Alcentra Global Policies
Alcentra Order Execution Policy
Anti-Money Laundering and Counter Terrorist Financing Policy (“AML/CTF Policy”) Statement
Alcentra Limited acting as Agent/ Investment Manager on behalf of its clients (inc. its sponsored collective investment schemes) is committed to high ethical standards. Our policies on anti-money laundering, sanctions and anti-bribery and corruption aim to ensure that risks identified by the firm are appropriately mitigated.
The objective of the AML/CTF policy is to identify and appropriately manage risks identified by Alcentra. This is achieved by establishing and implementing appropriate processes, systems and controls to protect Alcentra, its customers, shareholders and employees from money laundering. The AML/CTF policy sets out the minimum control standards to all Alcentra entities and employees, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.
The AML/CTF policy is informed by applicable laws, regulations, regulatory guidance and best practice from the United Kingdom, European Union, the United States of America and other jurisdictions for which it operates. In cases where material differences exist between the rules and regulations of these authorities or countries, the AML policy adopts the highest standard, while acknowledging the primary of local law.
Please see the Wolfsberg Questionnaire.
Following the global regulatory directive, Alcentra successfully completed phase one of their LIBOR transition programme at End 2021. This saw the cessation of GBP, JPY, EUR and CHF LIBOR, across all tenors (overnight, 1week, 3mth, 6mth, 12mth and USD (1 week, 2mth), replaced in line with industry recommendations by their secured overnight equivalent (SONIA, TONAR, ESTR, SARON and SOFR).
Phase two of the transition will see the permanent cessation or loss of representativeness of USD LIBOR (all remaining tenors) and is currently scheduled for End June 2023.
Alcentra has reviewed the impacts of these change across all business functions and has made a number of positive upgrades to our technology and operational architecture to support the smooth integration of these new rates. Additionally, Alcentra have successfully remediated, or in the process of remediating for USD, all applicable legal documentation to incorporate adequate fallback language.
As predominantly a ‘rate-taker’, rather than a ‘rate-setter’ in the market, Alcentra has also maintained close engagement with third parties throughout the transition period to oversee the amendment by Issuers of asset holdings with underlying LIBOR exposure to RFRs.
Alcentra Limited is incorporated in England.
Alcentra Limited is authorised and regulated by the Financial Conduct Authority.
Alcentra Limited is registered as an investment adviser with the Securities and Exchange Commission with respect to its US clients.
160 Queen Victoria Street
London EC4V 4LA
Registration number 2958399
Incorporated in England and Wales
Pillar 3 Disclosure as at 31st December 2021
Pillar 3 Disclosure as at 31st December 2020
Pillar 3 Disclosure as at 31st December 2019
Pillar 3 Disclosure as at 31st December 2018
Pillar 3 Disclosure as at 31st December 2017
Pillar 3 Disclosure as at 31st December 2016
Pillar 3 Disclosure as at 31st December 2015
Alcentra MiFID II – RTS 28 Disclosures FY 2020
Alcentra MiFID II – RTS 28 Disclosures FY 2019
Alcentra MiFID II – RTS 28 Disclosures FY 2018
Alcentra MiFID II – RTS 28 Disclosures FY 2017
Calls to Alcentra Limited may be recorded in line with applicable laws and regulations and for training and monitoring purposes.
Alcentra NY, LLC
Alcentra NY, LLC is incorporated in Delaware, USA
Alcentra NY, LLC is registered as an investment adviser with the Securities and Exchange Commission with respect to its US clients.
Alcentra New York
9 West 57th Street
New York, NY 10019
Alcentra High Yield
399 Boylston Street
Boston, MA 02116
A division of Alcentra NY, LLC
Complaints may be submitted via email to the Global Head of Investor Relations at [email protected] or in writing to:
Alcentra Group, 160 Queen Victoria Street, London, ECV4 4LA
Alcentra will acknowledge complaints in writing within three business days of receipt and will investigate the complaint. Alcentra will be transparent in our investigation, will not charge any fees for the investigation and will work to reach an agreeable solution as quickly as possible with the aim to have the complaint resolved within three business days. Business days are Monday to Friday excluding Bank Holidays. If the complaint cannot be resolved within 30 days, Alcentra will keep the complainant informed of the progress of the complaint every 14 days.
Following an investigation, Alcentra will notify you by email or in writing of the outcome.
If you are dissatisfied with the response to your compliant and wish to escalate the matter, please contact Alcentra’s Global Head of Compliance: [email protected]