Disclaimer & Modern Slavery Policy
Legal and Regulatory Terms
This website is communicated, issued and approved in the UK by The Lazarus Partnership Limited (Lazarus, us), a company which is authorised and regulated by the Financial Conduct Authority (FCA Register Number FRN: 60643) and is a Registered Investment Adviser with the U.S. Securities and Exchange Commission (CRD 175120 / SEC 801-81106).. Lazarus is a company incorporated in England and Wales (Company number: 07675948) and its registered address and principal office is at 18 St Swithin’s Lane, London EC4N 8AD.
Terms of Website Usage
The material and content of this website relate to information about Lazarus and the services provided by Lazarus. There are pages which contain research prepared by Lazarus. Lazarus Research is only available to customers who have signed legal agreements to access those pages. The services described in the website are available solely to eligible counterparties and professional clients as defined by the Financial Conduct Authority and Major Institutional Investor’s resident in the U.S. It is not suitable for, nor intended for any persons deemed to be a “Retail Customer” under the FCA Rules or those deemed to be a ‘Retail Investor’ under the US SEC rules or the equivalent in other jurisdictions. The services are not directed at, and may not be suitable for retail investors and therefore should not be relied upon by retail investors. The materials in this website have been prepared for persons resident in the United Kingdom. You must satisfy yourself that you are eligible to receive services and the materials outlined in this website according to local regulation and legislation and are urged to seek your own advice if you are in any doubt. Lazarus accepts no responsibility for any failure by a person resident outside the United Kingdom to observe the foregoing.
None of the content of this website constitutes an offer, solicitation or recommendation to buy or sell any investment or to provide any investment, legal or tax advice and should not be relied upon in making an investment decision.
Lazarus reserves the right to terminate your access to this website without notice if it has cause to believe that your continued access is in violation of any relevant legislation or regulation or is harmful to Lazarus or any of its customers.
Disclosure of Interests
Lazarus has robust policies and procedures in place designed to capture, manage and record any conflicts of interest which might arise in the course of its business operations. However, Lazarus employees and its Directors may from time to time, have investments and financial interests in the shares of issuers referred to within the website. As such those individuals may carry out transactions involving those shares. Lazarus may provide and seeks to provide bespoke services to those issuers for which it will be compensated. Further information relating to our Conflicts Management Policy can be obtained on request from the Lazarus Compliance department.
Accuracy of Information
The material and content of this website may have been derived from multiple sources including third party data vendors and subscription based tools. Whilst Lazarus will use only reputable sources and suppliers which it believes to be reliable, Lazarus does not warrant its completeness, timeliness or accuracy and accepts no liability in providing access to the materials. Any dated information is accurate only as the day it is published and Lazarus does not undertake any obligation to update or amend any such information.
Intellectual Property Rights including Copyright and any other rights of whatever nature in and to the Services and Research Products shall remain the property of and are vested in Lazarus and/or, where applicable, its licensors. Any right or interest in, the Services, Portal or Research Products are reserved to Lazarus and/or its licensors.
By using the pages on this website, and/or by reading the material within it, you agree that you will use the materials solely for your personal use and that you do not otherwise download, copy, transmit or distribute in by any method, any whole, part or extract of these materials without the express permission of Lazarus. Unauthorised use of Lazarus trademarks, trade names and logos is prohibited.
Use of Hyperlinks
From time to time, Lazarus may use hyperlinks in its materials available through this website and in using these hyperlinks you may not benefit from the protection afforded to you on which you may otherwise rely by using this website. These are provided for your information only and Lazarus accepts no responsibility or liability for the content of any website that you access from a hyperlink provided in this website. Any such website will have their own terms of usage, disclaimer and copyright restrictions.
Security of Data
Lazarus endeavours to protect any and all information provided to it through the website or via electronic means. Please note that internet communication is not secure unless encrypted and therefore Lazarus cannot guarantee or accept responsibility for the security of information you send to us, from you via the internet.
Limitation of Liability
Lazarus makes no warranty, express or implied relating to the services highlighted in this website. Lazarus expressly disclaims without limitation any warranty for the use of the results of the use of the services with respect to their correctness, quality, accuracy, completeness, reliability, performance timeliness or continued availability.
In no event will Lazarus be liable for any loss or damage of any kind including, without limitation, any direct, special, indirect or consequential damages, even if expressly advised of the possibility of such damages, arising out of or in connection with the use of, performance of, or your browsing in, or your links to other sites, from this site. Save that nothing shall exclude or limit Lazarus liability for fraud or for death or personal injury caused by its negligence or any other liability to the extent that the same may not be excluded or limited as a matter of law.
This site is established in England in accordance with and shall be governed by, and you’re browsing in and use of the site shall be deemed acceptance of, the laws of England and Wales. A condition of using the site, is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum. Each time you use the site, a condition of use is that you comply with the above terms.
