Meeting our obligations under the Revised Shareholder Rights Directive II (SRD II)

As a UK MiFID investment firm which provides portfolio management services to investors, we are required by this Directive to explain whether or not we have an engagement policy in relation to the companies we invest in, where those companies’ shares are admitted to trading on a regulated market.

We pursue an investment strategy to which the aims of SRD II are not directly relevant given that over 95% of the portfolios managed by us are in collective investment schemes with a very limited number of direct equity holdings. Consequently, whilst we support the general objectives that underlie SRD II, the provisions of the Directive are not relevant to the type of trading currently undertaken by us.

In addition, the proportion of shares we hold in investee companies is much lower than those held by large institutional investors and we are therefore not able to engage with investee companies to the extent envisaged by SRD II. We do not therefore have a formal engagement policy.

If our investment strategy changes in such a manner that the provisions of the Directive become relevant, we will amend this disclosure accordingly.