UK STEWARDSHIP CODE
As per the FCA Handbook and Rule COBS 2.2.3 R, Stone Mountain Capital LTD makes a public disclosure in relation to the nature of our commitment to the UK Stewardship Code ('Code'), which was published by the Financial Reporting Council (‘FRC’) in July 2010. The FRC is the UK’s independent regulator responsible for promoting high quality corporate governance and reporting to encourage investment in UK listed companies.
The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies (including through the asset managers) and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.
The seven principles of the Code that institutional investors should follow are:
1, Publicly disclose their policy on how they will discharge their stewardship responsibilities
2, Have a publicly disclosed, robust policy on managing conflicts of interest in relation to stewardship
3, Monitor their investee companies
4, Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value
5, Be willing to act collectively with other investors where appropriate
6, Have a clear policy on voting and disclosure of voting activity and
7, Report periodically on their stewardship and voting activities.
Stone Mountain Capital LTD pursues an alternative investment strategy involving investments in private and unlisted European companies and private collective investment schemes. While Stone Mountain Capital LTD supports the objectives that are underlying to the Code, it is therefore not relevant to the business model of Stone Mountain Capital LTD. However, in practice Stone Mountain Capital LTD will be broadly following the courses of action arising from the principles (when relevant), as set out in the Code. Stone Mountain Capital LTD determines its approach to stewardship on a case by case basis, the nature of the private and unlisted company or collective investment scheme invested and the actions that will lead to the most favourable outcome for the value of our investments.
Furthermore, the Stone Mountain Capital LTD takes a consistent approach to engagement with invested companies and collective investment schemes, in all of the relevant jurisdictions. Stone Mountain Capital LTD has therefore determined that it does not consider it appropriate to commit to any particular code relating to any individual jurisdiction. Should any material changes occur to the alternative investment strategies which would make the Code relevant to Stone Mountain Capital LTD, we will review our commitment to the Code at that time and make appropriate disclosures.
As per the FCA Handbook and Rule COBS 2.2.3 R, Stone Mountain Capital LTD makes a public disclosure in relation to the nature of our commitment to the UK Stewardship Code ('Code'), which was published by the Financial Reporting Council (‘FRC’) in July 2010. The FRC is the UK’s independent regulator responsible for promoting high quality corporate governance and reporting to encourage investment in UK listed companies.
The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies (including through the asset managers) and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.
The seven principles of the Code that institutional investors should follow are:
1, Publicly disclose their policy on how they will discharge their stewardship responsibilities
2, Have a publicly disclosed, robust policy on managing conflicts of interest in relation to stewardship
3, Monitor their investee companies
4, Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value
5, Be willing to act collectively with other investors where appropriate
6, Have a clear policy on voting and disclosure of voting activity and
7, Report periodically on their stewardship and voting activities.
Stone Mountain Capital LTD pursues an alternative investment strategy involving investments in private and unlisted European companies and private collective investment schemes. While Stone Mountain Capital LTD supports the objectives that are underlying to the Code, it is therefore not relevant to the business model of Stone Mountain Capital LTD. However, in practice Stone Mountain Capital LTD will be broadly following the courses of action arising from the principles (when relevant), as set out in the Code. Stone Mountain Capital LTD determines its approach to stewardship on a case by case basis, the nature of the private and unlisted company or collective investment scheme invested and the actions that will lead to the most favourable outcome for the value of our investments.
Furthermore, the Stone Mountain Capital LTD takes a consistent approach to engagement with invested companies and collective investment schemes, in all of the relevant jurisdictions. Stone Mountain Capital LTD has therefore determined that it does not consider it appropriate to commit to any particular code relating to any individual jurisdiction. Should any material changes occur to the alternative investment strategies which would make the Code relevant to Stone Mountain Capital LTD, we will review our commitment to the Code at that time and make appropriate disclosures.
