Stewardship policy
This policy sets out Aequitas Wealth Management Ltd (Aequitas) commitment to the principles of the Financial Reporting Council ("FRC")'s UK Stewardship Code (the "Code") and also constitutes the disclosure of that commitment required under the rules of the Financial Conduct Authority (Conduct of Business Rule 2.2 3).
Aequitas will review this stewardship policy annually.
Aequitas operates a number of UK authorised open-ended investment funds.
Aequitas recognises its stewardship responsibilities. In its capacity as asset manager, Aequitas recognises its primary responsibility for stewardship and its policy and practice in application of each Principle of the Code is set out below.
The Code is focused on UK investments, however to the extent practical. Aequitas also adopts a similar philosophy to investments managed in other markets.
The FRC recognises that the principles and guidance which constitute the Code are not a rigid set of rules and that not all parts of the Code are relevant to all signatories. In particular, the FRC recognises that some smaller institutions (relative to some other fund managers Aequitas falls into this category) may judge that some of its principles and guidance are disproportionate in their case. Where Aequitas takes this view, it is explained below.
The Code states that "so as to protect and enhance the value that accrues to the ultimate beneficiary, institutional investors should:"
1. Publicly disclose their policy on how they will discharge their stewardship responsibilities. Stewardship encompasses more than the exercise of votes in investee companies at general meetings. It also includes the selection of investments as well as the on-going engagement monitoring and communication with investee companies:
Aequitas does not invest directly in companies as our investment strategies use collective investment vehicles. Therefore, many aspects of the Stewardship Code do not apply.
2. Have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed:
Aequitas has a Conflicts of Interest Policy which sets out our policy for identifying and managing conflicts of interest and handling matters where the interests of individual clients differ. This policy is overseen by the Aequitas board which is composed of investment oversight, compliance and operations senior management.
3. Monitor their investee companies:
Aequitas does not invest directly into equities and therefore this element of the code is not applicable.
4. Establish clear guidelines on when and how they will escalate their stewardship activities:
Aequitas does not invest directly into equities and therefore this element of the code is not applicable.
5. Be willing to act collectively with other investors where appropriate:
Aequitas does not invest directly into equities and therefore this element of the code is not applicable.
6. Have a clear policy on voting and disclosure of voting activity:
Aequitas does not invest directly into equities and therefore this element of the code is not applicable.
7. Report periodically on their stewardship and voting activities:
Aequitas does not invest directly into equities and therefore this element of the code is not applicable.
Issued by Aequitas Wealth Management Ltd, authorised and regulated by the Financial Conduct Authority of 25 The North Colonnade, Canary Wharf, London E14 5HS.