Terms & Conditions

The website is accessible via the URL http://www.northofsouth.com (‘the Site’) is operated by North of South Capital LLP, a company incorporated and existing under the laws of England, whose registered office is 7 Chesham Mews, London SW1X 8HS, United Kingdom. We are regulated in the United Kingdom by the Financial Conduct Authority (FRN: 403114).

This disclaimer applies to the entire contents of the Site and contains important information explaining the rights of any visitor to the Site ("you" or "your") to access and use the Site. You should pay particular attention to the 'Disclaimer of Liability' section as this excludes or limits our legal liability in connection with your use of the Site. The information, material and content provided within the Site may be changed at any time without notice. We may also make changes to this disclaimer at any time without notice by updating these pages. You should review this section of the Site whenever you access the Site and your continued access to or use of the Site shall constitute proof of such review and your agreement to the latest published version of this disclaimer.
Certain provisions of this disclaimer may be superseded by expressly designated legal or regulatory notices or terms located on particular pages of the Site or on materials that are downloadable from the Site.
We do not warrant or otherwise promise that the Site, use of the Site or this disclaimer (in whole or in part) are in compliance with laws or available for use in locations from which you are accessing the Site. If you choose to access this Site, you do so at your own initiative and are responsible for compliance with local laws.

Disclaimer of Liability
All material on the Site is for information only and does not address the circumstances of any particular individual or entity. The information on the Site is not intended to be comprehensive or complete may not be up-to-date and should not be relied on as such. The firm does not assume or accept any responsibility or liability in relation to either the availability of the Site or the information on it. All information is provided "as is", without any warranties of any kind and at your sole risk. We make no representations and disclaim all express and implied warranties and conditions of any kind in relation to information on the Site.
Whether or not advised of the possibility, neither North of South Capital LLP, nor any other party involved in creating, producing, maintaining or delivering the Site shall be liable for any kind of loss or damage that may be suffered or claimed by you (or any person claiming under or through you) or to any third party, which arises in connection with the use of, inability to use or the results of use of the Site and any websites linked to the Site or the material on the Site or such other websites, whether such losses or damages are suffered directly or indirectly or are immediate or consequential and whether arising from negligence, breach of contract or otherwise.
Nothing in this disclaimer excludes or limits our liability for fraud, negligence, causing death or personal injury, or for any liability to the extent that it cannot be excluded or limited under the applicable law or regulatory requirements.

Intellectual Property Rights
The information contained in this website may not be reproduced, distributed or published for any purpose without the prior written consent of North of South Capital LLP.

Links To and From Other Websites
The hyperlinks within the Site may take you to third party websites which are not within our control. We have not reviewed these websites and are not responsible for their availability, accuracy or content or for any loss or damage that may arise out of your use of them. Access to third party websites is entirely at your own risk. You should read any terms and conditions applying to the use of any third party website that you visit and address any complaints or queries relating to such websites to the operator of that website. The inclusion of a link in the Site does not imply that we endorse, recommend or approve any material on the linked page or accessible from it.
You may not use any part of the Site on any other website or link any other website to the Site without prior written permission.

