Background and Scope

Winton takes its fiduciary obligations seriously and operating our business in a responsible and ethical manner is core to our firm’s values. We consider corporate social responsibility to concern both how we behave as an organisation and the investments directed by our strategies.

Below is a discussion of topics relevant to responsibility at Winton and includes governance, regulation, philanthropy, community and environmental responsibility.

Governance

Winton’s corporate governance structure is proportionate to the firm’s size and complexity. The structure primarily comprises the Winton Group Board and the Executive Management Committee. These two bodies oversee the management of the relevant business areas to ensure that we conduct our business appropriately, with integrity, and with due regard for the interests of all stakeholders. The Group Board includes both executive and non-executive directors.

Regulation and Ethics

Winton is committed to the highest standards of ethical conduct and has adopted a Code of Ethics that sets out the standard of business conduct that all employees must follow. The Code of Ethics makes a commitment to act ethically and with integrity, act in the best interests of clients, manage and disclose conflicts of interest, observe proper standards of market conduct and raise serious concerns or complaints about potentially unethical or improper conduct without fear of reprisal or dismissal.

Employees receive annual training on the Code of Ethics and other compliance training designed to ensure employees understand the regulatory standards and obligations that apply to Winton and to them as employees. A monitoring framework is in place to ensure adherence to Winton’s compliance policies and procedures.

Winton also understands the economic and social impact of financial crime and as a financial institution we have policies, procedures, systems and controls to comply with economic sanction regimes and to prevent our products and services being used for money laundering purposes or in connection with other types of financial crime including fraud, bribery and tax evasion.

In addition, we believe that effective regulation has a vital role to play in fostering innovations that are positive for society. Winton has long been a supporter of good rulemaking, and we seek to maintain open and constructive dialogue with the authorities that regulate our market activities worldwide. Winton has a history of engaging with other participants in the industry in order to improve industry practices and promote high standards, evidenced in the firm’s status as a founding signatory of the Standards Board for Alternative Investments (SBAI). Winton is also a member of industry groups including the Alternative Investment Management Association (AIMA) and the Managed Funds Association (MFA).

Philanthropy

Winton sponsors academic prizes, doctoral and post-doctoral research and academic events in the fields of maths, physics, computing, statistics and data science at 11 academic institutions across the UK. The firm also matches donations made by employees and employee fundraising – up to a limit of £10,000 per employee per annum – and allows UK based employees to donate to charities through payroll.

Winton’s founder and CEO, David Harding, is an active philanthropist through the David and Claudia Harding Foundation, supporting a range of initiatives related to science and mathematics, as well as other projects of personal interest such as the history of finance. In February 2019, the Foundation gave £100 million to Cambridge University, part of which funds the Harding Distinguished Postgraduate Scholars Programme.

Other notable endowments include the Winton Centre for Risk and Evidence Communication at the University of Cambridge, the Winton Programme for the Physics of Sustainability at the Cavendish Laboratory, the Harding Center for Risk Literacy at the Max Planck Institute in Berlin and Mathematics: The Winton Gallery at the Science Museum in London.

Community

Winton aims to contribute positively to the communities in which it operates. We seek to achieve this, in part, through philanthropy (described above) and through partnerships with community organisations to tackle specific problems. Such partnerships may involve employees contributing time towards a chosen project.

Environmental Responsibility

Winton is mindful of its environmental impact and seeks to adhere to the relevant environmental standards in the countries in which it operates.

In our London headquarters, we have entered into an agreement with the Low Carbon Workplace Trust. The scheme aims to deliver low-use carbon emissions by improving the fabric of the building, deploying high-efficiency technologies to heat, cool and ventilate the space, and reducing operational energy consumption through sophisticated energy monitoring. Where possible we source sustainable/recyclable products e.g., Compostable coffee cups, tea sourced from a B Corp-certified company and greener cleaning products.

We also receive ongoing advice from the Low Carbon Workplace Trust to help minimise carbon emissions, showing continued results in achieving energy usage levels well below the suggested ECON19 benchmarks.

In order to promote using low carbon transport, Winton offers an electric vehicle leasing scheme (through Octopus EV) and the Cycle to Work scheme for its UK-based employees.

Reporting

We publish the following statements and disclosures on our website (www.winton.com/policies-disclosures), which are updated as appropriate:

- Transparency Statement on Modern Slavery

- Sustainable Finance Disclosure Regulation

- Responsible Investment Policy

- An overview on our alignment with the Financial Reporting Council’s UK Stewardship Code

- Diversity and Inclusion Statement