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Elle Murgartroyd 23021416 Word Count: 3176 THE LACE AND HOSIERY WORKERS PROVIDENT CHARITY (LHWPC) Assumed Control: 31 st March 2015

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Page 1: Investment Portfolio

The Lace and hosiery workers provident charity (lhwpc)

Elle Murgartroyd

23021416 Word Count: 3176

Assumed Control: 31st March 2015

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ContentsIntroduction..............................................................................................................................2Current valuation of Investments...........................................................................................2Trustee’s responsibilities.........................................................................................................2Trustee comments and concerns.............................................................................................3Market/Economic background...............................................................................................3Risk Management.....................................................................................................................4Investment Theories and core strategy..................................................................................4Portfolio changes......................................................................................................................5The new suggested portfolio with likely income....................................................................6Conclusion.................................................................................................................................6Appendix 1 – Current Portfolio..................................................................................................7Appendix 2 Re-valued Portfolio (Trustnet, 2015) (Lansdown, 2015).......................................8Appendix 3 – Adapted Portfolio (Trustnet, 2015) (Lansdown, 2015).......................................9Appendix 4 Trustee Act 2000..................................................................................................10Appendix 5 Trustee comments.................................................................................................42Appendix 6 The Big Five (EthicalConsumer, 2012)...............................................................43Appendix 7 Risk Management (SRA, 2014)...........................................................................44Appendix 8 – SWOT Analysis.................................................................................................44Appendix 9 – Modern Portfolio Theory, Efficient Frontier and Risk (SMART401K, 2015). 45Appendix 10 – The Efficient Market Hypothesis (Boundless, 2015)......................................45Appendix 11 – CF Odey Opus Class I – Accumulation (GBP) (FundsLibrary, Hargreaves Lansdown, 2015)......................................................................................................................46Appendix 13 – Rathbone Ethical Bond (Rathbone, 2015).......................................................47Appendix 14 – Diageo – Ethics (Diageo, 2015)......................................................................47Appendix 15 – SABMiller – Ethical Practices (SABMiller, 2014).........................................48Appendix 16 – New Portfolio 6 Month Previously (Trustnet, 2015) (Lansdown, 2015)........49Glossary....................................................................................................................................50Bibliography.............................................................................................................................51

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The Lace and Hosiery Workers Provident Charity (LHWPC)

IntroductionWe have been presented with a portfolio set up for a charity that is clearly inappropriate and will be needing changes. We are given comments from Trustee members that highlight the key issues that they feel are significant and must therefore be addressed. It is therefore important to create a portfolio that produces capital growth in addition to income, however it must not be too risky. The level of risk was brought up my multiple Trustees and should be addressed immediately. Equally, we need to look into changing the current asset allocation as this will help to lower the level of risk but also make it more appropriate for their needs. This portfolio is heavily invested in individually quoted equities which is one of the riskier forms of investing. We must therefore look into different investment strategies to create a new broader and lower risk asset allocation. In doing so we can also add more diversification (another issue raised by trustees). Currently, the portfolio includes multiple investment within the same industry or sector which can cause an increase in unsystematic risk (see glossary). This is a diversifiable risk that we can lower through increased diversification of both companies and industries across various asset classes. I will demonstrate how this can be done to achieve lower risk growth of but with reasonable growth prospects and dividend income by a combination of:

Income – Equities, Gilts and Bonds producing dividends (referred to as yield in the case of Bonds)

Growth – Equities.

Current valuation of InvestmentsIn order to make decisions on what aspects of the current portfolio to change it was essential to revalue all assets at today’s prices (31st March 2015) this then gave us a picture of how that portfolio had performed and which assets should be removed. Before the revaluation (see appendix 1) it was clear that this was an inappropriately high risk ‘aggressive’ portfolio, two things that a charity’s portfolio should avoid. After the revaluation (see appendix 2) it is clear that the value of this portfolio has increased somewhat when compared to the previous valuation point. The previous total investment of assets (including cash) amounted to £5,274,871 and the revaluation amounts to £7,156,006. Although this does show a significant increase, the range of shares and the lack of diversified industries reflects more risk than desired. The primary increases were seen within the Investment trusts with Alliance Trust increasing by 12.22%, Monks Investment Trust increasing by 13.52% and Fidelity China Special Situations increasing by 46.53%. Murray International Trust was the only trust within the portfolio to see a reduction with it reducing by 6.24%.