Legal & Regulatory Information
Nothing on the Site constitutes or forms a part of any offer or solicitation of any offer for sale or subscription of or any invitation or solicitation to offer to buy or subscribe for, any securities, financial instruments or related instruments, nor should it or any part of it form the basis of or be relied upon in any connection with any contract or commitment whatsoever.
Nothing on the Site constitutes professional and/or financial advice, an information agreement, recommendation as to suitability or appropriateness, or an offer or solicitation to enter into any form of transaction. Certain products may be high risk and may not be suitable for all investors. Any discussion of the risks associated with a particular product or service should not be regarded as complete or comprehensive. Advice from a suitably qualified professional should always be sought in relation to any particular matter or circumstances.
This information is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use is contrary to local law or regulation. Distribution of this information to any person other than the person that received a unique user name and password to access this website and to such person’s advisors is unauthorised and any reproduction of this information, in whole or in part, or the disclosure of any such information, in each such instance is prohibited.
The information included herein is not intended to be complete, and material aspects of the descriptions contained herein may change at any time. If you express an interest in investing, you should carefully review the applicable offering memorandum and risk factors disclosed therein prior to making a decision to invest. You should rely only on the information contained in the offering memorandum in making your decision to invest which is available on request from info@northofsouth.com.
Our investments are available for professional clients and eligible counterparties due to the risk of liquidity within the funds. Such an investment will provide limited liquidity because interests in the fund will not be freely transferable and may be withdrawn infrequently and only under certain limited circumstances. There will be no public or secondary market for interests in the fund, and it is not expected that a public or secondary market will develop.
Investing in financial markets involves a substantial degree of risk. There can be no assurance that the investment objectives described herein will be achieved. Investment losses may occur, and investors could lose some or all of their investment. Nothing herein is intended to imply that an investment in any fund may be considered “conservative,” “safe,” “risk free” or “risk averse.” No regulatory authority has passed upon or endorsed this summary or the merits of an investment in any fund.

Further Information
If you wish to receive information about our funds or other products you should apply for a password by filling out a registration form found on the investor login page, or by contacting North of South directly at info@northofsouth.com
If you are a person to whom information about our funds may lawfully be provided under The Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 and Rule 4.12.3 of the FCA’s Conduct of Business Sourcebook, you will be provided with a password.

Client Disclaimer
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I understand that the website does not contain any investment advice and is not intended as an offer to buy any securities


Website Cookies Policy

How we use cookies
Cookies are small pieces of data stored on your device that helps us to remember who you are and show you content that is relevant to your interests. Besides improving your experience, this also helps us improve our website. Some cookies only last for a short time, while you browse webpages. Some are stored longer, so we can recognise you if you return to our website. By using and continuing to use our website, you agree that we can place these types of cookies on your computer or mobile device.

The types of cookies we use
We use a combination of the following types of cookies:

How to view and manage cookies
Most browsers give you tools to manage cookies to suit your needs. Some browsers allow you to manage cookies on a site by site basis, and some allow you to browse in a private mode which ensures cookies are deleted after you close your browser tab or window. If you chose to completely disable cookies while browsing our site, please note that some functionality may not work correctly.

Further Information
For more information, please refer to our privacy policy.


Cookies Policy

How we use cookies

Cookies are small pieces of data stored on your device that helps us to remember who you are and show you content that is relevant to your interests. Besides improving your experience, this also helps us improve our website. Some cookies only last for a short time, while you browse webpages. Some are stored longer, so we can recognise you if you return to our website.

By using and continuing to use our website, you agree that we can place these types of cookies on your computer or mobile device.

The types of cookies we use

We use a combination of the following types of cookies:
• Necessary cookies. These cookies help with website performance, ensuring that our services function as you expect, such as accessing secure areas of the website or navigating in or around pages. Without these cookies, the website cannot function properly.

• Analytics cookies. We use these cookies to understand how you are using our website, which in turn helps us to improve how website is built, making it easier for you to find the information you are looking for.

• Functionality cookies. These cookies are used to store your preferences, and enable us to personalise content for you and changes how the site behaves. This includes information such as preferred language, region etc. aswell as visual preferences.

• Advertising cookies. These cookies record you visit to our website, along with any immediate pages you visit and immediate links you follow out of the site. This allows any advertising displayed to be more relevant to your interests.

How to view and manage cookies

Most browsers give you tools to manage cookies to suit your needs. Some browsers allow you to manage cookies on a site by site basis, and some allow you to browse in a private mode which ensures cookies are deleted after you close your browser tab or window. If you chose to completely disable cookies while browsing our site, please note that some functionality may not work correctly.

Further Information

For more information, please refer to our privacy policy.


