ARC TIME Social Impact Property Feeder Trust
SRI Style:
Social Style
SDR Labelling:
Sustainability Impact label
Product:
OEIC
Fund Region:
UK
Fund Asset Type:
Property
Launch Date:
18/05/2017
Last Amended:
Dec 2024
Dialshifter (
):
Fund Size:
£100.50m
(as at: 31/10/0024)
Total Screened Themed SRI Assets:
£100.50m
Total Responsible Ownership Assets:
£100.50m
Total Assets Under Management:
£2100.00m
ISIN:
GB00BJK12Q56, GB00BJK12P40
Contact Us:
Objectives:
The Fund is a “feeder fund” and its sole purpose is to acquire and hold shares in ARC TIME Social Impact Property Fund.
The aim of the Fund is to offer Shareholders a consistent income stream with some capital growth prospects through the provision and utility of Social Infrastructure Assets in the United Kingdom which seeks to deliver positive sustainability impact.
Positive social impact for the Fund means the enhanced provision of and access to Social Infrastructure Assets providing health, housing, and education where there is an identified unmet need and/or underserved groups, with these services being provided in fit-for-purpose, quality facilities, which in turn supports the delivery and improvement of those essential services.
Sustainable, Responsible
&/or ESG Overview:
Positive social impact for the Fund means the enhanced provision of and access to Social Infrastructure Assets providing health, housing, and education where there is an identified unmet need and/or underserved groups, with these services being provided in fit-for- purpose, quality facilities, which in turn supports the delivery and improvement of those essential services.
Primary fund last amended:
Dec 2024
Information directly from fund manager.
Fund Filters
Sustainability - General
Funds that have policies that consider (environmental and social) sustainability issues. Strategies vary but are likely to consider environmental issues like climate change, carbon emissions, biodiversity loss, resource management, environmental impacts; and social issues like equal opportunities, human rights, labour standards, diversity and adherence to internationally recognised codes. See fund information.
Find funds which substantially focus on sustainability issues
Find funds that use the UN Global Compact to inform or help direct where they can or cannot invest and will typically not invest in companies with significant breaches (low standards) - although strategies vary. (The UNGC covers a wide range of issues - search 'UNGC'). See https://unglobalcompact.org/
Find funds that specifically aim to invest (and manage assets) in ways that help to address all or some of the UN's Sustainable Development Goals (SDGs). See https://sdgs.un.org/goals).
Find funds that publicly report their performance against specifically named sustainability objectives (in addition to reporting their financial performance)
Environmental - General
Funds that limit or 'reduce' their exposure to carbon intensive industries (ie sectors which are major contributors to climate change. Funds vary - some funds may be 'underweight' in this area which means they may have some investment in highly carbon intensive areas. Funds of this kind may choose companies they consider to be 'best in sector' and encourage ever higher standards. Strategies vary. See fund information for further details.
Climate Change & Energy
Funds that avoid investing in major coal, oil and/or gas (extraction) companies. Funds vary: some may exclude all companies that extract oil. Others may have exposure to oil extraction via more diversified energy companies. See fund literature to confirm details.
Funds that avoid companies involved in fracking and tar sands - which are widely regarded as controversial methods of oil and gas extraction. Strategies vary. See fund information for further information.
Funds that avoid investing in companies with coal, oil and gas reserves. See fund information for further details.
Find funds that have policies which say they avoid or limit their investment in the nuclear industry. Strategies vary. See fund information for further detail.
Social / Employment
Find funds with policies or themes that set out their approach to health and wellbeing issues. Funds of this kind typically aim to invest in companies with high standards - or encourage high standards. Themed funds are likely to have more of an emphasis on this area. Strategies vary. See fund information for further detail.
Ethical Values Led Exclusions
Companies are excluded if they are involved in any aspect of the production chain for tobacco products, including cigarettes, vaping, e-cigarettes, chewing tobacco and cigars.
Find funds that avoid companies with significant involvement in the gambling industry. Some funds may allow a small proportion of profits to come from this area. See fund policy for further details.
Find funds that avoid companies that derive significant income from pornography and related areas. Strategies vary. See fund details for further information.
Human Rights
Find funds that have policies in place to ensure they do not invest in companies that employ children.
The fund has a policy which excludes assets with involvement in Modern Slavery
Meeting Peoples' Basic Needs
Find funds that invest in social housing property freeholds. Strategies vary. See fund literature for further information.
Healthcare and or medical theme or area of investment - the fund may have a single theme or many themes
Governance & Management
Find fund options that have policies that relate to corporate governance issues such as board structure, executive remuneration, bribery and/or corporate corruption. These funds will typically avoid companies with poor practices. Strategies vary. See fund literature for further information.
Find funds that aim to avoid investing in companies with poor governance practices.(e.g. board structure, management practices etc.) Views may however vary on what counts as 'poor' practices - and funds may not immediately divest as they may prefer to work to encourage higher standards. See fund literature for further information.
Find funds that have policies explaining how managers will respond to assets / companies that do not comply with relevant anti-bribery and anti-corruption standards or laws. Strategies vary; options include stewardship/ engagement and divestment - or a combination. See fund literature for further information.
Find funds that have policies explaining how the fund managers take into account digital/cyber security related risks. Funds with cyber policies will typically favour companies with higher standards or that are helping to solve problems - but strategies vary. See fund literature for further information.
A core element of these funds will aim to encourage higher ESG standards through responsible ownership / stewardship / engagement /voting activity
Impact Methodologies
Funds that aim to help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Funds that aim to measure the positive real world environmental and / or social benefits that are associated with their investment strategy. Funds that aim to deliver positive impacts and measure those impacts may be referred to as 'impact funds' - although impact measurement is not restricted to impact funds. Strategies vary. See fund information.
Funds that are specifically marketed as ‘Impact investments funds' will work to deliver both financial performance and specific, measurable positive, real world social and/or environmental benefits. Strategies vary.
Find funds that specifically state that they aim to deliver positive social (i.e. people related) impacts and/or outcomes.
Fund aims to deliver positive environmental and or social impacts (real world benefits) through its engagement with investee assets
This fund has an explanation of the way in which the manager believes things need to change in order to deliver a more sustainable future, which they are working to help achieve.
