Sustainability Disclosures

The following funds are subject to the EU Sustainable Finance Disclosure Regulation (“SFDR”):

To view the relevant sustainability related disclosures made under SFDR select the links included above.

Details of the Integration of Sustainability Related Risks into the investment processes, Principle Adverse Impact Statements (PAIS) and, where relevant, how Remuneration Practices are consistent with the integration of sustainability risks can be found in the disclosures on the website of each fund.

The following funds are not subject to SFDR and therefore do not have sustainability related disclosures:

  • The Levendi Thornbridge Defined Return Fund
  • The Thornbridge Global Opportunities Fund
  • The Raynar Flagship Fund
  • The Raynar Enhanced Fund

Currently, none of Thornbridge’s funds are in-scope of the Sustainability Disclosure Requirements (UK SDR) or the FCA’s investment labels regime.

Stewardship Code

The UK Stewardship Code (“The Code”) was first published in July 2010, revised in September 2012 and January 2020. It promotes effective stewardship in the UK setting out good practice for institutional investors and asset managers. Stewardship activities include monitoring assets and service providers, engaging issuers and holding them to account on material issues, and publicly reporting on the outcomes of these activities.

Thornbridge Investment Management LLP fully supports and follows the objectives of the Code, although considers that it is not necessary for the Firm to be a signatory at this time. This decision is kept under review and should circumstances necessitate we will update our website to announce a change.

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.