Trustee’s responsibilitiesThe Trustee Act 2000 (see appendix 4) outlines the key provisions and responsibilities of Trustees (see glossary) and notes the investments powers that they have. Also, a Trustee may now make investment decisions on behalf of a trust as if they themselves were the sole owner. Although this power is available, settlors (see glossary) of the trust do not need to agree to this and may opt to restrict this power. Equally, a settlor can limit or widen the types of investments that can be made. An example of this would be if the settlor restricted all trust investment to be made in property or they could be more flexible and not limit the trust to this. The Trustee Act 2000 has introduced new responsibilities and duties that ordinarily cannot be removed. Prominently mentioning how the trustee must act in the best interest of the beneficiaries (see glossary) and trustees shall not themselves, profit from their investing. This would vary in the event that a beneficiary is a trustee, however in this case the trustee must still invest impartially between the beneficiaries. This

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references to a trust having multiple beneficiaries whereby some are entitled to income and others, capital.

The Act then goes on to states the difference that professional Trustees have and the higher standard that they must follow. Professional trustees must act will extreme skill and diligence due to the assumed level of skill and experience, unless a family/friend trustee has special skills and experience themselves they would not be expected to act to the same standard. Although a general duty of care must still be exercised, especially in acting in the best interest of the beneficiaries, trusts created after 2001 can omit this power. Due to their duty to diversify (see glossary) trustees must ensure that the trust has a sound level of diversification and must therefore follow the investment criteria set out in this Act. This includes the frequent review of all assets and as we have seen from the date that this charity’s portfolio was last updated (i.e. 6 months ago) this is an important area of concern.

Trustee comments and concernsThe comments made by the Trustees (see appendix 5) are concerning as it is clear they are vehemently against the current portfolio. Within these comments there are frequent points that keep arising. Firstly there is the issue of ‘unbalanced’ and the consequential level of risk this has resulted. There is a clear lack of diversification (as pointed out by the trustees) which increases the risk for the portfolio – an aspect not usually pursued by a charity. One trustee specifically notes how important security is to them and this is clearly something they would look for within their new portfolio. Within their current portfolio risk is too prominent. There is the clear lack of diversification where there has been a concentration in similar industries as opposed to spreading the risk. For example, the current portfolio has shares in Tesco, Sainsbury and Morrisons and then RBS, Barclays, HSBC and Lloyds Bank. In addition, the Trustees have also focused in on the bank shares with an evident sense of concern whereby we can assume that they do not want heavy investment in the banking sector.

These concerns made by the Trustees show that there is an issue with the asset allocation and that one way of improving this could be to change this allocation by limiting the riskier shares and investment trusts. I have therefore included for consideration, a small number of investment trusts as they generally have lower costs, improved performance and increased liquidity. The addition of further bonds will further help to mitigate risk and make this portfolio safer and more suitable for a low risk organisation such as this. A further worry made by the trustees was that the portfolio was out of date by 6 months, this is concerning due to the frequent changes in market prices particularly with a portfolio carrying this level of risk.

Market/Economic backgroundDue to the general election coming there is potential heightened risk within the UK economy both politically and economically. This uncertainty is causing concern to many investors, predominately currency and international investors. Many economists have become uncertain of the outcome and have noted to apparent fall in the value of the pound, last July we saw the pound worth over $1.70 dollars before dropping to $1.49 early April 2015. (Blitz, 2015) Blitz goes on to explain how some of this reduction should be credited to the strengthening within the US economy. Currency investing involves higher risk and unpredictability and should therefore be minimised within this portfolio as we do not want to add an investment with such high to a charity portfolio. It should be noted that some dollar exposure is okay and can aid a portfolio’s diversification. The following are considerations to be aware of prior to establishing our re-investment strategy:

Political environment. Timing of re-investment especially as the UK and US markets are at all-time highs.

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Economic uncertainty. Record low interest rates. Possible deflationary pressure. Quantitative monetary policies in Europe and Japan – though both markets due to these

measures are currently better placed for growth in the medium term.