How The Fund Works
Find funds that focus on finding and investing in companies with positive / beneficial attributes. This strategy can be applied in addition to exclusion criteria and engagement/stewardship activity.
Aims to avoid companies that do significant harm. This originates from the EU’s sustainable finance ‘DNSH’ (do no significant harm) work, which is not necessarily used by UK investors.
Find funds that have 'mapped' (reviewed) their investment selection and management strategies to identify which of the UN Sustainable Development Goals (SDGs) the fund is helping to address.
Find funds that make significant use of internationally agreed 'norms' (e.g. United Nations Global Compact - UNGC - or the UN Sustainable Development Goals - SDGs) as part of their investment selection process alongside additional SRI criteria such as positive or negative stock selection policies and/or stewardship strategies.
Unscreened Assets & Cash
The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets.
The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets.
The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets
All assets held in the fund - except cash - meet the sustainability criteria published in fund documentation.
Intended Clients & Product Options
Finds funds designed to meet the needs of individual investors with an interest in sustainability issues.
Finds funds designed to meet the needs of individual investors with an interest in ‘Impact investment funds’ which help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Find funds that are available via a tax efficient ISA product wrapper.
Labels & Accreditations
Find funds that are rated by research agency 'Rayner Spencer Mills Research' (awarded 'RSMR Rated' status). Read fund literature or contact RSMR for further information.
Find funds that have chosen to adopt one of the Financial Conduct Authority (FCA) SDR labels. Please note: there are a range of reasons why potentially relevant funds may not use an SDR label eg. adopting a label may be work in progress, the manager may not yet be allowed to do so because of the product type, a manager may feel their fund is insufficiently aligned to SDR requirements. Read fund literature and / or our blogs for further information.
Fund Management Company Information
About The Business
Finds fund management companies that have a published company wide stewardship, engagement and / or responsible ownership policy or strategy that covers all investments. Stewardship typically involves encouraging higher ESG standards through voting and dialogue.
Find fund management companies that actively encourage higher 'environmental, social and governance' and/or 'sustainable and responsible investment' practices across investee companies - typically where the aim is to encourage positive change that is aligned with the best interests of investors. Strategies vary. See additional information and options.
Find fund management companies that aim to align all their investments (across all funds) to help meet the aims of the UN Sustainable Development Goals.
Find fund management companies that encourage the companies they invest in to have strong diversity, race, gender and other equality policies across all assets held, not simply screened or themed SRI/ESG funds. (ie Asset Management company wide).
Collaborations & Affiliations
Find fund management companies that have signed up to the UN backed 'Principles of Responsible Investment'.
Find fund management companies that are members of UKSIF - the UK Sustainable Investment and Finance association
Fund management entity is a member of the Investment Association https://www.theia.org/
Resources
Find a fund management company that directly employs specialist ESG/SRI/sustainability researchers or analysts. This allows asset managers to discuss environmental, social and governance risks and opportunities directly with companies.
Find fund management companies that makes use of expert external research companies. This can help deliver specialist expertise and means resources are pooled with other investors.
Company Wide Exclusions
Find fund management companies (not funds) that avoid investment in 'controversial weapons' across all of their funds and other investment vehicles.
Find fund management companies that avoid investment in fossil fuel companies (e.g. coal, oil and gas) across all of their funds. (and/ or other assets.)
This asset manager has a strategy in place that will lead them to exit direct investments in the coal mining industry. Managers ability to do this may depend on the geographic regions in which they invest.
This asset manager excludes direct investment in the coal mining industry. Managers ability to do this may depend on the geographic regions in which they invest.
Climate & Net Zero Transition
Find fund management companies that are working with the companies they invest in to encourage reductions in carbon dioxide and other greenhouse gas emissions.
Finds organisations / fund management companies that are in the process of working out how to make a ‘net zero commitment’ - meaning that when that is finalised they will have started the process of reducing their total greenhouse gas emissions to'zero'.
Transparency
Find fund management companies that publish a report detailing their responsible investment ownership - also known as 'Stewardship' - activity.
Find fund management companies that will supply information about their sustainable and responsible investment activity on request.
Sustainable, Responsible &/or ESG Policy:
The specific targeted impacts are key positive societal benefits or real-world outcomes resulting from the investment activities performed by the Investment Manager for the purpose of delivering the desired impact, namely:
Enabling improved outcomes in health through activities that:
- Create more facilities, beds and capacity for health-related services
- Deliver facilities for health services in locations where there is an identified unmet need and/or underserved people
- Provide fit-for-purpose facilities enabling the effective delivery of the health service
Enabling improved outcomes in housing through activities that:
- Increase specialist housing capacity, being housing that is designed for a specific group of people, such as those who are disabled, vulnerable and/or elderly
- Deliver homes for the above user groups in locations where there is an identified unmet need and/or underserved people
- Provide fit-for-purpose housing for individuals, with better access to support services for those vulnerable user groups
Enabling improved outcomes in education through activities that:
- Create more facilities and places for educational services
- Deliver facilities for educational services in locations where there is an identified unmet need and/or underserved people
- Provide fit-for-purpose facilities enabling the effective delivery of the educational service
These sectors and assets may be in either/or the public and private sector.
“Social Infrastructure Assets” are UK property assets which provide health services, housing, and education. Property assets are typically freehold or long-term leasehold property assets or other infrastructure assets which are let to providers of services within the sectors. The assets targeted by the Fund are typically let on long-term leases (with initial leasehold terms in excess of 15 years) and are expected to provide investors with a secure long-term, inflation-correlated income stream and capital growth, whilst generating a positive social impact. Social Infrastructure Assets may also include other collective investment schemes which meet the Objective.
Through increasing the access to Social Infrastructure Assets there is the risk of unintended negative outcomes. These include negative environmental impacts that can occur during the construction, refurbishment and/or operation of property, such as increased emissions or energy usage. There are also potential negative social impacts that can occur, which include the impact new Social Infrastructure Assets and the services provided can have on existing services in the area, the risk that the services provided are sub-standard or that the rent received from through the provision of Social Infrastructure Assets is too high which puts the underlying services at risk.
The pursuance of the sustainability objective is not expected to have any material effect on the financial risk and return of the Fund. By investing in investments that promote positive social impact, the composition of the Fund may be significantly different to other portfolios, especially those not trying to achieve a social objective.
