Stewardship Code disclosure

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Feoh Investments UK LLP (the “Firm”) is required to make a public 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, its alternative investment strategy.

The Code is a voluntary code and sets out a number 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 noncompliance and state in general terms their alternative investment strategy.

The seven principles of the Code are that institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
  • Monitor their investee companies;
  • Establish clear guidelines on when and how they will escalate their activities;
  • Be willing to act collectively with other investors where appropriate;
  • Have a clear policy on voting and disclosure of voting activity; and
  • Report periodically on their stewardship and voting activities.

The Firm provides investment management services to Feoh Investments (the “Fund”), a Cayman based Alternative Investment Fund. The Firm directs the Fund to take concentrated positions in securities which the Firm, based on fundamental analysis, believes to be mispriced. The Fund has the flexibility to invest in a wide range of instruments, including equities as well as other listed and unlisted securities.

The Firm determines its approach to stewardship on a case-by-case basis, taking into account the actions which it anticipates will lead to the most favourable investment outcome. Moreover, the Firm engages with issuers and their respective management teams in a variety of jurisdictions, and the Firm’s direct investment in UK single equities represents only a part of its total operations. For these reasons, while the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code.