1. Introduction

This statement outlines the Firm’s position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in 2012 and 2020. Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, the Firm is required to make a public disclosure about the nature of its commitment and level of compliance to the Code or, where it does not commit to the Code, to explain its alternative investment strategy.

The Code is a voluntary code, which aims to enhance the quality of engagement between asset owners/asset managers and listed companies in the UK, to help improve long-term risk-adjusted returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “apply and explain” basis. It also describes steps that asset owners can take to protect and enhance the value that accrues to the ultimate beneficiary.

The FRC recognises that capital is invested in a range of asset classes over which investors have different terms and investment periods, rights and levels of influence. Hence the Code does not solely apply to equity investments.

The FRC also recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy.

The Code comprises twelve Principles that can be summarised as follows:

Purpose and governance	Purpose, strategy and governance Governance, resources and incentives Conflicts of interest Promoting well-functioning markets Review and assurance
Investment approach	Client and beneficiary needs Stewardship, investment and ESG integration Monitoring managers and service providers
Engagement	Engagement Collaboration Escalation
Rights and responsibilities	Exercising rights and responsibility

2. The firm’s position on the code

Whilst the revised Code covers a broader range of assets, the Firm does not consider it appropriate to commit to any particular voluntary code of practice and feels that the Code is not proportionate to the Firm’s business model. However, in practice, the Firm would take into consideration the principles as set out in the Code.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time.

For further details on any of the above information please contact the Firm’s Compliance Officer.