3 Tilney Street
London W1K 1BQ

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info@astaris.com

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Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Astaris Capital Management LLP (the “Firm”) is required to include on this website 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, 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.

The Firm pursues an event driven strategy that involves it investing in European equities, including UK equities. The Firm’s strategy is active and involves a wide variety of investment products and timeframes. Therefore, while the Company supports the principles of the Code, it does not consider it appropriate to conform to the Code at this time. The Firm invests in a variety of asset classes and in a variety of jurisdictions across Europe.

Shareholder Rights Directive (SRD II)

SRD II aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on EEA regulated markets and comparable regulated markets outside the EEA. It came into effect on 10 June 2019.

The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:

  • Publish their shareholder engagement policy (or explain why they don’t have one) – COBS 2.2B.5R.
  • Make annual public disclosures relating to the implementation of their shareholder engagement policy, from 10 June 2020 – COBS 2.2B.5R.
  • Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R.

Astaris Capital Management LLP is currently considering whether it will adopt an engagement policy pursuant to Article 3g of the amended EU Shareholder Rights Directive (Directive 2007/36/EC). When that decision has been made, this webpage will be updated accordingly.