The firm has a responsibility as a Discretionary Fund Manager to account for how it meets its obligations under the Revised Shareholder Rights Directive II (SRD II).
We are required by this Directive to explain whether or not we have an engagement policy in relation to the companies in which we invest to the extent that these companies’ shares are admitted to trading on a regulated market.
We do not have a formal engagement policy as we believe that the proportion of shares that we hold in companies is much lower than, and might be considered immaterial when compared to, those held by large institutional investors.
While we do not have a formal approach, which would entail, for example, an element of communication with other stakeholders and a dialogue with the companies, we do pay heed to issues of shareholder interest. We do cast votes or actively abstain in general meetings of companies, which we need to do in association with the custodians that we use, and we are happy to address in those meetings we do hold with companies any issues that have arisen. We would also see issues on governance and the like as precluding us from investing.