Conflicts of Interest Summary

We provide here a summary of the policy we maintain in order to manage conflicts of interest in respect of the duties we owe to our clients. This applies from 15 February 2021.


A conflict of interest can arise between North of South Capital LLP and Pacific Capital Partners and dVam LLP Group companies and associates, the directors and staff of such companies (‘us’) and you as a client, or between your interests and those of another client of ours. Conflicts can also arise as a result of inducements from or to third parties. We aim to establish and maintain and operate effective organisational and administrative arrangements with a view to taking all appropriate steps to prevent conflicts of interest from constituting or giving rise to a risk of damage to the interests of our clients.


A conflict of interest may arise where a relevant person (for example, an employee), or a person directly or indirectly linked by control to North of South Capital LLP:


We aim to keep a record of the kinds of activity we carry on in which a conflict could arise or has arisen, and, in doing so we take account of the activities of other members of our group of companies. We also maintain procedures to prevent or manage actual or potential conflicts. This includes procedures to maintain appropriate independence between members of our staff who are involved in different activities, for example, through the operation of information barriers, physical separation of staff, the segregation of duties and responsibilities and maintenance of a policy of independence which requires our staff, when providing services to a client, to act in the best interests of the client and to disregard any conflicts of interest; and, in some circumstances declining to act for a client or potential client.


Engagement Policy




  1. Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”), a firm which trades shares on regulated and comparable markets, is required to either develop and publicly disclose an engagement policy as prescribed in COBS 2.2B.6R or disclose a clear and reasoned explanation of why it has chosen not to do
  2. North of South has elected to disclose its engagement policy as set out below. Further, North of South is also required to further disclose on an annual basis how the engagement policy has been implemented in a way that meets the requirements in COBS 2B.7R. North of South publishes its annual disclosure separately on its website.


Policy Definition


  1. An Asset Manager for the purposes of this policy relates to investment firms that provide portfolio management services to investors; alternative investment fund managers; and/or Undertaking for Collective Investment in Transferable Securities (UCITS) management companies.




  1. The following Engagement Policy applies to North of South Capital LLP because whilst the Firm invests in the emerging markets in Asia, Latin America, Africa, the Middle East and Russia some of the equities of some companies are dual listed both in the UK and in the EU and are therefore listed on a recognised trading venue within the EEA.


Policy Standards


  1. North of South Capital LLP is required to disclose this engagement policy which complies with the requirements set out in the FCA’s Conduct of Business Sourcebook.
  2. It is also required to publicly disclose on an annual basis how that engagement policy has been implemented in a way that meets the requirements (including disclosure of certain of voting activities in respect of shares in investee companies) or to publish a clear and reasoned explanation of why the Firm has chosen not to comply with the requirements.
  3. North of South Capital LLP must describe how it:


Integrating shareholder engagement in our investment strategies  (COBS 2.2B.6 R (1))


  1. Research and analysis by our investment managers includes evaluation of performance on strategy, financials, risk, material environmental social and governance (‘ESG’) factors.
  2. Engagement with company management, boards, subject specialists as well as other shareholders and stakeholders is a key input into this process and investment strategy.
  3. Voting and engagement activities can be used by the Firm to provide a forward-looking view of the financial and non-financial performance of a company.


Monitoring investee companies on relevant matters (COBS 2.2B.6 R (2))


  1. North of South Capital LLP may actively monitor investee companies. Areas of focus may include issues with regard to company strategy, ongoing performance and operational ESG factors. The Firm may have discussions with company officials and representatives where appropriate.
  2. The Firm’s monitoring is also supported by the following:


Conducts dialogues with investee companies (COBS 2.2B.6 R (3))


  1. The Firm will take a   case-by-case   approach   in   its   decision   to   engage   with the management of an investee company. Normal methods through which dialogue shall be exercised include:
  1. Any material proposals or suggestions will be discussed and agreed with portfolio managers within the Firm before they are put to investee companies.


