORETriton Investments Advisers LLP (“Triton”) is required on an annual basis to provide additional disclosures around the execution venues utilised for each in scope asset class as well as certain information on the quality of execution, as detailed in the Regulatory Technical Standard 28 detailed in the Commission delegated regulation (EU) 2017/576 of 8 June 2016. As a MiFID advisory firm and in accordance with the FCA Policy Statement 17/14, Triton is required to provide these disclosures in relation to its client for which it provides the services listed in Annex I, Section A of the Directive 2014/65/EU.
When determining the strategy for placing orders for execution in the market, Triton took into account a number of execution factors, including, but not limited to, price, cost, speed, likelihood of execution and settlement, size, nature and any other consideration relevant to the execution of orders as appropriate for the characteristics of each order and the prevailing market conditions. In determining the relative importance of the execution factors Triton took into account the characteristics of the client order, the characteristic of the financial instrument including its liquidity and the available counterparties. These factors may differ from one order to another. In 2018, the only in scope asset class was debt instruments.
Triton has no close links or common ownership with any counterparties used to execute trades.
Triton has a suite of policies designed to identify and mitigate any potential conflicts of interest which may affect execution quality and are designed to safeguard Triton’s obligations to take all sufficient steps to achieve best execution
For the year ending 31 December 2018 Triton confirms that it considers it took all sufficient steps to achieve the best possible result when executing trades for its client.
Debt Instruments
On average there has been less than one trade per day in 2018.
| Top five execution venues ranked in terms of trading volumes (descending order) | Proportion of volume traded as a % of total in that class | Proportion of orders executed as % of total in that class | % of Passive orders | % of Aggressiv e orders | % of Directed orders |
|---|---|---|---|---|---|
| Pareto Securities | 39% | 60% | N/A | N/A | 0% |
| Barclays Bank PLC | 37% | 21% | N/A | N/A | 0% |
| Citibank Financial Products | 7% | 8% | N/A | N/A | 0% |
| JP Morgan | 6% | 5% | N/A | N/A | 0% |
| HSBC | 6% | 2% | N/A | N/A | 0% |
Please click here to download table as csv.
This relates to trades in corporate debt. Size of order, price and cost were significant factors.
However, likelihood of execution is also a factor where liquidity in an instrument was limited.