Minutes taken from a recent Monetary Policy Committee (8th/9th April) saw continued concerns over ‘headwinds’1 that the UK economy is currently facing in addition to the effects of the 2008 financial crisis still lingering. In 2013 this deliberate policy was put in place by central banks as a way of discouraging savings and encourage consumers to borrow more. (Buttonwood, 2013) These low interest rate have the ability to ‘boost the equity market’2 as a result of lower rates being placed on bonds leading to many seeing equities as having larger benefits. This impact could be the driving power behind the equity rally seen in 2013.

Risk ManagementThe Trustees specifically noted that they were unhappy with the level of risk the portfolio currently holds which leads us to conclude that we must undertake risk management (see glossary) steps to reduce this risk. The process will be through the portfolio’s life span and will not stop once the investments have taken place (see appendix7). Regular monitoring will be required in order to keep control of any minor or major risks that may arise. One way we can identify any risks would be through the creation of a SWOT analysis (see appendix 8) as this will help determine which investments are going to produce more benefits and which have too many threats or weaknesses that could cause the portfolio to lose unnecessary value.

In order to help minimise risk our strategy should be to incorporate:

Bond and gilt pooled funds –invested with quality managers with experienced track records in these investments.

Equity Income funds that will offer consistent income, once again with managers with consistent track records of excellent performance. However, these will likely be of lower to medium risk with anticipated income returns of between 2% to 4%.

I also suggest including some lower to medium risk Investment Trusts whose strategy is to preserve wealth and produce consistent performance during turbulent markets.

Achieve a range of investments across the major asset classes though balanced for lower to medium risk spread and incorporating a low cost investment approach wherever possible as high costs can have a damaging effect upon the portfolio.

Investment Theories and core strategyBefore making any changes to the portfolio and investment strategies, different investment theories should be examined and strategies considered. Firstly, we should consider the Modern Portfolio Theory (see glossary) this theory looks at analysing an entire market over the older alternative of the analysis of ‘each investment’s individual merits’3 the latter way of analysis will include good analysis of each investment but it doesn’t consider the way in which certain investments perform comparatively with each other. Equally, MPT heavily emphasises the correlation between each investment where it compares changes in value between asset classes. (SMART401K, 2015) A key issue here is the way in which risk and volatility is treated as the same thing when in reality, they are different. This theory makes the assumption that when an investor is approached with two portfolios, both with equal return, the investor is more likely to select the one that carries the least 1 Fox Business2 The Economist3 SMART401K

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risk. (SMART401K, 2015) If the customer opts for additional risk, it is assumed that they will receive additional return. This theory shows risk coming in two forms, systematic risk and unsystematic risk (see glossary). Systematic risk cannot be mitigated by the use of diversification because a fall in the entire market will impact each investment, where unsystematic risk relates to individual investment and so diversification into other investments will help to reduce the impact caused. The efficient frontier (see appendix 9) illustrates the level of reward that would be received with any given level of risk. Portfolios below the line are not producing enough return for the level of risk that has been undertaken.

The efficient-market hypothesis (EMH) (see glossary) has three variations, weak-form, semi-strong and strong-form. It is said that investors are using a system whereby the price is the most accurate, adequate price, using the available information. (Investing, 2015) EMH suggests that ‘no stock trades too cheaply or too expensively’4, it explains that the rationale behind this pricing is that if any given stock is trading too high or too low then the demand will greatly change, quickly altering the price to its most reasonable value. (Investing, 2015) The new portfolio will have far more diversification with less focus on the banking sector and more emphasis on low risk bonds and low cost collectives. It will incorporate Socially Responsible Investing (see glossary) in order to respect the ethical values that the charity holds. In addition we would ideally want to build a core fund with initial deposits and then ‘drip feed’ the remainder over an 18 month period to protect against market lows.

Portfolio changesDue to the risky nature of this portfolio there are many changes that should be made, changes that will make this portfolio more appropriate for the charity it is intended for. Firstly, in line with comments made by trustees regarding their distaste of investing in the banking sector. The specifically make reference to ‘all those damned bank shares’5. The current portfolio includes investments in four high profile banks, RBS, Barclays, HSBC and Lloyds Banks. We would have to question, what do banks invest in? It is important that we look into what the banks are investing in, but also their reputation as a business. (see appendix 6) Recently, Barclays have had multiple episodes of bad press and negativity surrounding their company activity and the many tax havens they are involved in. In terms of ethical investing it was apparent that Barclays have significant investments in ‘both the nuclear and arms industries’6. Recently, HSBC have been under fire due to their involvement in a money laundering scheme and they saw multiple offices being ‘raided and individuals could face fines’7. Due to the unethical nature of the current investment the new portfolio will omit these investments and in doing so it will help make the portfolio more ethical. In addition both Imperial Tobacco and British American Tobacco (BAT) will be replaced by more ethically trading companies. The number investment trusts have been reduced due to their lack of transparency in addition to the Trustees dislike of this investment type. I have included a selection of Exchange Traded Funds (ETFs) (see glossary).