Exercising voting and any other shareholder rights (COBS 2.2B.6 R (4))


  1. For North of South Capital LLP, voting is an effective tool to escalate issues and express particular concerns and/or opinions the Firm may have. North of South Capital LLP aims to ensure effective and efficient voting processes and controls by focusing on investments that are material to the Firm.

Cooperating with other shareholders  (COBS 2.2B.6 R (5))


  1. North of South Capital LLP takes into consideration the following when deciding whether to participate in collective engagement:


Communicating with relevant stakeholders of investee companies (COBS 2.2B.6 R (6))


  1. North of South Capital LLP’s investment professionals regularly engage with companies seeking to improve shareholder value, specifically the value of clients’ investments. Engagement activities in some instances are conducted on a one-to- one basis with company management or members of the board of directors.


Managing actual and potential conflicts of interests in relation to North of South Capital LLP’s engagement  (COBS 2.2B.6 R (7))


  1. North of South Capital LLP as an investment firm is aware that conflicts of interest may arise when assessing whether and how to engage with companies. The Firm has a Conflict of Interest Policy in place to help define limitations, the need for robust internal processes and procedures to mitigate the risk of conflicts, as well as the disclosure being the last resort for instances in which potential or actual conflicts are unable to be effectively managed internally. Said policy shall apply to the Firm’s engagement and any proxy voting activity.


Annual Review & Disclosure


  1. The Firm shall disclose a general description of voting behaviour, an explanation of the most significant votes and report on the use of the services of proxy advisors.
  2. The disclosure must include details of how votes have been cast, unless they are insignificant due to the subject matter of the vote or to the size of the holding in the company.
  3. This shall be made freely available on North of South Capital LLP’s website and updated annually, unless there has been any material change.



Best Execution Policy


1. Background


Under the EU Markets in Financial Instruments Directive (MiFID) and COBS 11.2A of the Financial Conduct Authority (“FCA”) Handbook, North of South Capital LLP (“North of South”) must take sufficient steps to obtain the best possible result (or Best Execution) on behalf of its clients taking into account the execution factors. 

These rules require a firm to put in place an order execution policy which sets out how it will obtain Best Execution and the order handling for its clients and will provide appropriate information to its clients about its order execution policy.

This Order Execution Policy applies to Professional Clients dealing in Financial Instruments (as set out in Annex 1) where North of South executes orders on a client’s behalf.


2. Duty of Best Execution


The duty of Best Execution applies when executing orders on behalf of a client. North of South will be executing orders on a client’s behalf where the client legitimately relies on North of South to protect its interests in relation to the pricing or other aspects of the transaction that may be affected by how North of South executes the order. For example, this will be the case when North of South executes an order by dealing as agent.


This means that North of South will aim to provide Best Execution subject to, and taking into account, the nature of client orders, the prices available to North of South in the market, the nature of the market in question and a reasonable assessment of the execution factors (see below).


North of South’s intention, so far as possible, is to exercise consistent standards and operate the same processes across all markets, clients and financial instruments in which North of South operates.


3. Clients


North of South will only deal on behalf of Professional Clients as defined in MiFID and by the Financial Conduct Authority. Eligible Counterparties are not entitled to best execution as defined under the FCA/MiFID II requirements.


North of South will take into account the characteristics of the client n particular:



In line with the FCA rules North of South will NOT exempt particular products or activities from best execution requirements or permit clients to waive the application of best execution.


4. Order Execution Factors


North of South will exercise its own discretion in determining the factors that North of South needs to take into account for the purpose of providing clients with the best possible result.


These execution factors in the markets in which North of South operates will include, but are not restricted to:



Price will ordinarily merit a high relative importance in obtaining the best possible result.  However, in some circumstances North of South may appropriately determine that other execution factors are more important than price in obtaining the best possible execution result.  Given that North of South invests in emerging markets the non-price execution factors can be given greater weight than would be usual when trading in developed markets.


