Stewardship Code disclosure statement


Under Rule 2.2.3 of the FCA's Conduct of Business Sourcebook, we are required to include a statement on our website to share our commitment to the UK Financial Reporting Council's Stewardship Code (the "Code"), or, where we do not commit to the Code, our alternative investment strategy.

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. The Code sets out good practice on engagement with investee companies through a set of 'apply and explain' principles. The Financial Reporting Council recognises that not all principles of the Code will be equally relevant to all institutional investors and that smaller institutions may judge certain principles and guidance to be disproportionate.

We take our responsibilities as an asset manager towards investors and investees seriously and have developed a stewardship and engagement approach as part of our investment process. We are an active asset manager that engages with fund managers and other financial organisations in a targeted way during the due diligence and portfolio management stages of the investment process. This seeks to ensure that the organisation’s investment approach, process and operations minimise negative and maximise positive impacts for people, communities and the planet. A key part of our portfolio management approach is to support fund manager development including structured support programmes and training; proactively identifying and acting to strengthen key areas for improvement; and ensuring there is capacity and expertise within our organisation to engage and respond to key issues for fund managers as they arise. While we support the principles and objectives of the Code, we do not currently comply with the detailed requirements of the Code for the following reasons:

  • We are a social investment wholesaler in the social impact investment sector in the UK with the aim of delivering measurable positive social impact as well as long term capital growth and income principally through investing in private market impact funds. As such, we do not generally invest in UK listed companies.
  • We aim to invest through fund managers into underlying investees, and so do not interact with the management of the underlying investees.

Find out more about our investment approach

Should there be a material change to our investment strategy that would render the principles of the Code applicable, we will review our commitment to the Code at the time and will amend this disclosure statement accordingly.

For further details on the above please contact Philipp Essl