Remove unethical – e.g. tobacco – alongside treasury bonds that have a close maturity date. Include ETFs, Unit Trusts Aim for 60% in bonds and collectives, 40% equities Looking for an average income yield of 3% Growth on portfolio between 3%-4% making a conservative 7% per annum overall Keep portfolio charges as low as reasonably possible as these will effect net income. Diversified Medium Risk Portfolio

4 Simple Stock Investing5 Lace and Hosiery Workers Provident Charity (LHWPC) – Comment made by a Trustee.6 (EthicalConsumer, 2012)7 www.theguardian.com

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Core selection of wealth preservation funds – ideal for a charity particularly in bad economic times.

Make decisions that incorporate considering the changes for funds/investments that reflect lower costs to the portfolio.

o ETFs – Cheapest 0.2%-0.4% per year.8

o Investment Trust 0.4% -1% (Lower than Unit Trusts)o Although Unit Trusts have gone down 0.7%-1.25%

The new suggested portfolio with likely incomeThere are some large changes within the new portfolio to enable the charity to have more diversification and more protection against inflationary pressure. Certain shares have been removed, with both BAT and Imperial Tobacco due to their unethical nature and a less investment in the banking sector – as requested by the Trustees. Instead I have included a selection of collectives that include a wide variety of sectors and industries (see appendix 11). I have to ensure that they were still operating ethically and transparently throughout their operations and so I researched their values (see appendix 13). This shows the core ethics and morals that the Rathebone Ethical Bond Fund is based and it highlighted its connection to Socially Responsible Investing. This was included because it allowed for the once unethical fund to now include a fund that prides themselves on ethical investing and completes a regular ‘review of ethical criteria’9. In addition to incorporating new shares and funds into the portfolio there are also a small amount that have remained from the original. Diageo (see appendix 14) have a clear cut ethical policy and one they appear to stick to. This has meant that it has remained in the portfolio.

Although the ethical stance of companies was a crucial factor in creating a new portfolio, I also wanted to add some protection against external factors. I have therefore included Odey Opus Accumulation fund, despite being a low growth fund they act in anticipation of a downfall and operate under a smooth curve. Within the selection of gilts I have included UK index liked gilts as this helps protect the charity against inflation risk. These resulted in a final annual income of £214,055.22 on a portfolio value of £7,156,006.

ConclusionIn conclusion, I have included a diversified range of investments that will create wealth preservation for the charity whilst acting ethically. I have also focused my research on the costs of running the portfolio as costs too high would become a drag on performance. Within my collectives I have included an ETF which will help with low risk in addition to it being low cost investment. I did not however, want to create a portfolio solely made up of low risk investments and so I have suggested the addition of a Global Equity Unit Trust Fundsmith collective led by a manager with an excellent track record – Terry Smith. This is a medium risk (particularly due to the investment in Microsoft) investment with a dividend yield of 2.60%. Finally, I converted the new portfolio into the prices we would have paid on 30th September 2014 – 6 months ago (see appendix 16) to see whether the market value would have decreased or increased. It is clear that the market value of the new portfolio is £1,055,583 higher than the previous market value on 30 th September 2014.

8 The Economist9 Rathbone Ethical Bond Fund

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Appendices

Appendix 1 – Current PortfolioCURRENT INVESTMENT PORTFOLIO

THE LACE AND HOSIERY WORKERS PROVIDENT CHARITY (LHWPC)

GILTSNominal Stock Description Price Value £200,000 4.00% Treasury 2016 £107.10 £214,200 £150,000 8.75% Treasury 2017 £123.65 £185,475£250,000 5.00% Treasury 2025 £121.00 £302,500 £175,000 3.50% UK War Loan £84.50 £147,875

Sub Total for Gilts £850,050

Investment Trusts Shares Price (p) Value 60,000 Murray International Trust 1089 £653,400 50,000 Alliance Trust 454 £227,00070,000 Monks Investment Trust 380 £266,000 120,000 Fidelity China Special Situations 98 £117,600

