Anti-Bribery and Corruption Policy

Latitude Investment Management LLP (“Latitude” or “the Firm”) is committed to conducting business ethically and with financial integrity. Bribery is a criminal offence under the UK Bribery Act 2010. 

To minimise this risk, the Firm will:

• Maintain a clear anti-bribery policy; 
• Train “Staff” (including partners, employees, consultants, agents, or any person acting on its behalf) to recognise and avoid bribery; 
• Encourage vigilance and confidential reporting of suspected bribery, via appropriate channels; 
• Notify all third parties of Latitude’s zero-tolerance policy on bribery and corruption;
• Rigorously investigate allegations of bribery and cooperate with police and other authorities;
• Take firm action against anyone involved in bribery. 

The Policy 

‍Latitude prohibits Staff from offering, giving, requesting, or receiving any bribe, to or from any person or organisation, public or private, anywhere in the world, in order to: 

• gain an unethical commercial, contractual, or regulatory advantage for the Firm; or
• obtain any personal advantage, financial or otherwise, for the individual or their associates. 

This policy operates alongside the Firm’s obligations to prevent conflicts of interest and manage third-party inducements under the FCA rules in SYC 10 and COBS 2.3A. 

Further Clarification 

Latitude recognises that market practices vary across the territories in which it does business, however, this policy prohibits any inducement that offers personal gain to the recipient, or their associates, or where it is intended to influence them to act other than solely in the interests of Latitude or the party they represent or work for. 

This does not prohibit normal, proportionate practices that are customary and properly recorded, such as: 

• reasonable and appropriate hospitality; and
• gifts given for a corporate or occasional reason, provided they are logged in the Firm's Gifts and Hospitality Register. 

Where doubt exists as to whether an act constitutes bribery, Staff should consult their manager or Latitude’s Chief Compliance Officer, James Foster, before proceeding. 

‍Responsibility 

‍All Staff share responsibility for preventing, detecting, and reporting bribery. Confidential reporting channels are maintained under the Firm's Anti-Bribery and Corruption Reporting procedures.