FundRock Partners Limited

Stewardship Code

The FCA requires firms managing investments for professional clients to disclose the nature of its commitment to the Financial Reporting Council’s UK Stewardship Code 2020 (the Code). FundRock Partners Limited (FP) fully supports the principles embodied in the Code.

The Code comprises a set of ‘apply and explain’ Principles for asset managers. The Code does not prescribe a single approach to effective stewardship. Instead, it allows organisations to meet the expectations in a manner that is aligned with their own business model and strategy.

When applying the Principles, signatories to the Code should consider the following, among other issues:

• The effective application of the UK Corporate Governance Code and other governance codes.
• Directors’ duties, particularly those matters to which they should have regard under section 172 of the Companies Act 2006.
• Capital structure, risk, strategy and performance.
• Diversity, remuneration and workforce interests.
• Audit quality.
• Environmental and social issues, including climate change.
• Compliance with covenants and contracts.

The Code consists of 12 principles for asset managers.

Principle 1 : Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.

Principle 2 : Signatories’ governance, resources and incentives support stewardship.

Principle 3 : Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first.

Principle 4 : Signatories identify and respond to market-wide and systemic risks to promote a well-functioning financial system.

Principle 5 : Signatories review their policies, assure their processes and assess the effectiveness of their activities.

Principle 6 : Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.

Principle 7 : Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.

Principle 8 : Signatories monitor and hold to account managers and/or service providers.

Principle 9 : Signatories engage with issuers to maintain or enhance the value of assets.

Principle 10 : Signatories, where necessary, participate in collaborative engagement to influence issuers.

Principle 11 : Signatories, where necessary, escalate stewardship activities to influence issuers.

Principle 12 :Signatories actively exercise their rights and responsibilities.

All Principles are supported by reporting expectations. Firms wanting to become signatories to the code will be required to produce an annual stewardship report explaining how they have implemented the code in the preceding 12 months. The Financial Reporting Council would evaluate these stewardship reports and those that meet the reporting expectation would be listed as signatories to the Code.

FP is an Authorised Fund Manager and outsources the investment management function of its Funds to third party investment managers whilst retaining overall responsibility for ensuring that the schemes are managed in accordance with the Funds’ scheme documentation and any and all applicable regulation. FP expects all its delegated Investment Managers and, if applicable, their sub delegated investment managers to state the nature of their commitment to the Code or where it does not, provide details of their alternative approach.