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Regulatory Disclosures

STEWARDSHIP CODE DISCLOSURE

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook (“COBS”), FM Capital Partners Ltd (“FMCP” or the "Firm"), to the extent that it is managing investments for a professional client (as defined by the FCA), is required to include on its website 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 aimed at enhancing the quality of engagement by asset managers and owners with corporate issuers and sets out 12 principles relating to how investment and stewardship is integrated, including environmental, social and governance issues.
FMCP provides investment management services to funds which pursue a variety of strategies involving equities and fixed income assets on a global basis with a variety of timeframes. Although, the Code is therefore applicable to some aspects of these strategies, this generally represents a small proportion of the invested asset base which is typically across a variety of jurisdictions globally.
Whilst the Firm is supportive of the Code's objectives and principles, the specific provisions of the Code are not aligned with the type of trading currently undertaken by the Firm. The Firm has therefore chosen not to commit to the Code at this time. If the Firm’s investment strategy changes, in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.
The Firm further provides regular and routine reporting to its clients, such that they remain apprised of the stewardship of their investments.


SHAREHOLDER RIGHTS DIRECTIVE II


Under COBS 2.2B.5R, FM Capital Partners Ltd (“FMCP” or the “Firm”) is required to either develop and publicly disclose an engagement policy that meets the requirements of the Shareholder Rights Directive (“SRD II”) or to publicly disclose a clear and reasoned explanation of why it has chosen not to develop an engagement policy that meets the SRD II requirements.
FMCP has chosen not to develop an engagement policy that complies with the requirements of the SRD II, as the Firm considers that it has an investment strategy that is not commensurate with the outcomes sought thereunder. Moreover, the Firm ensures that its clients are regularly and routinely apprised of the investment strategies employed by the Firm. As such, it is felt that clients would not expect the Firm to achieve compliance with the core requirements of the SRD II.
FMCP’s investment strategy involves both long and short-term investment and is driven by fundamental research and portfolio construction. Additionally, whilst the Firm may occasionally interact with the management of companies in which it invests on behalf of its clients, it does not employ an “activist” investment strategy.


SECTION 172 STATEMENT


The company’s customer is also the company’s majority shareholder, this ensures that the relationship between maximising the Company’s gain and the interests of both are maintained.

The Company maintains the balance of company gains with the interests of its suppliers with the assurance of continuity of supply through staff remuneration reflecting the expertise of each individual and the current market value of their skills along with a safe and healthy working environment. The balance of these aims with suppliers is maintained through constant review of our suppliers to ensure an effective service at a comparable market cost.

For further information, please contact the Compliance Department at FM Capital Partners Ltd.