COMMITMENT TO THE UK STEWARDSHIP CODE
Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Autonomy Capital Research LLP (“ACR” or “the Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include 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, explain its considered choice based on the Firm’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.
ACR invests in a variety of asset classes in a variety of jurisdictions globally and exposure to UK- listed companies is relatively limited. Therefore, whilst ACR generally supports the objectives that underlie the Code, the nature of its investment strategy do not allow it to formally engage with investee companies through voting rights. The Firm has therefore chosen not to commit to the Code at this time.
SHAREHOLDER RIGHTS DIRECTIVE
The Firm is considering its position with respect to obligations under the Shareholder Rights Directive and will in due course publish in full an appropriate disclosure regarding its policy, related processes, and engagement with investee companies (as per FCA rules at COBS 2.2B.5R).