UK STEWARDSHIP CODE DISCLOSURE STATEMENT
Under COBS 2.2 of the FCA Handbook, Gullwing Capital Advisers Limited (“the Firm”) are required to make a public disclosure in relation to the nature of our commitment to the above Code, which was published by the Financial Reporting Council (‘FRC’) in July 2010.
The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term 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 “comply or explain” basis. 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.
The Firm advises and manages funds which invest in various types of securities. The Firm’s strategy, however, does not involve any investment in UK listed companies, and the Firm does not anticipate making any such investments in the future.
For this reason, whilst the Firm supports the Code’s objectives, it has decided not to commit to the principles of the Code.
Should the Firm’s investment strategy change, there will be a review of its commitment to the code at that time and appropriate disclosures will be made.