Regulatory Disclosures

Privacy Notice

Cookies Policy

Last Updated: September 2024

COOKIE USAGE INFORMATION

This website uses cookies to personalize content and analyze our traffic and this notice explains what cookies are and the types of cookies Capstone Investment Advisors, LLC uses on www.capstoneco.com and the webpages accessible through www.capstoneco.com (collectively, the “Sites”). The cookies are designed to customize and improve users’ visits to our Sites, to deliver content tailored to users’ interests and the manner in which they browse our Sites, and to manage our Sites and other aspects of our business.

WHAT ARE COOKIES?

A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Those cookies are set by us and are called first party cookies – we currently do not use any first party cookies.

We also use third party cookies – these are cookies from a domain different than the domain of the website you are visiting or a domain we are not operating – for example to protect the security of our website.

WHAT TYPES OF COOKIES ARE USED ON THE SITES AND HOW DO WE USE THEM

We use strictly necessary cookies to: (i) detect non-logged in users and to restrict access to secure areas; (ii) provide notification when an administrator logs in from a new device or location; and (iii) provide two-factor authentication.  Strictly necessary cookies always need to be on.

We use non-essential (non-strictly necessary) cookies to gather statistics and analytics information about you as a user, including how you got to the website, the pages you visit and how long you spend on each page, and what you click on, so that we can understand how you use the website.

Cookies may be first party or third party, meaning they are operated by us (first party) or by another party (third party). We currently do not use any first party cookies. Please note that interactions with the third party cookies on our website are governed by the privacy and cookie policies of the third party as set out below.

MANAGING COOKIES

On your first visit to our website and every six months thereafter,  on the homepage you will see a cookie banner informing you why cookies are used, and asking you to consent to each non-essential cookie if you agree with us using them (or “Accept All Non-Essential Cookies”). If you do not agree, you can select which ones to reject or accept or you can choose to “Reject All Non-Essential  Cookies”.

You can change your cookie preferences through the cookie banner, where you have the option of opting-in or opting-out to the use of non-essential cookies on your device. However, you can also update your cookie preferences at all times by using the button at the bottom left of this page .

COOKIE PREFERENCES

Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

 

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout

Please note that you cannot disable strictly necessary cookies since these affect the functionality of our website and your ability to use certain features and functionalities.

Types of Cookies Used

Operator Cookie Name Session or Persistent Purpose Lifespan
Strictly Necessary Cookies
Wordfence wfwaf-authcookie-(hash) Session Functional – detect non-logged in users and to restrict access to secure areas Session
Wordfence wf_loginalerted_(hash) Session Functional – provide notification when an administrator logs in from a new device or location Session
Wordfence wfCBLBypass Session Functional – security Session
Wordfence wfls-remembered-(hash) Persistent Functional – provide two-factor authentication Up to 30 days
Non-Essential Cookies
Google Analytics _ga Persistent Statistics and Analytics – count and store page views Default is 2 years
Google Analytics _ga_<container_id> Persistent Statistics and Analytics – count and store page views Default is 2 years
Google Analytics _gid Session Statistics and Analytics – registers a unique ID that is used to generate statistical data on how the visitor uses the website Session

 

List of Third Parties Using Cookies on our Website

Name Third Party Purpose of Cookie Set by Third Party Third Party Business Link to Cookie and Privacy Policy
Google Analytics Statistics and Analytics – count and store page views Google https://policies.google.com/privacy
Wordfence Functional – security purposes Wordfence https://www.wordfence.com/privacy-policy/#:~:text=They%20help%20us%20understand%20which,used%20to%20visit%20our%20Sites.

 

Contact Us

For more information on our use of cookies on our website, please contact us at:

 

By Post:

Steve Schatteman

Capstone Investment Advisors, LLC

7 World Trade Center

250 Greenwich Street, 32nd Floor

New York, NY 10007

 

Capstone Investment Advisors (Italy) S.R.L.

Via Ciovassino, 1

20121, Milano, Italy

 

Steve Schatteman

Capstone Investment Advisors (UK), LLP

10 New Burlington Street, 1st Floor

London, UK W1S 3BE

  1. +44 0207 297 0411

 

By Email: [email protected]

 

For more information on how we process personal data including through the use of cookies, if any, please visit our Privacy Policy.

 

UK Stewardship Code

Capstone Investment Advisors (UK) LLP supports the stewardship code’s objectives but does not claim to comply with the code as its investment strategies do not generally involve taking positions in UK listed stock. Moreover, if we were to take a position in a UK listed stock, our investment strategy would be to trade the volatility of the security and this investment strategy is not consistent with the principles of the code.

Shareholder Rights Directive Statement

Capstone Investment Advisors (UK) LLP firmly believes in the importance of effective stewardship and long-term decision making, involving transparency of engagement policies between institutional investors and the investee companies.  However, Capstone believes that its investment strategies and operational structure are not compatible with shareholder engagement activities.  Capstone invests across a variety of asset classes, in various jurisdictions. As a result, most of its investment activities relate to assets other than listed Equities, and for the portion of investments that is focused on equities the exposure is not typically taken on an activist investor basis. As such, Capstone does not currently maintain and will not publish an engagement policy as specified by the Shareholder Rights Directive (“SRD II”).  Capstone shall periodically review its investment strategies to determine whether its investment activities have changed to the extent that Capstone should adopt an engagement policy under SRD II.

