North Rock Capital Management (UK) LLP

UK Financial Reporting Council’s Stewardship Code - Statement

 

Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook (“COBS”) requires North Rock Capital Management (UK) LLP (“the Firm”) to disclose on its website or in another accessible form:

• 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 was re-published in October 2019 and sets out a number of principles relating to investor engagement with the companies and other assets in which they are invested. Compliance with the Code is voluntary in nature on a “comply or explain” basis.

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The Firm is supportive of the policy objectives of the Code, however has not decided to commit to the Code.

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The Firm pursues a multi-strategy approach across multiple independent investment teams across multiple jurisdictions and timeframes, focusing on relative value strategies. The Firm does not take an activist approach to investing. In particular, the Firm does not typically pursue buy-and-hold strategies of UK equities and undertakes all UK equity investment through swap and CFD which offer a restricted ability to undertake shareholder engagement. The Firm is also a Sub-Advisor to a US investment manager, and any proxy engagement is subject to a group-wide approach.

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The Firm periodically reviews its position regarding the Code and, if the Firm’s strategies change such that the Code becomes more relevant, the Firm will amend its approach accordingly.