Stewardship Code Disclosure
UK Stewardship Code Disclosure Statement
Under COBS 2.2.3 of the FCA Handbook, all FCA authorised firms are required to make a public disclosure in relation to the nature of their commitment to the above Code ("the Code"), a revised version of which was published by the Financial Reporting Council ("FRC"), and which came into effect in January 2020.
The Code defines stewardship as the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society. Firms may either comply with the Code or choose not to comply with certain aspects of the Code, in which case an explanation of non-compliance is required. If a firm does not commit to the Code, it must state, in general terms, its alternative investment strategy.
Although the Firm supports the Code's objectives, the Firm has taken the decision not to commit to the specific principles of the Code.
Investment approach and engagement
The Firm invests in various asset classes and jurisdictions globally. The current policy of the Firm in engaging with issuers and their management is determined by the Chief Investment Officer and the investment team. The Firm takes a consistent approach to engaging with the issuers and their management in all the jurisdictions in which the Firm invests.
As part of our investment process the Firm assesses a range of ESG factors, particularly climate change risk. The Firm believes that climate change-related risks, in particular a company’s greenhouse gas (GHG) emissions, will have a material effect on a company’s long-term profitability, sustainability and investor returns. These risks include regulation, taxation, competitive disadvantage, brand impairment, financing, physical asset impairment and litigation.
We actively engage on ESG to help us understand, quantify and influence a company’s exposure to climate change-related risks and the way in which it is managing those risks.
We require companies in which we invest to make appropriate and timely public disclosure of carbon and other GHG emissions. Such disclosure should include targets for emissions intensity reduction and absolute level reduction.
The Firm will commonly publish on its website the correspondence with these companies.
The Firm communicates closely with its funds and the fund investors as to the discussions with and our requirements of those companies through newsletters and other investor communications, in addition to the correspondence placed on the Firm’s website.