5. Assessing Costs


Cost is one of the execution factors and North of South have duty to control the costs incurred on behalf of their clients as it is integral to best execution for Professional Clients.


There are three broad categories of cost, all of which are relevant to Professional Clients:



For Professional Clients cost is simply one of the execution factors.


5.1 Implicit Cost Control


Implicit costs arise from the execution of all client orders. Firms should measure implicit costs as part of their arrangements to monitor execution performance and review the execution quality of entities or execution venues.


Implicit costs result from how a trade is executed (for example, immediately or worked over a period of time, in a block, aggregated with other trades, or as child orders sent to multiple different execution venues). A trade may appear more expensive in terms of explicit costs but may be less expensive when implicit costs are considered. For example, a firm that works a large order over time, preserving the client’s confidentiality and minimising market impact, may achieve the lowest total costs (and the best net price). Unlike explicit costs, the impact of implicit costs can only be precisely assessed after a trade is completed and even then, implicit costs are difficult to quantify. As a result, ahead of a trade, a judgement will be made by North of South about the likely implicit costs of an execution strategy and North of South will take all reasonable steps to manage them.


North of South will not discriminate unfairly between execution venues in the way in which they structure or charge commissions.  In other words, North of South will not charge a different commission or spread to clients for execution on different execution venues which is not related identifiable differences in the explicit costs incurred on behalf of clients


5.2 Explicit External Costs


This include commissions, fees, taxes, exchange fees, clearing and settlement costs, or any other costs passed on to the client by intermediaries participating in the transaction.


5.3 Explicit Internal Costs


This represents North of South’s own remuneration (including a commission or spread) for completing a transaction. These internal commissions and costs for executing an order must be taken into account in assessing where to execute the order, where there is more than one competing venue available. Thereafter, when judging whether best execution has been given on an individual transaction, firms can omit their own fees and charges from the assessment.


North of South will determine the relative importance of the execution factors by using its commercial judgment and experience in light of market information available and taking into account the execution criteria. 


6. Execution Criteria


The execution criteria that will be taken into account are the characteristics of:



Where a client order is received without a specific instruction, North of South will exercise discretion in determining the factors to be considered in order to provide the best possible result for the client.


6.1 Order Execution Venues


In meeting its obligation to take all reasonable steps to obtain on a consistent basis the best possible result for the execution of client orders, North of South may use one or more of the following venue types when executing an order on behalf of its clients:




North of South believes that these venues or sources of liquidity enable it to obtain on a consistent basis, the best possible result for orders North of South executes on behalf of its clients. North of South will assess which venues in the attached list (see Appendix 2) are likely to provide the best possible result for its clients on a transaction-by transaction basis.


6.2 Order Execution Timescales


Throughout the execution of your orders, we cannot be held accountable for any third-party failures

We do not owe you any fiduciary responsibilities over and above or regulatory obligation to provide you with Best Execution or as otherwise specifically agreed with us.


Regulations requires us to take sufficient steps to provide you with the best possible result on a consistent basis. Whilst we will robustly monitor the achievement of Best Execution, we cannot guarantee that we will achieve it for every order where we act on your behalf. Sale and buy orders with the same settlement date will be placed on the same day where possible.


It should be noted that if there is a delay in us receiving proceeds of the sale order, any further delay may be caused to the buy order.   


7. Cancellation


We reserve the right to cancel an order without notice where we believe this is sufficiently justified. This may include, but is not limited to, circumstances where we are requested to do so by our counterparty or the relevant exchange, or where we believe there may be potential market abuse.


We will not be liable for any loss you incur because of the cancellation of an order in these circumstances.


8. Broker Review


North of South informs its brokers that it expects them to provide best execution regardless of market practices in the relevant markets or of the capacity in which the broker transacts.


If and when North of South trades instruments in instruments where brokers are acting as broker rather than as principal and the concept of best execution exists in the relevant market, North of South will seek to impose a best execution obligation on the brokers to whom orders have been placed. 


