Item 5: Additional compensation 16
Item 6: Supervision 16
FIRM INFORMATION
This Disclosure Brochure (‘Form ADV Part 2’) provides
information regarding the qualifications, business
practices, and the advisory services provided by Ruffer
LLP (‘the Firm’, ‘we’, ‘us’, ‘ours’).
We are a federally Registered Investment Adviser
with the US Securities and Exchange Commission
(SEC) and regulated by the UK’s Financial
Conduct Authority.
Ruffer is an independent Investment Manager,
founded in 1994 by Jonathan Ruffer (Chairman), to
provide a different approach to discretionary fund
management. We are owned and operated by the
existing and former partners of the Firm. Members of
the partnership contribute capital to and share in the
profitability of the Firm. We believe this arrangement
aligns the interests of the partnership with those of our
clients, in seeking to achieve long term, sustainable
investment returns and client relationships.
TYPES OF ADVISORY SERVICES
We provide discretionary investment management
services to high-net-worth individuals, banks or
thrift institutions, investment companies, wealth
management platforms, pension and profit-sharing
plans, ERISA plans, trusts, estates and charitable
organizations, corporations and other business
entities. In addition, the Firm also manages a number
of investment vehicles; including a London listed,
Guernsey registered investment company, a number
of UK and Luxembourg domiciled UCITS collective
investment schemes and a Cayman Limited Company
master feeder fund (with Cayman Limited Company
and Delaware Limited Partnership feeder funds).
Our compensation is solely from fees paid directly by
clients. We do not receive commissions based on our
clients’ purchase(s) of any financial product, including
insurance. No commissions in any form are accepted.
INVESTMENT MANAGEMENT SERVICES
We will manage investment accounts on a discretionary
basis only. This service typically includes the selection,
monitoring and review of portfolio assets, and follows a
single investment philosophy and process.
Prior to investment, we will gather information about
a client’s financial situation, including investment
objectives, risk capacity and constraints, to ensure that
our approach is appropriate. The client will enter into
an Investment Management Agreement (IMA) with us
prior to the management of the portfolio beginning.
The IMA sets out the terms of the engagement.
We manage all client portfolios in line with our single
investment approach, which is described as a global,
macro-driven,
absolute return strategy. We have two
simple investment objectives
1 not to lose money in any rolling 12-month period
2 to grow funds at a higher rate than would be
achieved by depositing them in cash
The portfolios we create for our clients have no con-
straints on their asset allocation. This means they will
typically consist of some or all of the following assets:
equities, bonds, Ruffer-managed funds, third party
managed funds, commodities, foreign currencies and
derivatives. The portfolio’s multi-asset allocation will
be built to reflect our stated investment objective to
preserve capital as well as any investment constraints
imposed by the client.
TAILORED RELATIONSHIPS
Whilst keeping to the dual investment aims described
above, we tailor investment advisory services to the
individual needs of the client. Our clients are allowed
to impose restrictions on the investments in their
account. All limitations and restrictions placed on
accounts must be presented to us in writing.
WRAP FEE PROGRAMS
A ‘wrap-fee’ program is one that provides the client
with advisory and brokerage execution services for
an all-inclusive fee. The client is not charged separate
fees for the respective components of the total ser-
vice. We do not sponsor, manage or participate in a
wrap-fee program.
FIDUCIARY STATEMENT
Both we and our employees are fiduciaries who must
take into consideration the best interests of the Firm’s
clients. We will act with competence, dignity, integrity,
and in an ethical manner, when dealing with clients.
We will use reasonable care and exercise independent
professional judgement when conducting investment
analysis, making investment recommendations,
trading, promoting our services, and engaging in other
professional activities.
As a fiduciary, we have the obligation to deal fairly
with our clients. We have the following responsibilities
when working with a client –
–to render impartial advice
–to make appropriate recommendations based on
the client’s needs, financial circumstances and
investment objectives
–to exercise a high degree of care and diligence to
ensure that information is presented in an accurate
manner and not in a way to mislead
–to have reasonable basis, information, and under-
standing of the facts in order to provide appropriate
recommendations and representations
–disclose any material conflict of interest which can’t
be mitigated/managed in writing and
–treat clients fairly and equitably.
ASSETS UNDER MANAGEMENT
As of 31 March 2023, our assets under management
are $31,345,000,000. This number represents all the
assets the Firm manages for its discretionary clients.
Currently, the asset under management for US clients
is $178,484,000.