Legal Disclosures & Terms

If you do not agree to be bound by or comply with these Terms, do not access or use our website.
CCAT reserves the right, in our sole discretion, to change, modify, add or remove Terms or portions thereof at any time. Any changes, modifications, or additions to, or deletions from the Terms shall be effective upon posting on this website. If you use this website after we post changes to the Terms, you accept the Terms as changed.

Intended Audience and Purpose

The information provided on our website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject CCAT, its wholly-owned affiliates, or any of its products to any registration requirement within such jurisdiction or country. CCAT assumes no responsibility for access to this website by any person located within a country or jurisdiction where such access would be contrary to any law or regulation in that country. 

Our website and its contents is for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security that may be referenced on or through our website. Further, our website and its contents does not constitute an offering or recommendation by CCAT or its wholly-owned affiliates of any transaction, product or service, including securities transactions and investment management or advisory services. CCAT does not provide investment advice, tax advice, or legal advice through this website, and you agree that this website will not be used by you for such purposes.

The information provided on our website is intended for institutional investors and Professional Clients and Eligible Counterparties as defined by the FCA under the Markets in Financial Instruments Directive. It is not intended for retail investors.

Use Limitations

All copyrights, trademarks, logos, service marks, trade names, or other intellectual property displayed on, or used in conjunction with, this website are proprietary to CCAT, unless otherwise noted. The content of this website is protected by applicable intellectual property (copyright) law. CCAT reserves all rights with respect to intellectual property ownership of all material on this website, and will enforce such rights to the full extent permissible by law.

The material accessible on or through this website is accessible for personal browsing and printing purposes only. Users of this website may not otherwise:

 (1) copy, reproduce, sell, republish, post, transmit (by electronic means or otherwise), modify, link into, use for any public or commercial purpose or distribute in any way material from this website without the express, written permission of CCAT;

 (2) use, copy, modify, or display any CCAT name, CCAT employee name, logo, text or graphic image without CCAT's express, written permission;

 (3) display any of the pages, text, images or other content of this website in any manner without CCAT's express written permission;

 (4) modify or use the pages, text, images, papers, or other content from this website for any purpose other than browsing or printing for personal, non-commercial use; or

 (5) take any action to create an impression of affiliation, sponsorship or endorsement between any user and/or website and CCAT.

Privacy

CCAT may collect information about you when you access the website if you voluntarily choose to send CCAT electronic mail, request information, or ask to be contacted. CCAT may use this information to provide you with updated information about the products and services we offer. Certain employees of CCAT and our wholly owned affiliates may be given the information you provide to respond to your requests. Employees of CCAT and its affiliates are instructed to handle any information you provide confidentially. Our full Privacy and Data Protection Policy is provided as part of the website.

Our website uses "cookies" and "web beacons" (such as Google Analytics) to collect, store and aggregate data about usage and browsing patterns. As it relates to web analytics, we use cookies and web beacons for session management and to analyze site usage; we do not use cookies and web beacons to store any personally identifiable information about you. A "cookie" is a small text file containing a random and unique alphanumeric identifier that we transfer to your computer's hard drive through your web browser (unless you set your browser to reject cookies) that enables our systems to recognize your browser. A "web beacon" (also known as a "page tag," "data tag" or "image tag") is a mechanism by which a small section of code that is embedded in our website pages allows us to check that a user has viewed the page. These technologies can help us analyze and better understand how our website is being used and improve the user experience.

Our website also uses "cookies" and "web beacons" that are able to collect, store, and aggregate personally identifiable information about usage and browsing patterns relating to users that have opted into our email marketing program. These specific "cookies" and "web beacons" will not collect any data if you are not part of our email marketing activities.

Disclaimer

CCAT does not warrant this website for any particular purpose. It is provided "as is" and on an "as available" basis. CCAT disclaims, to the fullest extent of the law, any warranty of any kind, whether express or implied, as to any matter relating to this website, including without limitation the implied warranties of merchantability, fitness for a particular purpose, and non-infringement. Use of this website is at your own risk.

All content on this website is presented as of the date published or indicated. It may not reflect current opinions or events. Although the information and data provided to you on this website is obtained or compiled from sources believed to be reliable, CCAT cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information, data or opinions made available to you for any particular purpose. This website may include forward-looking statements, which are based on current opinions, expectations and projections. CCAT expressly disclaims any duty to update or revise any information, opinion or forward-looking statement appearing on this website. Decisions based on information contained on this website are solely your responsibility.

In no event will CCAT be liable for any decision made, action or inaction taken by you in reliance on any information or data on our website and under no circumstances is any information available on our website to be construed as investment advice or recommendations.

CCAT does not warrant that our website, or the functions contained in our website, will be uninterrupted or error-free, that defects will be corrected, or that our website, or the servers that make it available, are free from viruses or other harmful components. You assume the entire cost of any necessary servicing, repairing, or correcting of your property or operations as a result of using our website. You accept at your own risk that the Internet or other online communications medium may not perform as intended as a result of human, mechanical or other error, despite the efforts of CCAT, you or any third party.

You hereby agree to indemnify, defend and hold harmless CCAT and its wholly-owned affiliates, and their directors, officers, employees and agents, from and against any and all claims, liabilities, damages, losses or expenses (including reasonable attorneys' fees and expenses) arising out of or in any way connected with your access to or use of our website.

Proxy Voting

Policy

Whether CCAT will have proxy voting responsibility on behalf of a separate account client is subject to negotiation as part of the overall investment management agreement executed with each client. We will have voting responsibility for all CCAT branded funds.

