COMMITMENT TO THE UK STEWARDSHIP CODE
Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Rondine Capital LLP (“Rondine” or “the Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include 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.
Whilst Rondine generally supports the objectives of the Code, Rondine invests in diverse jurisdictions. The nature of these jurisdictions, the Firm’s investment strategy and the means employed in the execution of the strategy do not always embrace the type of engagement with investee companies required by the Code, and the Firm does not consider that its clients expect such engagement. On that basis, the Firm has chosen not to commit to the Code at this time.