Sub Total for Investment Trusts £1,264,000

Ordinary Shares Price (p) Value 25,000 Tesco 302 £75,500 32,000 Sainsbury 346 £110,72022,100 Morrisons 201 £44,42118,500 RBS 345 £63,825 36,400 Barclays 248 £90,272 28,000 HSBC 630 £176,40035,000 Lloyds Bank 78 £27,300 2,500 BAT 3325 £83,12510,000 Imperial Tobacco 3616 £361,60010,000 Diageo 1914 £191,40010,000 SABMiller 3324 £332,400 10,000 BAE Systems 424 £42,400 19,800 Meggitt 486 £96,228 9,750 A.B.Foods 3028 £295,230 350,000 Premier Foods 60 £210,000 Sub Total for Ordinary Shares: £2,200,821

Total Investment assets held (excluding cash): £4,314,871

PLUS £960,000 CASH HELD IN A LLOYDS MONEY MARKET ACCOUNT

Total Investment assets held (including cash): £5,274,871

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Appendix 2 Re-valued Portfolio (Trustnet, 2015) (Lansdown, 2015)

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Appendix 3 – Adapted Portfolio (Trustnet, 2015) (Lansdown, 2015)

NOTEFor ‘CF Odey Opus Class 1 – Accumulation’ and ‘Rathbone Ethical Bond Inclusive –Class R –Accumulation’ instead of an income payment the dividend equivalent is received through additional shares or additional shares.

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Appendix 4 Trustee Act 2000

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Appendix 5 Trustee commentsThe chairman of the Trustees has also mentioned that, following the appointment of five new members, there has been some heated debate about the progress of the funds under their control. He says that the following views have been expressed at a recent meeting:

"The current investment prices and values are out of date by at least six months. Also they look very unbalanced. Look at all those damned bank shares. We've lost a fortune thanks to those ruddy bankers".

"The shares look like they have been selected with a pin. And a bent pin at that. These professional advisors are useless. They will tell you to sell something and then invest the money in something else just as flaming unbalanced and useless".

"Financial advisors are just a bunch of rogues and charlatans and are only in it for the commission they make by churning investments around. The one thing that they cannot control is risk and, as a charity, security is damned important to us."

"The stock market is just a casino and is no place for a well respected charity such as ours. You might as well stick all the money on the National Lottery or at the very most keep it safe in cash".

"Our share investments seem to be concentrated in similar companies and not very well spread about. A friend of mine, who does a bit of investing in the stock market, tells me this can potentially be very dangerous, and quite risky, if anything goes wrong."

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Appendix 6 The Big Five (EthicalConsumer, 2012)

Appendix 7 Risk Management (SRA, 2014)

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Appendix 8 – SWOT Analysis

STRENGTH WEAKNESSWe will need to be made aware of the strengths of the company (ies) we are investing in. Firms that we are investing in are more than likely going to be successful companies that have a core strength and we can use them to help us analyse whether or not we see them as a feasible investment. We may also look into strengths of management, their products/services or the margins they retain. (Amongst others)

In addition to the strengths it is crucial that we are mindful of any potential weaknesses the company may possess. Most businesses may hide these behind their strengths in an attempt to increase investors. These may include, management, the financial stability of the company and any future prospects, both financially and in terms of the life span of the product.

OPPORTUNITY THREATThis is an important section as it will enable us to determine the future for potential growth and if they are able to enter new markets which would open up a wider consumer base.

Before investing it is crucial to look at the threats to the investments and any potential down falls that could occur as a result of these. This section is particularly relevant at this point if time due to the upcoming election and the changing in legislation that this could bring about. Both internal and external threats must be considered.

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Appendix 9 – Modern Portfolio Theory, Efficient Frontier and Risk (SMART401K, 2015)

Appendix 10 – The Efficient Market Hypothesis (Boundless, 2015)

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Appendix 11 – CF Odey Opus Class I – Accumulation (GBP) (FundsLibrary, Hargreaves Lansdown, 2015)

Appendix 12 – Rathbone Ethical Bond Inclusive – Class R – Accumulation (GBP) (FundsLibrary, Hargreaves Lansdown, 2015)

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Appendix 13 – Rathbone Ethical Bond (Rathbone, 2015)

Appendix 14 – Diageo – Ethics (Diageo, 2015)

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Appendix 15 – SABMiller – Ethical Practices (SABMiller, 2014)

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Appendix 16 – New Portfolio 6 Month Previously (Trustnet, 2015) (Lansdown, 2015)

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GlossaryTrustee – This is when an individual or firm administrates property or assets for a third party where they must act in their best interest. There may be multiple reasons for a trustee to be appointed, for example, a charity, pension plans or trust funds. (Amongst others)

Settlor – The settlor will set up the trust and pay into it.

