Compliance & Legal
UK Stewardship Code
The Firm supports the principles enshrined in the Financial Reporting Council's Stewardship Code which sets out good practice for investor engagement. The FCA requires all authorised asset managers to publicly disclose either a statement of compliance with the Stewardship Code or where they do not commit, their alternative investment strategy.
The Financial Conduct Authority and the Financial Reporting Council have acknowledged that certain aspects of the Stewardship Code are not directly relevant to all managers. The Firm is a fund manager which act as an Alternative Investment Fund Manager (AIFM) for Alternative Investment Funds (AIF) and also act as a Collective Portfolio Management Investment Firm (CPMI).
It should be noted that given the Firm’s specialist focus is not UK focused/dominant, the number of occasions on which the Firm will be involved in UK equity or fixed income investments, will be limited. Therefore, the Firm has chosen not to formally commit to the Code as it has limited applicability to the Firm’s investment activities .
The Firm’s Executive Management will continue to review the Code's applicability.
Shareholder Rights Directive
The Firm does not invest exclusively in listed equities as a core strategy, though does invest in listed equities on behalf of client portfolios as part of its overall investment strategy. The Firm does not have ‘engagement’ with the relevant companies as such. In addition, the Firm may invest from time to time in listed equities in various overseas jurisdictions which have equivalent standards of shareholder behaviour to SRD. Therefore, adherence to the SRD’s disclosure requirements is considered to be duplicative.
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