Article 3(g) of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as Kirkoswald Capital Partners LLP (‘Kirkoswald’ or ‘Firm’) to either:
- Develop and disclose an engagement policy describing how the Firm integrates shareholder engagement in its investment strategy; or
- Disclose why the firm has chosen not to comply with those requirements.
Such an engagement policy requires a firm to describe how it:
- Integrates shareholder engagement in its investment strategy;
- Monitors investee companies on relevant matters, including: strategy; financial and non-financial performance and risk; capital structure; and social and environmental impact and corporate governance;
- Conducts dialogues with investee companies;
- Exercises voting rights and other rights attached to shares;
- Cooperates with other shareholders;
- Communicates with relevant stakeholders of the investee companies; and
- Manages actual and potential conflicts of interests in relation to the firm’s engagement.
The above engagement policy is limited to the extent that a firm invests on behalf of investors in shares traded on a regulated market, or on third country markets that meet comparable requirements and where the shares dealt in are of a quality comparable to those in a regulated market in the UK.
Kirkoswald’s Approach to Engagement
The investment strategies of the Firm’s collective investment schemes, pooled vehicles and/or separately managed accounts (each an “Investment Vehicle” and, collectively, the “Investment Vehicles”) are such that whilst the Firm may invest in shares traded on a regulated market (or comparable market), the resultant holdings are sufficiently immaterial in terms of size and voting power for the Firm to actively engage with investee companies. In addition, where an Investment Vehicle trades equities as part of its strategy, it does so mainly via swaps, which does not confer voting rights.
While Kirkoswald generally supports the objectives that underlie SRD II, for the above reasons the Firm has chosen not to produce an engagement policy at this time. Should this change in the future, Kirkoswald will update this statement accordingly.
For any questions regarding this statement email firstname.lastname@example.org.