Under Rule 2.2.B.5R of the FCA’s Conduct of Business Sourcebook, Astra Asset Management UK Limited (“the Firm”) is required to develop and disclose a shareholder engagement policy, or explain why it has chosen not to do so.

The Shareholders Rights Directive II (“SRD II”) aims to improve stewardship and corporate governance by firms that invest in shares traded on a regulated market in the EEA.

The engagement policy requires firms to describe how it:

  1. integrates shareholder engagement in its investment strategy:
  2. monitors investee companies on relevant matters, including:
    1. strategy;
    2. financial and non-financial performance and risk;
    3. capital structure; and
    4. social and environmental impact and corporate governance;
  3. conducts dialogues with investee companies;
  4. exercises voting rights and other rights attached to shares;
  5. cooperates with other shareholders;
  6. communicates with relevant stakeholders of the investee companies; and
  7. manages actual and potential conflicts of interests in relation to the firm’s engagement.

While the Firm generally supports the objectives that underlie SRD II, the Firm has chosen not to produce an engagement policy at this time. The Firm provides investment and advisory services to a number of segregated client portfolios that invest in shares traded on a regulated market in the EEA. Investing in European listed equities constitutes represents only a very small proportion of the firm’s overall investment strategy and therefore the Firm does not typically engage with investee companies.

Should the Firm’s approach change, we will update this statement.

Please contact our Chief Compliance Officer (This email address is being protected from spambots. You need JavaScript enabled to view it.) if you have any questions.