Process:
The Sustainability Objective is fully integrated into the investment process, from initial appraisal through to the Investment Committee and ongoing management. Our commitments are:
- To seek to identify, measure and manage ESG-related risks, and where possible, benefits
- To incorporate sustainability in our engagement with stakeholders
- To continuously seek improvement in our ability to gather and disclose relevant data
- To promote a culture focused on sustainability
- To constantly consider and report our progress on sustainability issues.
The Investment Manager selects assets for inclusion in the portfolio to meet the sustainability objective. As set out in the Investment policy, at least 70% of the Gross Asset Value of the Fund must be invested in Social Infrastructure Assets.
The Investment Manager reflecting the Theory of Change and the challenges identified, seeks opportunities and locations across Health, Housing and Education where there is an unmet demand or underserved population. The Investment Manager assesses the opportunities, as to how it will address the challenges looking at aspects such as
- Suitability of location
- Design of the buildings and is it fit for purpose
- Operator/Tenant quality (operational capability, financial and reputational)
The Investment Manager will then test each prospective asset against the following criteria to determine whether or not they are supporting the Sustainability Objective. The information on the asset is recorded in a scorecard with other key data and assessed by the Investment Committee as part of the acquisition process. An asset must meet both tests to qualify for prospective and continuing investment:
(A) Additionality impact rating: This criteria seeks to assess what specific contribution the asset can make in delivering the social outcomes set out in the sustainability objective and which would not be provided but for the Fund’s investment. Any additionality is regarded as positive but can also be categorised into a “High” “Medium” and “Low” rating by asset to assess the delivery of positive additionality for end users, specifically in locations where there is an identified unmet demand and/or underserved groups. This is delivered through new and/or refurbished buildings (often change of use) in a location where there is under provision of fit-for-purpose facilities. Whilst additionality will be maximised there is no requirement for specific allocations by additionality rating, as long as there is absolute positive additionality.
The Investment Manager working with a third-party advisor, using the guidelines included in the Impact Management Project (Place Based Impact Investing Reporting Framework Guidance 2023 (“Framework”)), has allocated an additionality rating (which is a measure of contribution to a targeted impact and improved outcome) to various investment categories. This categorisation is then allocated to individual investments as part of the investment process and then monitored.
(B) Impact classifications: Each of the in-scope Social Infrastructure Assets will be allocated an impact category, using the Framework. The Fund Investment Manager has worked with a third-party advisor in seeking to define classification guidelines to various investment scenarios. Specifically, the assets are classified into one of the following categories under the Framework:
- Does cause harm,
- May cause harm,
- Act to avoid harm,
- Benefit Stakeholders, or
- Contribute to solutions.
Only those prospective assets with a categorisation of “Benefit Stakeholders” or “Contribute to Solutions” under the Framework are considered for investment under the Sustainability Objective.
This categorisation is then allocated to individual investments as part of the investment process and then monitored.
Resources, Affiliations & Corporate Strategies:
In-house & external ESG/SRI research resources, roles and responsibilities
The Group (Alpha Real Capital LLP and TIME Investments) counts on a dedicated sustainability team which is composed of the Head of Sustainability & CIO, Associate Director and Associate. The Group will also work with external sustainability teams (sustainability consultants and service providers), as needed, to support the team’s initiatives where additional resources or specific technical knowledge is required. For example, the in-house sustainability team worked with CBRE and Evora on environmental data collection and climate risk and opportunities assessment across our portfolios, respectively. We also worked with The Good Economy and BlueMark to support our impact management framework development and alignment with SDR requirements. Finally, the Group makes use of external tools such as MSCI Climate Value-at-Risk (CVaR), PropTech (Arbnco) and Refinitiv (now LSEG) and other tools to support sustainability analysis and our quantitative approach, where possible.
Governance structure and responsibilities
The board of Alpha Real Capital Ltd ("ARCL") takes ultimate responsibility for the Group’s ESG performance, including climate-related risks and opportunities. The Group counts on its internal governance structures, which include relevant governance bodies, to ensure that ESG factors are considered throughout the firm. Relevant committees include the Group’s ESG Committee, Executive Management Committee (EMC), Investment Committee (IC) and Risk Committee (RC). Alongside the ESG Committee and IC, the Group’s Regulatory Working group also plays a key role in the implementation of SDR. A brief description of the aforementioned bodies is included below. The role of fund and asset management teams are also described below within the governance structure and responsibilities.
- Executive Management Committee (EMC) The EMC holds a delegated authority from the Board to assess the Group’s progress towards the management and mitigation of climate-related issues (both physical and transition risks). Under certain circumstances executive decision-making or escalation of certain risks to the Board may be required.
- ESG Committee The ESG Committee is chaired by the CIO & Head of Sustainability, with representatives from across the Group and is convened quarterly. Some of its responsibilities include: the initiation of ESG-related projects; reviewing and advising on suitable sustainability objectives and criteria for ESG funds; providing governance and oversight of ESG-related reporting including ESG regulatory reporting; monitoring compliance with the ESG policies throughout the Group and reviewing performance annually against agreed targets.
- Investment Committee (IC) The IC assesses the ability to manage climate-related risks at the time of acquisition. This is done (in conjunction with an assessment of other ESG risks) through the integration of an ESG Scorecard within the papers considered by the committee. The IC will decide whether the risks identified can be mitigated, managed or accepted, or whether they present an unacceptable or unmanageable risk
- Risk Committee (RC) The RC meets to discuss and review climate-related risks to the extent they impact the business strategy of the Group. As such, the RC may need to take action to manage certain risks.
- Regulatory Working Group This group was established to address the evolving compliance requirements related to sustainability. This group has collaborated to understand the SDR regulation and labelling regime and includes representatives from ESG, Marketing, Compliance, Regulatory and Fund Management Teams.
- Fund management and asset management teams Fund Management and Asset Management Teams play a role in the monitoring of sustainability factors throughout the investment process, from due diligence to post-acquisition, which include monitoring of relevant data and KPIs at the asset and portfolio level as well as progress towards specific goals.
