Hollbeach Investment Management: UK Stewardship Code

Rule 2.2.3R of the Conduct of Business sourcebook of the FCA Rules requires an FCA authorised firm to either disclose its compliance or explain its non-compliance with the principles set out in the UK Financial Reporting Council's Stewardship Code (the "Code"). Hollbeach Investment Management LLP ("the Firm") is regulated by the FCA in the United Kingdom and therefore subject to COBS 2.2.3R.

The Firm manages assets across a number of global diversified hedge funds and UCITS strategies, but does not take an activist shareholder approach. Accordingly, whilst the Firm supports the Code as a mechanism to promote best practice in the institutional shareholder governance of UK listed companies, the Firm does not consider the Code or its principles to be appropriate for the funds' investment strategies.