Under FCA Rule COBS 2.2.3, Stenham Asset Management (UK) Plc (the “Firm”) is required to make a public disclosure in relation to the nature of its commitment to the Financial Reporting Council’s ("FRC") Stewardship Code on Corporate Governance (the “Code”). If it does not commit to the Code, either in full, or in part, it is incumbent on the Firm to state in general terms its alternative investment strategy.

The Code, which is voluntary, aims to promote dialogue between UK institutional investors and their investee companies with the aim of increasing transparency and thereby returns to shareholders.

The FRC 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, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

·         Publicly disclose their policy on how they will discharge their stewardship responsibilities;

·         Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;

·         Monitor their investee companies;

·         Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder                value;

·         Be willing to act collectively with other investors where appropriate;

·         Have a clear policy on voting and disclosure of voting activity; and

·         Report periodically on their stewardship and voting activities.

Whilst adhering to the highest standards of corporate governance and due diligence in respect of its investments, the Firm, having considered the Code, considers that its principles are not generally applicable to its investment activities. The Firm provides discretionary investment management services to a small number of Professional clients, all of which invest in predominantly unitised funds of hedge funds and hedge funds. That notwithstanding, the Firm also invests a small amount of its clients' assets in large cap, exchange traded stocks. That those companies the Firm invests in on behalf of its clients are companies with considerable amounts of issued share capital means that the Firm does not consider appropriate or necessary to engage with them directly on voting issues. 

Should any of the above change, the Firm will review its commitment to the Code.

Please contact the Compliance Officer at
compliance@stenham.com should you have any further queries.