FTE in-house staff working on ESG/SRI as well as stewardship / responsible ownership
We have a dedicated team of three FTE and various others across the business who also work on ESG/SRI as well as Stewardship/responsible ownership initiatives to varying degrees as part of their roles.
List related affiliations, memberships, and involvement with groups
Across the group, we are members of the following industry initiatives:
- UN PRI
- UN Global Compact
- Pensions for Purpose
- INREV and AREF
- UKSIF
- RenewableUK, Solar EnergyUK and SafetyOn
SDR Labelling: Sustainability Impact label
Key Performance Indicators:
In order to robustly measure progress towards the Sustainability Objective, the ACD and Investment Manager will use the following KPIs as an objective measurement basis to ensure the investment activities achieve the targeted impact.
The data and information sourced for monitoring the KPIs and progress towards meeting the sustainability objective are robust and evidence-based gathered from numerous sources, including formal property documentation (leases, construction documents, floor plans etc), independent third party reports (building surveys, environmental surveys, valuation reports etc), regulatory reports (Ofsted, CQC etc), property management data (rent collection, service charge expenditure), inspection reports (carried out by independent valuer, property manager and investment manager), tenant engagement feedback (questionnaires and surveys) and other independent third party data sources.
This data and information is stored on an internal database which is reviewed and updated periodically and at least once per annum.
Number of Beds/Places/Spaces: Number that are created and/or maintained for the provision of Health, Housing and Education in locations where there is an identified unmet need and/or underserved groups of people, through the Investment Manager’s investment activities.
- On investment - the number of Beds/Places/Spaces that are created or maintained within the relevant sectors for the provision of Health, Housing and Education assessed against the size of the unmet need and/or underserved groups in the locality. This is delivered through investment in or funding of new build, refurbished properties or existing properties that already meet the required standards for that sector and use. Measured on an asset-by-asset basis as well as on a relative basis, with respect to the amount of capital deployed, to understand not only the number of Beds/Places/Spaces for investments made but also the efficiency of the capital deployed (using quantitative metrics such as the additional capacity created per £ of capital deployed) and whether it meets the identified unmet need and/or underserved groups – for example, the Investment Manager identifies whether there is a shortage of care home beds through mapping demand and supply and will look to increase absolute capacity through investment or funding in order to support meeting this need.
- Post initial investment - the continuing provision of Beds/Places/Spaces for the delivery of Health, Housing and Education requirements or to repurpose assets to an alternative social infrastructure use that meet the required standards for that sector and use. Measured on an asset-by-asset basis as well as in terms of the amount of capital deployed, in order to understand the number of Beds/Places/Spaces maintained as well as the efficiency of the capital deployed in locations where there is an identified unmet need and/or underserved groups of people The Investment Manager monitors whether the investment continues to support meeting the identified unmet need and/or underserved groups through monitoring of demand e.g. whether the setting is still operational and has sufficient occupancy levels.
Through the creation and maintaining of Beds/Places/Spaces in appropriate social infrastructure assets, this KPI assesses how investor capital is being used to facilitate provision and/or continuity of the services within Health, Housing, and Education and therefore contribute to the targeted impacts.
Additionality: Maintenance of at least 70% of Gross Asset Value to have a positive Additionality rating. That means one of Low Additionality, Medium Additionality or High Additionality. Measured based on amount of capital deployed into new investments on a rolling 1, 3 and 5 year period. Measured based on the capital deployed in the period and the proportion achieving a level of “Low”, “Medium” or “High” additionality.
Through additionality rating assessment, this KPI assesses the depth of impact investor capital is having and the role in the achievement of the targeted outcomes.
Impact Classification: Maintenance of at least 70% of Gross Asset Value to have an Impact Classification of one of: Benefit Stakeholders or Contribute to solutions. Measured based on the valuation of the assets and the proportion achieving categorisation of Benefit Stakeholders or Contribute to solutions.
Through impact classification which was designed by the Impact Management Project (IMP), the system allows investors to classify the impact of their assets in a consistent and transparent manner. This is applied to the Fund’s assets and related sectors in relation to the targeted impacts.
Standard of Social Infrastructure Assets: Maintenance of at least 70% of Gross Asset Value which are of suitable quality and have been registered with the relevant regulator and deemed appropriate for their intended social use. This is assessed based on initial registration for intended use and approval required ahead of use from the relevant regulatory body or organisation. Ongoing review against inspection reports from the relevant regulatory body or organisation, and/or independent valuer. Measurements include the valuation of the assets and the proportion meeting the required standards for operation under the relevant regulators most recent assessment, including an assessment of the quality of each operator. Standards of property maintained are as per the terms set within the respective leases (which are usually FRI leases). Ongoing review against annual inspection reports from independent valuer. Measured based on the valuation of the assets and the proportion meeting the required standards of operation following the most recent independent valuers inspection.
Through focusing on the standard of the Social Infrastructure Assets, this KPI is assessing that the social infrastructure asset is appropriate or exceeds the level required for the provision of the underlying service within Health, Housing, and Education and therefore contributing to the targeted impacts.
Rent Affordability Rent affordability for social infrastructure tenants includes affordability and rents set at appropriate levels with rental collection metrics an indicator of these arrangements. KPI of at least 95% of contracted rent collection. This is measured based on portfolio rent levels on a rolling 1, 3 and 5 year period. This KPI is assessing the appropriateness of the rent level. This helps support the assessment that the investment is contributing to - or if there is a risk to - the targeted impacts.
Occupancy: Occupancy data is gathered from tenants on a regular basis to assess the level of capacity being utilised. This KPI is assessing the demand for the underlying service. This helps support the assessment that the investment is contributing to - or if there is a risk to - the targeted impacts.
The ACD utilises the KPI data and reporting to assess and identify if the intended impact, as described in the investment objective, is being met or if changes are required, this includes assessing if the building is in use for the intended purpose.
The ACD reports annually on how the investment activities contribute to the stated impact as well as how the assets are achieving the impact outlined.
Literature
Disclaimer
The value of investments and the income from them may fall as well as rise as a result of fluctuations in market, currency or other factors and investors may not get back the original amount invested. Any past performance data cited is not a reliable indicator of future results. The ARC TIME Social Impact Property Fund (“the Fund”) invests in assets that may at times be hard to sell. This means that there may be occasions when you experience a delay or receive less than you might otherwise expect when selling your investment. For more information on risks, see the Fund’s prospectus and KIID.
