UK Stewardship Code

Under Rule 2.2A.5 of the FCA’s Conduct of Business Sourcebook, ShadowFall 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 sets out a number of principles relating to engagement by asset managers or asset owners across all asset classes including listed equities and investments outside the UK.

Whilst ShadowFall generally supports the objectives that underlie the Code, the nature of its investment strategy does not allow it to formally engage with investee companies through voting rights. The Firm has therefore chosen not to commit to the Code at this time. The Firm will review this position annually and update this disclosure accordingly if the provisions of the Code become relevant.