Beneficiary – These are those who have an entitlement to receive the benefits of the trust.

Duty to Diversify – The trustee must insure sound diversification throughout the trust in order to mitigate risk.

Unsystematic Risk – This type of risk is specific to a company or industry. It is also known as diversifiable risk as you can prevent this risk through diversification. For example, by purchasing stocks in multiple companies and in a variation of industries this risk will be lowered.

Systematic Risk – Also known as market risk, systematic risk is the inherent to an entire market. Unlike unsystematic risk, this type of risk cannot be mitigated by using diversification.

Risk Management – This is the procedure an investor takes to try and eliminate risk identifying the areas of risk, analysing them and finding ways to control those risks in an attempt to maximise results. These potential risk will also have to be monitored to stop any potential damages caused by these risks.

Exchange Traded Funds (ETFs) – These are low cost marketable securities that can track a commodity, an index, a bond or a collection of assets. Due to the lower costs involved these can be a more attractive substitute to a higher cost investment trust.

Efficient-Market Hypothesis (EMH) – This theory assumes that markets are ‘informationally efficient’10 suggesting that an investor cannot continue to earn return in excess of market levels. There are three forms:

Weak Form Semi-Strong Form Strong Form

Socially Responsible Investing (SRI) – Investments covered under this category are those where the company acts in an ethical nature. Common themes that surround this topic include avoiding companies that are involved in gun manufacturing, alcohol and tobacco (amongst others).Modern Portfolio Theory (MPT) – The Modern Portfolio Theory explains the way in which a risk-averse investor can create a portfolio that will maximise return in line with the level of risk taken. This theory stresses the concept of higher risk leading to higher returns. In order to create a portfolio based on this theory there are four basic steps that will be taken:

Security Valuation Asset Allocation Portfolio Optimization Performance Measurement

10 Boundless 2015

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BibliographyBlitz, R. (2015, April 16). The Financial TImes. Retrieved from The Financial Times:

http://www.ft.com/cms/s/0/00558a00-e374-11e4-9a82-00144feab7de.html#axzz3YRsYSSNE

Boundless. (2015). Boundless. Retrieved from https://www.boundless.com/finance/textbooks/boundless-finance-textbook/security-market-efficiency-and-returns-9/market-efficiency-85/the-efficient-market-hypothesis-365-7276/

Buttonwood. (2013, 02 5). Economist. Retrieved from The Economist: http://www.economist.com/blogs/buttonwood/2013/02/investing

EthicalConsumer. (2012). Retrieved from Ethical Consumer: http://www.ethicalconsumer.org/ethicalreports/bankingindustrysectorreport/bankprofiles.aspx

FundsLibrary. (2015, 02 28). Hargreaves Lansdown. Retrieved from http://www.hl.co.uk/funds/fund-discounts,-prices--and--factsheets/search-results/r/rathbone-ethical-bond-accumulation-inclusive/fund-analysis

FundsLibrary. (2015, 02 28). Hargreaves Lansdown. Retrieved from http://www.hl.co.uk/funds/fund-discounts,-prices--and--factsheets/search-results/c/cf-odey-opus-class-i-accumulation/fund-analysis

Investing, S. (2015). Simple Stock Investing. Retrieved from http://www.simplestockinvesting.com/efficient-market-hypothesis.htm

Rathbone. (2015). Rathbone Unit Trust Management. Retrieved from https://www.rutm.com/pa/fund-rathbone-ethical-bond-fund.aspx

SMART401K. (2015). SMART 401K. Retrieved from http://www.smart401k.com/Content/retail/resource-center/advanced-investing/modern-portfolio-theory-and-the-efficient-frontier

SRA. (2014, 03 21). Solicitors Regulation Authority. Retrieved from http://www.sra.org.uk/riskframework/

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