Access to this site is confirmation that you have understood and accepted these terms. If you do not agree with our Terms of Website Usage please do not use or access the Website.
Communication: If you have any questions about this privacy statement, or our privacy practices, you can contact the company by sending a letter to The Lazarus Partnership Limited, 18 St Swithin’s Lane, London EC4N 8AD.
Information We Collect: You can browse the Website without telling us who you are or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us. If you choose to use our services, we may require you to provide contact and identity information, payment information, address information and other personal information. You always have the option to not provide information by choosing not to use a particular service or feature. For every visitor, we automatically collect and store: the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access the Website; and the Internet address of the site from which you linked directly to our sites. We use this information only as anonymous aggregate data to determine the number of visitors to different sections of the Website, to ensure the Website is working properly, and to help us make the Website more useful. We use your IP address to help diagnose problems with our server, and to administer the Website. Your IP address is also used to gather broad demographic information. We do not install, download or otherwise distribute or utilize Spyware on the Website.
How We Use Information We Collect: We do not sell, rent, trade or otherwise share any personally identifiable information about our users to any third party. This includes, but is not limited to the names, addresses, e-mail addresses, and phone numbers of our users. In addition, we will not disclose any personally identifiable financial or security-related personally identifiable information. We may share the personal information you provide with other companies we have hired to provide services for us. These companies, our vendors, are contractually bound to use personal information we share with them only to perform the services we have hired them to provide. We will release information about you if you direct us to do so, if we are required by law to do so, or in other legally limited circumstances (for example, to protect your account from fraud).
Email: Any information that is submitted to us via email becomes our property and may be used at our discretion. The information you send to us may be stored and used to improve the Website and our products, or it may be reviewed and discarded.
Links: The Website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites and make no statement on the privacy policies of sites not under our direct control.
Changes: Our business changes regularly; this privacy statement will change also, and use of information that we gather now is subject to the privacy and security statement in effect at the time of collection. You should check this policy frequently to see recent changes.
Ethical Procurement & Modern Slavery Policy
People are our business and Lazarus Research is committed to dealing with clients, candidates and third parties honestly, ethically and with integrity.
This extends to both our own internal processes within the business and externally in supporting the declared policies that our clients practice.
Ethical Procurement & Modern Slavery Policy
At Lazarus Research we insist on ethical standards from our suppliers and clients, and in turn we must exhibit the highest ethical standards ourselves. We must not only be fair and above board in our dealings, but avoid any conduct which is capable of having an adverse interpretation put on it.
It is the duty of all employees, to maintain and be seen to maintain this unimpeachable standard of integrity in all business relationships, both internally and externally, and firmly to reject those practices which might reasonably be deemed improper so ensuring that both employees and Lazarus Research are trusted and respected by all for not only carrying out its business efficiently but in a fair and reasonable manner and with integrity.
Our guiding principles of ethical behaviour in procurement are:
- That the conduct of staff should not foster the suspicion of any conflict between their official duty and their private interest,
- That the action of staff should not give the impression to any member of the public, to any organisation with whom they deal or to their colleagues that they have been or may have been influenced by a gift or a consideration to show favour or disfavour to any person or organisation,
-That dealings with suppliers and associates must at all times be honest, fair and even-handed, in line with the requirements placed upon us by the Public Procurement Regulations 2006,
-That ethical behaviour must be promoted and supported by appropriate systems and procedures.
Fortunately, corruption is rare in this country’s commercial environment but it is present. Any improper approaches whether in the form of inducements or threats, must be reported.
Furthermore, Lazarus Research seeks to provide a healthy and safe working environment for their employees and will endeavour to ensure that working conditions exceed international labour standards and are in accordance with the Modern Slavery Act 2015. This includes:
- No forced labour and employment is freely chosen,
- The right of freedom of association is respected and encouraged by the employer,
- No child labour is used,
- Living wages are paid (wages should always be enough to meet basic needs and to provide some discretionary income),
- No harsh treatment is used or discrimination practised,
- Workers are not pressurised to undertake overtime they do not wish to do,
- A safe and hygienic working environment shall be provided,
- Put in place sufficient systems to monitor and take responsibility for compliance with social policies,
- Conduct regular assessments of our operations to identify eventual non- compliance cases,
- Develop remediation plans to resolve non-compliance cases,
- Regularly monitor the effective implementation of remediation plans,
- Make sure that our suppliers and associates ensure that workers’ conditions in their operations meet (or exceed) the above standards. Lazarus Research will continue to update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.
To achieve a high standard of health and safety the active co-operation of all employees is essential. Employees are reminded of their own duties under the Health and Safety at Work Etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 to take care of their own safety and that of other persons and to co-operate with their employer so as to enable him to carry out his responsibilities successfully.
Lazarus Research will continue to update its policies and procedures as required to ensure it maintains appropriate safeguards against any mistreatment of persons involved in its supply chain or own business.