Stewardship Code

Thornbridge Investment Management LLP (“Thornbridge”) fully supports the UK Stewardship Code (“The Code”) which was first published in July 2010, revised in September 2012 and sets out good practice for institutional investors (and investment managers) when engaging with the UK listed companies in which they invest, and is intended to enhance this relationship.

In line with the FCA’s requirements Thornbridge’s Stewardship Code Statement discloses how they apply the Code’s Principles set out below. This Statement will always be available on request by contacting our offices.

Principle 1

Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities

Thornbridge is a boutique investment manager and as such the holdings that it has in UK companies are small as a proportion of the issued share capital.  Thornbridge will only vote securities where it believes such voting to be in the best interest of its clients.

Principle 2

Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed

Thornbridge is an independent boutique investment business and so there is a low risk of conflict of interest. In the event that a potential conflict of interest is identified the governing body of the firm will meet and determine the appropriate course of action in accordance with its conflicts of interest policy.

Principle 3

Institutional investors should monitor their investee companies

Thornbridge undertakes research and constantly monitors the companies that form part of the client portfolios.

Principle 4

Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value

As a boutique manager the influence that Thornbridge is able to bring to bear on investee companies is limited. In the event that Thornbridge loses confidence in the management of an investee company the investment will be divested.

Principle 5

Institutional investors should be willing to act collectively with other investors where appropriate

Thornbridge is willing to work collectively with other investors and will determine on a case by case basis whether such collaboration is in the best interests of its clients.

Principle 6

Institutional investors should have a clear policy on voting and disclosure of voting activity

Thornbridge’s policy is to exercise voting rights where it believes, taking into account the size of the holding, it is in the interests of the underlying clients for such rights to be exercised.

Principle 7

Institutional investors should report periodically on their stewardship and voting activities

If requested to do so Thornbridge will send details of voting record to clients

Shareholder Rights Directive II Disclosure

The FCA has published the requirements in relation to the Shareholder Rights Directive II (“SRD II”) in SYSC 3.4 of the FCA Handbook.

The objective of the SRD II is to encourage long-term shareholder engagement with investee companies regarding performance on strategy, governance, environmental and social issues. Firms like Thornbridge must either develop an engagement policy and publish it on the firm’s website or publish a statement explaining why it has chosen not to.

Thornbridge fully endorse the objectives of SRD II. However, it has decided that it is not in the best interests of its clients to develop an engagement policy at this time.