Commitment to the UK Stewardship Code and Shareholder Rights Directive
Under Rule 2.2.3R of the FCA's Conduct of Business sourcebook, Russell Clark Investment Management Limited (the "Firm", “RCIM”) is required to publicly disclose 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, its alternative investment strategy. The Code is a voluntary set of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance.
Additionally, in accordance with Rule 3.4.3R of the FCA’s Senior Management Arrangements, Systems and Controls sourcebook, the Firm is required to publicly disclose its compliance with the Shareholder Rights Directive (the “Directive”), or where it does not comply with the Directive, why it has chosen not to comply. The Directive seeks to strengthen the position of shareholders through the establishment of requirements relating to the exercise of shareholder rights attached to voting shares and to ensure that voting decisions are made for the long-term stability of a company.
The Firm pursues long/short equity strategies that involve investment in global equities. Investment strategies and trading decisions are based on macro events, investment themes, publically available information about the company, and market conditions. The Firm does not pursue an activist strategy; it predominantly employs a short strategy and where it does take long positions, these investments are typically less than 1% of the listed company’s shares. RCIM does not actively engage in dialogue with the companies it invests in or their stakeholders, it does not try to actively influence management decisions through voting strategies nor does it coordinate with other shareholders. Therefore whilst RCIM generally supports the objectives that underlie the Code and the Directive, it has determined that compliance with both the Code and the Directive are not relevant because of the investment strategies it employs on behalf of its clients.