Introduction

The Firm is a Full-Scope Alternative Investment Fund Manager.

SRD II

Article 3g of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as the 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
  • 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).

The Firm’s approach to engagement

The Firm’s investment strategy is such that:

• Whilst the firm may invest in shares traded on a regulated market (or comparable market), they are for investment purposes and typically the firm does not actively engage with investee companies.
• The investment strategy pursued by the funds, to which the Firm provides investment services to, typically trade equity positions but only via derivatives / swaps, which do not come with any voting rights attached. 

While the Firm 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.

For further information on the Firm’s approach please contact the Firm’s Compliance Officer, Andrew Wall at andrew@greenvalecapital.com