Stewardship Code Disclosure
The UK Stewardship Code 2020 (The Code) came into effect on 1 January 2020. The Code sets expectations to those investing money on behalf of UK savers and pensioners.
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”.
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Rampart Capital LLP (the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code sets out a number of principles relating to engagement by investors with UK equity issuers, as follows:
The seven principles of the Code are that institutional investors should:
- Publicly disclose their policy on how they will discharge their stewardship responsibilities;
- Have a robust policy for managing conflicts of interest in relation to stewardship and publicly disclose this conflict of interest policy;
- Monitor their investee firms;
- Establish clear guidelines on how and when they will escalate their investment activities in order to enhance shareholder value;
- Act collectively with other investors if appropriate;
- Establish a clear policy on voting and disclosure of voting policy; and
- Report periodically on stewardship and voting activities.
Rampart Capital LLP does not manage any funds which hold equity holdings in UK listed companies, nor does it manage the portfolios of investors who engage with UK equity issuers and as such it will not be applicable.
Shareholders Rights Directive II (‘SRD II’) Disclosure
SRD II establishes requirements in relation to the exercise of certain shareholder rights attached to voting shares in general meetings of companies which have their registered office in an EU Member State and the shares are traded on a regulated market situated or operating within a Member State. The requirements apply to intermediaries, proxy advisers, institutional investors, asset managers and issuers.
Institutional investors and asset managers must comply with the requirements of SRD II or publicly disclose a clear and reasoned explanation as to why they have chosen not to comply with one or more of the requirements.
Rampart Capital LLP has considered whether it will need to develop and publicly disclose an engagement policy and concluded it does not require an engagement policy at present because it does not manage any EU listed securities on behalf of its clients, nor does it manage the funds of any institutional investors to date.