This is a financial promotion as set out in the Financial Services and Markets Act 2000 (FSMA). This document is issued in the UK by TIME Investments (‘TIME’) which is the trading name of Alpha Real Property Investment Advisers LLP, which is the Investment Manager of the Fund with delegated authority from Alpha Real Capital LLP, the authorised corporate director of the Fund, both of which are authorised and regulated by the Financial Conduct Authority. Please note your capital is at risk and there is no guarantee that the Fund’s investment objective will be achieved. TIME Investments may source data from third party data providers but accepts no responsibility or liability for the accuracy of third-party data. This document does not constitute investment advice and potential investors are recommended to seek professional advice before investing. Applications for shares in the Fund can only be made via an Application Form and after reviewing the Key Investor Information Document (“KIID”) and the Prospectus and investors should carefully read the risk warnings contained within. All documentation is available on request. Specific Fund Information: The underlying investments in the Fund consist wholly or substantially of real property. The value of the real property concerned will generally be a matter of valuer’s opinion rather than fact. Fund Status: The Fund is a sub-fund of ARC TIME:Funds II and is a Non-UCITS Retail Scheme within the meaning of the rules contained in the Collective Investment Schemes Sourcebook (the “FCA Regulations”) published by the FCA as part of their Handbook of rules made under the FSMA. Issued: September 2024
| Fund Name | SRI Style | SDR Labelling | Product | Region | Asset Type | Launch Date | Last Amended |
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ARC TIME Social Impact Property Feeder Trust |
Social Style | Sustainability Impact label | OEIC | UK | Property | 18/05/2017 | Dec 2024 | |
ObjectivesThe Fund is a “feeder fund” and its sole purpose is to acquire and hold shares in ARC TIME Social Impact Property Fund. The aim of the Fund is to offer Shareholders a consistent income stream with some capital growth prospects through the provision and utility of Social Infrastructure Assets in the United Kingdom which seeks to deliver positive sustainability impact. Positive social impact for the Fund means the enhanced provision of and access to Social Infrastructure Assets providing health, housing, and education where there is an identified unmet need and/or underserved groups, with these services being provided in fit-for-purpose, quality facilities, which in turn supports the delivery and improvement of those essential services. |
Fund Size: £100.50m (as at: 31/10/0024) Total Screened Themed SRI Assets: £100.50m (as at: 31/10/0024) Total Responsible Ownership Assets: £100.50m (as at: 31/10/0024) Total Assets Under Management: £2100.00m (as at: 31/10/0024) ISIN: GB00BJK12Q56, GB00BJK12P40 Contact Us: questions@time-investments.com |
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Sustainable, Responsible &/or ESG OverviewPositive social impact for the Fund means the enhanced provision of and access to Social Infrastructure Assets providing health, housing, and education where there is an identified unmet need and/or underserved groups, with these services being provided in fit-for- purpose, quality facilities, which in turn supports the delivery and improvement of those essential services.
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Primary fund last amended: Dec 2024 |
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Information received directly from Fund Manager |
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Fund FiltersSustainability - General
Sustainability policy
Funds that have policies that consider (environmental and social) sustainability issues. Strategies vary but are likely to consider environmental issues like climate change, carbon emissions, biodiversity loss, resource management, environmental impacts; and social issues like equal opportunities, human rights, labour standards, diversity and adherence to internationally recognised codes. See fund information.
Sustainability focus
Find funds which substantially focus on sustainability issues
UN Global Compact linked exclusion policy
Find funds that use the UN Global Compact to inform or help direct where they can or cannot invest and will typically not invest in companies with significant breaches (low standards) - although strategies vary. (The UNGC covers a wide range of issues - search 'UNGC'). See https://unglobalcompact.org/
UN Sustainable Development Goals (SDG) focus
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Report against sustainability objectives
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Limits exposure to carbon intensive industries
Funds that limit or 'reduce' their exposure to carbon intensive industries (ie sectors which are major contributors to climate change. Funds vary - some funds may be 'underweight' in this area which means they may have some investment in highly carbon intensive areas. Funds of this kind may choose companies they consider to be 'best in sector' and encourage ever higher standards. Strategies vary. See fund information for further details. Climate Change & Energy
Coal, oil & / or gas majors excluded
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Fracking and tar sands excluded
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Fossil fuel reserves exclusion
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Nuclear exclusion policy
Find funds that have policies which say they avoid or limit their investment in the nuclear industry. Strategies vary. See fund information for further detail. Social / Employment
Health & wellbeing policies or theme
Find funds with policies or themes that set out their approach to health and wellbeing issues. Funds of this kind typically aim to invest in companies with high standards - or encourage high standards. Themed funds are likely to have more of an emphasis on this area. Strategies vary. See fund information for further detail. Ethical Values Led Exclusions
Tobacco and related product manufacturers excluded
Companies are excluded if they are involved in any aspect of the production chain for tobacco products, including cigarettes, vaping, e-cigarettes, chewing tobacco and cigars.
Gambling avoidance policy
Find funds that avoid companies with significant involvement in the gambling industry. Some funds may allow a small proportion of profits to come from this area. See fund policy for further details.
Pornography avoidance policy
Find funds that avoid companies that derive significant income from pornography and related areas. Strategies vary. See fund details for further information. Human Rights
Child labour exclusion
Find funds that have policies in place to ensure they do not invest in companies that employ children.
Modern slavery exclusion policy
The fund has a policy which excludes assets with involvement in Modern Slavery Meeting Peoples' Basic Needs
Invests in social property (freehold)
Find funds that invest in social housing property freeholds. Strategies vary. See fund literature for further information.
Healthcare / medical theme
Healthcare and or medical theme or area of investment - the fund may have a single theme or many themes Governance & Management
Governance policy
Find fund options that have policies that relate to corporate governance issues such as board structure, executive remuneration, bribery and/or corporate corruption. These funds will typically avoid companies with poor practices. Strategies vary. See fund literature for further information.
Avoids companies with poor governance
Find funds that aim to avoid investing in companies with poor governance practices.(e.g. board structure, management practices etc.) Views may however vary on what counts as 'poor' practices - and funds may not immediately divest as they may prefer to work to encourage higher standards. See fund literature for further information.