Should a separate account client desire that CCAT vote proxies on their behalf, CCAT will accept such authority and agree with the client as part of the investment management agreement whether votes should be cast in accordance with CCAT’s proxy voting policy or in accordance with a client specific proxy voting policy. Should the client wish to retain voting responsibility themselves, CCAT would have no further involvement in the voting process but would remain available to provide reasonable assistance to the client as needed.

CCAT utilizes the services of Institutional Shareholder Services (“ISS”), an unaffiliated proxy firm, to help manage the proxy voting process and to research and vote proxies. CCAT has adopted the ISS voting policies for use when contractually directed by the client to votes proxies on their behalf in accordance with our proxy voting policy. We review the ISS policies at least annually and believe that they are reasonably designed to ensure that we vote proxies in the best interest of clients and that our voting decisions are insulated from any potential material conflicts of interest.

Should a client contractually direct CCAT to vote proxies on their behalf in accordance with Client specific voting policies and procedures, we will still utilize the services of ISS to cast the votes in accordance with the client’s instructions.

When voting proxies on behalf of our clients, CCAT assumes a fiduciary responsibility to vote in our clients' best interests. In addition, with respect to benefit plans under the Employee Retirement Income Securities Act (ERISA), CCAT acknowledges its responsibility as a fiduciary to vote proxies prudently and solely in the best interest of plan participants and beneficiaries. So that it may fulfill these fiduciary responsibilities to clients, CCAT has adopted and implemented these written policies and procedures reasonably designed to ensure that it votes proxies in the best interest of clients.

Procedures

Proxy Voting Guidelines

CCAT acknowledges it has a duty of care to its clients that requires it to monitor corporate events and vote client proxies when instructed by the client to do so. To assist in this effort, CCAT has retained ISS to research and vote its proxies. ISS provides proxy-voting analysis and votes proxies in accordance with predetermined guidelines. Relying on ISS to vote proxies is intended to help ensure that CCAT votes in the best interest of its clients and insulates CCAT’s voting decisions from any potential material conflicts of interest. CCAT will also accept specific written proxy voting instructions from a client and communicate those instructions to ISS to implement when voting proxies involving that client’s portfolio.

In specific instances where ISS will not vote a proxy, will not provide a voting recommendation, or other instances where there is an unusual cost or requirement related to a proxy vote, CCAT’s Head of Investment Operations will coordinate with members of our investment team to conduct an analysis to determine whether the costs related to the vote outweigh the potential benefit to our client. If we determine, in our discretion, that it is in the best of interest of our client not to participate in the vote CCAT will not participate in the vote on behalf of our client. If we determine that a vote would be in the best interest of our client, CCAT will provide voting direction back to ISS and ensure the vote is cast as they instruct.

Unless contrary instructions are received from a client, CCAT has instructed ISS to not vote proxies in so-called "share blocking" markets. Share-blocking markets are markets where proxy voters have their securities blocked from trading during the period of the annual meeting. The period of blocking typically lasts from a few days to two weeks. During the period, any portfolio holdings in these markets cannot be sold without a formal recall. The recall process can take time, and in some cases, cannot be accomplished at all. This makes a client’s portfolio vulnerable to a scenario where a stock is dropping in attractiveness but cannot be sold because it has been blocked. Shareholders who do not vote are not subject to the blocking procedure.

CCAT also reserves the right to override ISS vote recommendations under certain circumstances. CCAT will only do so if they believe that voting contrary to the ISS recommendation is in the best interest of clients. The reasons for any overrides and for voting against the ISS recommendation will be documented.

Conflicts of Interest

Occasions may arise during the voting process in which the best interest of our clients conflict with CCAT’s interests. In these situations, ISS will continue to follow the same predetermined guidelines as formally agreed upon between CCAT and ISS before such conflict of interest existed. Conflicts of interest generally include (i) business relationships where CCAT has a substantial business relationship with, or is actively soliciting business from, a company soliciting proxies, or (ii) personal or family relationships whereby an employee of CCAT has a family member or other personal relationship that is affiliated with a company soliciting proxies, such as a spouse who serves as a director of a public company. A conflict could also exist if a substantial business relationship exists with a proponent or opponent of a particular initiative.

If CCAT learns that a conflict of interest exists, the Head of Investment Operations will work with our compliance and investment team as needed to document (i) the details of the conflict of interest, (ii) whether or not the conflict is material, and (iii) procedures to ensure that CCAT makes proxy voting decisions based on the best interests of clients. If CCAT determines that a material conflict exists, it will defer to ISS to vote the proxy in accordance with the predetermined voting policy.

Voting Process

CCAT’s Head of Investment Operations acts as coordinator with ISS including ensuring proxies CCAT is responsible to vote are forwarded to ISS, overseeing that ISS is voting assigned client accounts and maintaining appropriate authorization and voting records.

After ISS is notified by the custodian of a proxy that requires voting and/or after ISS cross references their database with a routine download of CCAT holdings and determines a proxy requires voting, ISS will review the proxy and make a voting proposal based on the recommendations provided by their research group. Any electronic proxy votes will be communicated to the proxy solicitor by ISS Global Proxy Distribution Service and Broadridge’s Proxy Edge Distribution Service, while non-electronic ballots, or paper ballots, will be faxed, telephoned or sent via Internet. ISS assumes responsibility for the proxies to be transmitted for voting in a timely fashion and maintains a record of the vote, which is provided to CCAT on a monthly basis. Proxy voting records specific to a client’s account are available to each client upon request.

Proxy Voting Record

CCAT will maintain a record containing the following information regarding the voting of proxies: (i) the name of the issuer, (ii) the exchange ticker symbol, (iii) the CUSIP number, (iv) the shareholder meeting date, (v) a brief description of the matter brought to vote; (vi) whether the proposal was submitted by management or a shareholder, (vii) how CCAT/ ISS voted the proxy (for, against, abstained) and (viii) whether the proxy was voted for or against management.