Public Website Disclosure
UK Stewardship Code Disclosure
We are required to make a public disclosure in relation to the nature of our commitment to the UK Stewardship Code (“the Code”), which was published by the Financial Reporting Council (”FRC”) in July 2010. The disclosure is made in relation to Prisma Capital Management International LLP, which is authorized and regulated by the Financial Conduct Authority (“FCA”), in accordance with Rule 2.2 of the FCA’s Conduct of Business Sourcebook.
The Code aims to enhance the quality of engagement between institutional investors and companies they invest in to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “comply or explain” basis. The FRC recognizes that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.
The seven principles of the Code are that institutional investors should:
- Publicly disclose their policy on how they will discharge their stewardship responsibilities;
- Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
- Monitor their investee companies;
- Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
- Be willing to act collectively with other investors where appropriate;
- Have a clear policy on voting and disclosure of voting activity; and
- Report periodically on their stewardship and voting activities.
The Code is not currently relevant to Prisma Capital Management International LLP for the following reasons:
- Prisma Capital Management International LLP, through which its US parent, Prisma Capital Partners LP (”Prisma” or “PAAMCO Prisma”), conducts business, manages all client investments through sub-advisory agreements;
- Prisma is a hedge fund-of-funds manager that makes and monitors investments in hedge fund managers; and
- Prisma does not make direct investments in companies listed in the UK and, therefore, does not engage in the stewardship practices set out in the Code.
Should any of the above factors change, we will review our commitment to the Code at that time and make appropriate disclosure.
For further details on any of the above information, please contact Vincent Cuticello (+ 212-590-0879).
Prisma Capital Management International LLP
May 31, 2017