Anti-bribery and corruption policy
Find funds that have policies explaining how managers will respond to assets / companies that do not comply with relevant anti-bribery and anti-corruption standards or laws. Strategies vary; options include stewardship/ engagement and divestment - or a combination. See fund literature for further information.
Digital / cyber security policy
Find funds that have policies explaining how the fund managers take into account digital/cyber security related risks. Funds with cyber policies will typically favour companies with higher standards or that are helping to solve problems - but strategies vary. See fund literature for further information.
Encourage higher ESG standards through stewardship activity
A core element of these funds will aim to encourage higher ESG standards through responsible ownership / stewardship / engagement /voting activity Impact Methodologies
Aims to generate positive impacts (or 'outcomes')
Funds that aim to help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Measures positive impacts
Funds that aim to measure the positive real world environmental and / or social benefits that are associated with their investment strategy. Funds that aim to deliver positive impacts and measure those impacts may be referred to as 'impact funds' - although impact measurement is not restricted to impact funds. Strategies vary. See fund information.
Described as an ‘impact investment fund’
Funds that are specifically marketed as ‘Impact investments funds' will work to deliver both financial performance and specific, measurable positive, real world social and/or environmental benefits. Strategies vary.
Positive social impact theme
Find funds that specifically state that they aim to deliver positive social (i.e. people related) impacts and/or outcomes.
Aim to deliver positive impacts through engagement
Fund aims to deliver positive environmental and or social impacts (real world benefits) through its engagement with investee assets
Publish ‘theory of change’ explanation
This fund has an explanation of the way in which the manager believes things need to change in order to deliver a more sustainable future, which they are working to help achieve. How The Fund Works
Positive selection bias
Find funds that focus on finding and investing in companies with positive / beneficial attributes. This strategy can be applied in addition to exclusion criteria and engagement/stewardship activity.
Significant harm exclusion
Aims to avoid companies that do significant harm. This originates from the EU’s sustainable finance ‘DNSH’ (do no significant harm) work, which is not necessarily used by UK investors.
Assets mapped to SDGs
Find funds that have 'mapped' (reviewed) their investment selection and management strategies to identify which of the UN Sustainable Development Goals (SDGs) the fund is helping to address.
Combines norms based exclusions with other SRI criteria
Find funds that make significant use of internationally agreed 'norms' (e.g. United Nations Global Compact - UNGC - or the UN Sustainable Development Goals - SDGs) as part of their investment selection process alongside additional SRI criteria such as positive or negative stock selection policies and/or stewardship strategies. Unscreened Assets & Cash
Assets typically aligned to sustainability objectives 70 - 79%
The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets.
Assets typically aligned to sustainability objectives 80 – 89%
The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets.
Assets typically aligned to sustainability objectives > 90%
The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets
All assets (except cash) meet published sustainability criteria
All assets held in the fund - except cash - meet the sustainability criteria published in fund documentation. Intended Clients & Product Options
Intended for investors interested in sustainability
Finds funds designed to meet the needs of individual investors with an interest in sustainability issues.
Intended for clients who want to have a positive impact
Finds funds designed to meet the needs of individual investors with an interest in ‘Impact investment funds’ which help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Available via an ISA (OEIC only)
Find funds that are available via a tax efficient ISA product wrapper. Labels & Accreditations
RSMR rated (OEIC funds only)
Find funds that are rated by research agency 'Rayner Spencer Mills Research' (awarded 'RSMR Rated' status). Read fund literature or contact RSMR for further information.
SDR Labelled
Find funds that have chosen to adopt one of the Financial Conduct Authority (FCA) SDR labels. Please note: there are a range of reasons why potentially relevant funds may not use an SDR label eg. adopting a label may be work in progress, the manager may not yet be allowed to do so because of the product type, a manager may feel their fund is insufficiently aligned to SDR requirements. Read fund literature and / or our blogs for further information. Fund Management Company InformationAbout The Business
Responsible ownership / stewardship policy or strategy (AFM company wide)
Finds fund management companies that have a published company wide stewardship, engagement and / or responsible ownership policy or strategy that covers all investments. Stewardship typically involves encouraging higher ESG standards through voting and dialogue.
ESG / SRI engagement (AFM company wide)
Find fund management companies that actively encourage higher 'environmental, social and governance' and/or 'sustainable and responsible investment' practices across investee companies - typically where the aim is to encourage positive change that is aligned with the best interests of investors. Strategies vary. See additional information and options.
SDG aligned aims / objectives (AFM company wide)
Find fund management companies that aim to align all their investments (across all funds) to help meet the aims of the UN Sustainable Development Goals.
Diversity, equality & inclusion engagement policy (AFM company wide)
Find fund management companies that encourage the companies they invest in to have strong diversity, race, gender and other equality policies across all assets held, not simply screened or themed SRI/ESG funds. (ie Asset Management company wide). Collaborations & Affiliations
PRI signatory
Find fund management companies that have signed up to the UN backed 'Principles of Responsible Investment'.
UKSIF member
Find fund management companies that are members of UKSIF - the UK Sustainable Investment and Finance association
Investment Association (IA) member
Fund management entity is a member of the Investment Association https://www.theia.org/ Resources
Employ specialist ESG / SRI / sustainability researchers
Find a fund management company that directly employs specialist ESG/SRI/sustainability researchers or analysts. This allows asset managers to discuss environmental, social and governance risks and opportunities directly with companies.
Use specialist ESG / SRI / sustainability research companies
Find fund management companies that makes use of expert external research companies. This can help deliver specialist expertise and means resources are pooled with other investors. Company Wide Exclusions
Controversial weapons avoidance policy (AFM company wide)
Find fund management companies (not funds) that avoid investment in 'controversial weapons' across all of their funds and other investment vehicles.
Fossil fuel exclusion policy (AFM company wide)
Find fund management companies that avoid investment in fossil fuel companies (e.g. coal, oil and gas) across all of their funds. (and/ or other assets.)
Coal divestment policy (AFM company wide)
This asset manager has a strategy in place that will lead them to exit direct investments in the coal mining industry. Managers ability to do this may depend on the geographic regions in which they invest.
