Collidr Asset Management Limited (the “Firm”)
STATEMENT IN RELATION TO THE SHAREHOLDER RIGHTS DIRECTIVE II

1. INTRODUCTION

The Second Shareholder Rights Directive (“SRD”), which took effect in the UK on 10 June 2019, aims to improve shareholder engagement and increase transparency around stewardship. The Firm invests in listed equities and as such we are required to disclose and make publicly available our policies on how we engage with other shareholders and the companies that we invest in, and how our strategies create long-term value.

2. SRD AND THE FRC STEWARDSHIP CODE

The UK Stewardship Code (the “Code”) was established by the Financial Reporting Council in 2010. UK authorised asset managers have been required under the rules of the Financial Conduct Authority to produce a statement of commitment to the Code or to explain why it is not appropriate to its business model.

Unlike SRD, which applies to investments in listed equities globally, the Code focuses on investments in UK companies only.

The Firm’s response to the Code detailed in a separate statement, available here: Statement on the UK Stewardship Code.

3. THE FIRM’S APPROACH

We are required to either:

• publicly disclose an Engagement Policy and a public statement on an annual basis on how the Engagement Policy has been implemented; or
• publicly disclose a clear and reasoned explanation of why the Firm has chosen not to make these disclosures

The Firm has elected to not publicly disclose its Engagement Policy. This is because direct investments in liquid equities constitutes a small proportion (less than 2%) of the Firm’s assets under management and where there are direct investments in liquid equities these are made using quantitative methodologies and any equity may only be held to the next rebalance point.

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 SRD and make appropriate disclosure at that time.