Public Disclosure

Statutory Status Disclosure and Complaints

Capstone Investment Advisors (UK) LLP is authorised and regulated by the Financial Conduct Authority. For professional investors only.

COMPLAINTS HANDLING POLICY
We aim to ensure that we treat our customers fairly at all times. Any complaints will be investigated competently, diligently and impartially, assessed fairly and promptly with respect to the subject matter of the complaint, and whether the complaint should be upheld and what remedial action or redress may be appropriate.

The FCA’s Dispute Resolution (“DISP”) handbook sets out the rules relating to the handling of complaints from eligible complainants and MiFID clients. We have determined that we have no eligible complainants under the DISP rules at present.

However, certain consumers could be considered to be eligible complainants under the DISP rules in the future and, as such, we will apply the rules within DISP with respect to those investors.

COMPLAINTS HANDLING PROCEDURE
We define complaints as follows with respect to the two categories of complainants:

Eligible complaint – defined by the FCA as meaning ‘any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service which (a) alleges that the complainant has suffered (or may suffer) financial loss, material distress of material inconvenience; and (b) relates to an activity of that respondent, or any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service (“FOS”).

MiFID complaint – defined as ‘any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service or a redress determination which alleges that the complainant has suffered or may suffer financial loss, material distress or material inconvenience’. This does not come under the jurisdiction of FOS.

Upon receipt of a Complaint, as defined above, the Chief Compliance Officer will ensure that eligible complainants are provided a copy of this document, which constitutes our complaints handling policy, when acknowledging a complaint.

We will endeavor to communicate with you clearly and in plain language that is easy to understand and reply to your complaint without undue delay. As soon as we have made the relevant enquiries and reviewed your complaint we will write to you. If we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in your complaint, we may promptly forward the complaint, or the relevant part of it, in writing to that other respondent. We will inform you promptly in a final response of the reason for forwarding the complaint, including the other respondent’s contact details. Where jointly responsible for the fault alleged in the complaint, we will comply with own obligations under the DISP rules in respect of that part of the complaint we have not forwarded.

We will endeavor to write to you within eight weeks.

All complainants should contact the Chief Compliance Officer.

Contact: Emily Locher

Email: [email protected]

FINANCIAL OMBUDSMAN SERVICE (“FOS”)
We are required to provide clear and accessible information about the Financial Ombudsman Service (“FOS”) including its website address.

If your complaint is not resolved by us to your satisfaction, and if your complaint falls within the jurisdiction of the FOS, then you may take your complaint to the FOS.

If a business and a customer can’t resolve a complaint themselves, the FOS can give an unbiased answer about what’s happened. If the FOS decide someone’s been treated unfairly, they have legal powers to put things right. In order to contact the Financial Ombudsman Service or obtain details of the compensation scheme you should:

Modern Slavery Statement

Sustainable Finance Disclosure Regulation

SUSTAINABLE FINANCE DISCLOSURE REGULATION
Capstone Investment Advisors, LLC (“Capstone”) has made a determination that sustainability risks are not currently relevant to its investment decision making process and has further determined that sustainability risks are currently not likely to have a material impact on the returns of its investment portfolios. Given the focus of the investment portfolios on volatility, relative value strategies and seeking risk-based returns, Capstone generally does not expect sustainability risks and their associated effects on the underlying value of investments to influence the selection and performance of investment portfolio positions. Capstone may consider it appropriate to integrate sustainability risks into its investment decisions in the future and this disclosure will be updated in accordance with the Disclosures Regulation to reflect any such decision.

Taking into account the size, nature and scale of its activities, and as the primary objective of Capstone is to achieve attractive risk-adjusted returns for investors, Capstone considers it would be disproportionate to consider principal adverse impacts of investment decisions on sustainability factors at this time.  Capstone therefore does not currently consider principal adverse impacts of investment decisions on sustainability factors.  Capstone acknowledges that the pursuit of the investment portfolios’ objectives may, in some circumstances, have an adverse impact on sustainability factors.

Transparency in Coverage

US Insurance Provider – Cigna Readable Files

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

Japan Financial Instruments and Exchange Act

The following entit(ies) have submitted the Article 63 filing under the Financial Instruments and Exchange Act of Japan. Please email [email protected], if you would like to obtain public disclosure documents. Please note that none of the Capstone entities other than the entit(ies) listed below as the general partner and filing entity has conducted or will conduct a private placement or investment management as may be permitted under the Article 63 filing.
General partner, filing entity
Capstone Fund Services, LLC
Capstone Fund Services II, LLC

Additional Disclosures for Capstone Video Presentations

For professional investors only.

The information presented on this website reflects, as of the date hereof, the views of Capstone Investment Advisors, LLC (“Capstone”) and sources believed by Capstone to be reliable. No representation or warranty is made concerning the accuracy of any data compiled herein. In addition, there can be no guarantee that any projection, forecast or opinion in on this website will be realized. The content presented on this website is provided for informational purposes only, and under no circumstances may any information contained herein be construed as investment advice. Capstone does not provide tax, legal or accounting advice. This presentation is not an offer or solicitation for the purchase or sale of any financial instrument, product or services sponsored or provided by Capstone.

This content presented on this website is provided for informational purposes only, reflecting prevailing market conditions and our judgments as of the date indicated herein. Opinions and estimates may be changed without notice and involve a number of assumptions which may not prove valid.

Capstone is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended. Registration of an investment adviser with the SEC does not imply a certain level of skill or training.