Coal exclusion policy (group wide coal mining exclusion policy)
This asset manager excludes direct investment in the coal mining industry. Managers ability to do this may depend on the geographic regions in which they invest. Climate & Net Zero Transition
Encourage carbon / greenhouse gas reduction (AFM company wide)
Find fund management companies that are working with the companies they invest in to encourage reductions in carbon dioxide and other greenhouse gas emissions.
Working towards a ‘Net Zero’ commitment (AFM company wide)
Finds organisations / fund management companies that are in the process of working out how to make a ‘net zero commitment’ - meaning that when that is finalised they will have started the process of reducing their total greenhouse gas emissions to'zero'. Transparency
Publish responsible ownership / stewardship report (AFM company wide)
Find fund management companies that publish a report detailing their responsible investment ownership - also known as 'Stewardship' - activity.
Full SRI / responsible ownership policy information available on request
Find fund management companies that will supply information about their sustainable and responsible investment activity on request. Sustainable, Responsible &/or ESG Policy:The specific targeted impacts are key positive societal benefits or real-world outcomes resulting from the investment activities performed by the Investment Manager for the purpose of delivering the desired impact, namely: Enabling improved outcomes in health through activities that:
Enabling improved outcomes in housing through activities that:
Enabling improved outcomes in education through activities that:
These sectors and assets may be in either/or the public and private sector.
“Social Infrastructure Assets” are UK property assets which provide health services, housing, and education. Property assets are typically freehold or long-term leasehold property assets or other infrastructure assets which are let to providers of services within the sectors. The assets targeted by the Fund are typically let on long-term leases (with initial leasehold terms in excess of 15 years) and are expected to provide investors with a secure long-term, inflation-correlated income stream and capital growth, whilst generating a positive social impact. Social Infrastructure Assets may also include other collective investment schemes which meet the Objective.
Through increasing the access to Social Infrastructure Assets there is the risk of unintended negative outcomes. These include negative environmental impacts that can occur during the construction, refurbishment and/or operation of property, such as increased emissions or energy usage. There are also potential negative social impacts that can occur, which include the impact new Social Infrastructure Assets and the services provided can have on existing services in the area, the risk that the services provided are sub-standard or that the rent received from through the provision of Social Infrastructure Assets is too high which puts the underlying services at risk.
The pursuance of the sustainability objective is not expected to have any material effect on the financial risk and return of the Fund. By investing in investments that promote positive social impact, the composition of the Fund may be significantly different to other portfolios, especially those not trying to achieve a social objective.
Process:The Sustainability Objective is fully integrated into the investment process, from initial appraisal through to the Investment Committee and ongoing management. Our commitments are:
The Investment Manager selects assets for inclusion in the portfolio to meet the sustainability objective. As set out in the Investment policy, at least 70% of the Gross Asset Value of the Fund must be invested in Social Infrastructure Assets.
The Investment Manager reflecting the Theory of Change and the challenges identified, seeks opportunities and locations across Health, Housing and Education where there is an unmet demand or underserved population. The Investment Manager assesses the opportunities, as to how it will address the challenges looking at aspects such as
The Investment Manager will then test each prospective asset against the following criteria to determine whether or not they are supporting the Sustainability Objective. The information on the asset is recorded in a scorecard with other key data and assessed by the Investment Committee as part of the acquisition process. An asset must meet both tests to qualify for prospective and continuing investment:
(A) Additionality impact rating: This criteria seeks to assess what specific contribution the asset can make in delivering the social outcomes set out in the sustainability objective and which would not be provided but for the Fund’s investment. Any additionality is regarded as positive but can also be categorised into a “High” “Medium” and “Low” rating by asset to assess the delivery of positive additionality for end users, specifically in locations where there is an identified unmet demand and/or underserved groups. This is delivered through new and/or refurbished buildings (often change of use) in a location where there is under provision of fit-for-purpose facilities. Whilst additionality will be maximised there is no requirement for specific allocations by additionality rating, as long as there is absolute positive additionality.
The Investment Manager working with a third-party advisor, using the guidelines included in the Impact Management Project (Place Based Impact Investing Reporting Framework Guidance 2023 (“Framework”)), has allocated an additionality rating (which is a measure of contribution to a targeted impact and improved outcome) to various investment categories. This categorisation is then allocated to individual investments as part of the investment process and then monitored.
(B) Impact classifications: Each of the in-scope Social Infrastructure Assets will be allocated an impact category, using the Framework. The Fund Investment Manager has worked with a third-party advisor in seeking to define classification guidelines to various investment scenarios. Specifically, the assets are classified into one of the following categories under the Framework:
Only those prospective assets with a categorisation of “Benefit Stakeholders” or “Contribute to Solutions” under the Framework are considered for investment under the Sustainability Objective.
This categorisation is then allocated to individual investments as part of the investment process and then monitored. Resources, Affiliations & Corporate Strategies:In-house & external ESG/SRI research resources, roles and responsibilities The Group (Alpha Real Capital LLP and TIME Investments) counts on a dedicated sustainability team which is composed of the Head of Sustainability & CIO, Associate Director and Associate. The Group will also work with external sustainability teams (sustainability consultants and service providers), as needed, to support the team’s initiatives where additional resources or specific technical knowledge is required. For example, the in-house sustainability team worked with CBRE and Evora on environmental data collection and climate risk and opportunities assessment across our portfolios, respectively. We also worked with The Good Economy and BlueMark to support our impact management framework development and alignment with SDR requirements. Finally, the Group makes use of external tools such as MSCI Climate Value-at-Risk (CVaR), PropTech (Arbnco) and Refinitiv (now LSEG) and other tools to support sustainability analysis and our quantitative approach, where possible.
Governance structure and responsibilities The board of Alpha Real Capital Ltd ("ARCL") takes ultimate responsibility for the Group’s ESG performance, including climate-related risks and opportunities. The Group counts on its internal governance structures, which include relevant governance bodies, to ensure that ESG factors are considered throughout the firm. Relevant committees include the Group’s ESG Committee, Executive Management Committee (EMC), Investment Committee (IC) and Risk Committee (RC). Alongside the ESG Committee and IC, the Group’s Regulatory Working group also plays a key role in the implementation of SDR. A brief description of the aforementioned bodies is included below. The role of fund and asset management teams are also described below within the governance structure and responsibilities.