Monitoring and review will take the form of semi-annual commission rate review and review of each execution against price recaps to determine if best execution has been obtained.  Where either a broker is acting as principal or the concept of best execution does not apply in the relevant market North of South will make an ex-ante assessment of which broker it believes can deliver best execution and on an ex-post basis will review of each execution against price recaps to determine if best execution has been obtained.


9. Governance


North of South has established a Best Execution Committee which meets on a semi-annual basis to assess whether the execution venues listed above continue to provide the best possible result for the Firm’s clients. As part of this review, the Firm takes into consideration the annually published execution data made available by trading venue operators and other investment firms. The Best Execution Committee approves all execution venues (and their terms of engagement). Execution venues may only be added to the list with the consent of the Best Execution Committee and they will consider factors including but not limited to: credit and counterparty risk; the level of service; and markets covered during their due diligence process and ongoing review. Where only one execution venue is available to North of South for a particular class of financial instrument, the Best Execution Committee will additionally consider whether the execution venue enables the Firm to consistently achieve the best results for its clients and whether any other suitable venues exist.


10. Policy Review & Disclosures


North of South continually (and formally at least annually) reviews the effectiveness of this policy and its execution arrangements to identify and, where appropriate, incorporates any changes to enhance the quality of execution obtained.


North of South  provides all its clients with a copy of its Best Execution Policy (otherwise known as an Order Execution Policy) and confirms their consent in writing (or by email) to it prior to the provision of services.


North of South  will notify its clients of any material changes to this policy. A change is material where it would affect the best execution parameters and/or its disclosure is necessary to enable clients to make a properly informed decision about whether to continue utilising the services of the Firm.



11. Publication of top execution venues and summary analysis of execution quality


On an annual basis, North of South  summarises and makes public, for each class of financial instrument, the top five entities in terms of trading volumes where the Firm transmitted or placed orders for execution in the preceding year.


In addition to the above, North of South  publishes for each class of financial instrument, a summary of the analysis conducted and conclusions drawn from the monitoring of the execution venues utilised. Specifics of what the analysis is to cover include:


North of South  publishes this information on the Firm’s website in a machine-readable electronic format available on our website at www.northofsouth.com



Appendix 1: Financial Instruments as defined in Annex 1, Section C, of MiFID




Appendix 2: Order Execution Venues


The following list is not exhaustive and may change from time to time as venues are accessed differently, or markets or normal process change. It is open to North of South Capital to use venues not referenced on the list below where we believe it to be necessary to obtain Best Execution:


Abu Dhabi Securities Exchange; Athens Stock Exchange; Australian Stock Exchange; BM&F BOVESPA; Bombay Stock Exchange; Bolsa de Valores de Columbia; Budapest Stock Exchange; Bursa Malaysia Colombo Stock Exchange; Egyptian Stock Exchange; Frankfurt Stock Exchange; GreTai Securities Market; Harare Stock Exchange; Hong Kong Stock Exchange; Indonesia Stock Exchange; Irish Stock Exchange; Istanbul Stock Exchange; JSE Securities Exchange; Korea Exchange; Lima Stock Exchange; London Stock Exchange; Madrid Stock Exchange; Mexican Stock Exchange; NASDAQ Stock Market Exchange; National Stock Exchange of India; New York Stock Exchange; Nigerian Stock Exchange; NYSE ARCA; NYSE Amex Equities; Philippines Stock Exchange; Prague Stock Exchange; Russian Trading System Stock Exchange; San Jose Stock Exchange; Santiago Stock Exchange; Shanghai Stock Exchange; Shenzhen Stock Exchange; Singapore Stock Exchange; Stock Exchange of Thailand; Taiwan Stock Exchange; Tel-Aviv Stock Exchange; Tokyo Stock Exchange; Toronto Stock Exchange; TSX Venture Exchange; Vienna Stock Exchange; Warsaw Stock Exchange