FTE in-house staff working on ESG/SRI as well as stewardship / responsible ownership We have a dedicated team of three FTE and various others across the business who also work on ESG/SRI as well as Stewardship/responsible ownership initiatives to varying degrees as part of their roles.
List related affiliations, memberships, and involvement with groups Across the group, we are members of the following industry initiatives:
SDR Labelling: Sustainability Impact label Key Performance Indicators: In order to robustly measure progress towards the Sustainability Objective, the ACD and Investment Manager will use the following KPIs as an objective measurement basis to ensure the investment activities achieve the targeted impact.
The data and information sourced for monitoring the KPIs and progress towards meeting the sustainability objective are robust and evidence-based gathered from numerous sources, including formal property documentation (leases, construction documents, floor plans etc), independent third party reports (building surveys, environmental surveys, valuation reports etc), regulatory reports (Ofsted, CQC etc), property management data (rent collection, service charge expenditure), inspection reports (carried out by independent valuer, property manager and investment manager), tenant engagement feedback (questionnaires and surveys) and other independent third party data sources.
This data and information is stored on an internal database which is reviewed and updated periodically and at least once per annum.
Number of Beds/Places/Spaces: Number that are created and/or maintained for the provision of Health, Housing and Education in locations where there is an identified unmet need and/or underserved groups of people, through the Investment Manager’s investment activities.
Through the creation and maintaining of Beds/Places/Spaces in appropriate social infrastructure assets, this KPI assesses how investor capital is being used to facilitate provision and/or continuity of the services within Health, Housing, and Education and therefore contribute to the targeted impacts.
Additionality: Maintenance of at least 70% of Gross Asset Value to have a positive Additionality rating. That means one of Low Additionality, Medium Additionality or High Additionality. Measured based on amount of capital deployed into new investments on a rolling 1, 3 and 5 year period. Measured based on the capital deployed in the period and the proportion achieving a level of “Low”, “Medium” or “High” additionality. Through additionality rating assessment, this KPI assesses the depth of impact investor capital is having and the role in the achievement of the targeted outcomes.
Impact Classification: Maintenance of at least 70% of Gross Asset Value to have an Impact Classification of one of: Benefit Stakeholders or Contribute to solutions. Measured based on the valuation of the assets and the proportion achieving categorisation of Benefit Stakeholders or Contribute to solutions. Through impact classification which was designed by the Impact Management Project (IMP), the system allows investors to classify the impact of their assets in a consistent and transparent manner. This is applied to the Fund’s assets and related sectors in relation to the targeted impacts.
Standard of Social Infrastructure Assets: Maintenance of at least 70% of Gross Asset Value which are of suitable quality and have been registered with the relevant regulator and deemed appropriate for their intended social use. This is assessed based on initial registration for intended use and approval required ahead of use from the relevant regulatory body or organisation. Ongoing review against inspection reports from the relevant regulatory body or organisation, and/or independent valuer. Measurements include the valuation of the assets and the proportion meeting the required standards for operation under the relevant regulators most recent assessment, including an assessment of the quality of each operator. Standards of property maintained are as per the terms set within the respective leases (which are usually FRI leases). Ongoing review against annual inspection reports from independent valuer. Measured based on the valuation of the assets and the proportion meeting the required standards of operation following the most recent independent valuers inspection. Through focusing on the standard of the Social Infrastructure Assets, this KPI is assessing that the social infrastructure asset is appropriate or exceeds the level required for the provision of the underlying service within Health, Housing, and Education and therefore contributing to the targeted impacts.
Rent Affordability Rent affordability for social infrastructure tenants includes affordability and rents set at appropriate levels with rental collection metrics an indicator of these arrangements. KPI of at least 95% of contracted rent collection. This is measured based on portfolio rent levels on a rolling 1, 3 and 5 year period. This KPI is assessing the appropriateness of the rent level. This helps support the assessment that the investment is contributing to - or if there is a risk to - the targeted impacts.
Occupancy: Occupancy data is gathered from tenants on a regular basis to assess the level of capacity being utilised. This KPI is assessing the demand for the underlying service. This helps support the assessment that the investment is contributing to - or if there is a risk to - the targeted impacts.
The ACD utilises the KPI data and reporting to assess and identify if the intended impact, as described in the investment objective, is being met or if changes are required, this includes assessing if the building is in use for the intended purpose. The ACD reports annually on how the investment activities contribute to the stated impact as well as how the assets are achieving the impact outlined. LiteratureDisclaimerThe value of investments and the income from them may fall as well as rise as a result of fluctuations in market, currency or other factors and investors may not get back the original amount invested. Any past performance data cited is not a reliable indicator of future results. The ARC TIME Social Impact Property Fund (“the Fund”) invests in assets that may at times be hard to sell. This means that there may be occasions when you experience a delay or receive less than you might otherwise expect when selling your investment. For more information on risks, see the Fund’s prospectus and KIID. This is a financial promotion as set out in the Financial Services and Markets Act 2000 (FSMA). This document is issued in the UK by TIME Investments (‘TIME’) which is the trading name of Alpha Real Property Investment Advisers LLP, which is the Investment Manager of the Fund with delegated authority from Alpha Real Capital LLP, the authorised corporate director of the Fund, both of which are authorised and regulated by the Financial Conduct Authority. Please note your capital is at risk and there is no guarantee that the Fund’s investment objective will be achieved. TIME Investments may source data from third party data providers but accepts no responsibility or liability for the accuracy of third-party data. This document does not constitute investment advice and potential investors are recommended to seek professional advice before investing. Applications for shares in the Fund can only be made via an Application Form and after reviewing the Key Investor Information Document (“KIID”) and the Prospectus and investors should carefully read the risk warnings contained within. All documentation is available on request. Specific Fund Information: The underlying investments in the Fund consist wholly or substantially of real property. The value of the real property concerned will generally be a matter of valuer’s opinion rather than fact. Fund Status: The Fund is a sub-fund of ARC TIME:Funds II and is a Non-UCITS Retail Scheme within the meaning of the rules contained in the Collective Investment Schemes Sourcebook (the “FCA Regulations”) published by the FCA as part of their Handbook of rules made under the FSMA. Issued: September 2024
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