UK Stewardship Code Disclosure Statement

 

The Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”) defines stewardship as “the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries”. Effective from 1 January 2026, the amended Code introduces a streamlined structure for reporting and is divided into two parts: Policy and Context Disclosure and Activities and Outcomes Report.

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The Principles of the Code

There are six Principles of the Code that apply to asset owners and asset managers:

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Purpose and governance

1. Integrating stewardship and investment

2. Promoting well-functioning markets

3. Engagement

4. Exercising rights and responsibilities

5. Selection and oversight of managers

6. Monitoring service providers

 

The FRC requires that firms aiming to be signatories to the Code must produce an annual Stewardship Report explaining how they have applied the Code in the previous 12 months. The FRC will evaluate Reports against an assessment framework and those meeting the reporting expectations will be listed as signatories to the Code.

 

 

FCA Regulatory Disclosure on the Stewardship Code

Rule 2.2.3R of the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (“COBS”) requires an FCA authorised firm to disclose the nature of its commitment to the FRC’s UK Stewardship Code or, where it does not commit to the code, its alternative investment strategy.

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Adherence to the Code is voluntary. Consequently, while Perbak generally supports the objectives that underlie the Code, the provisions of the Code are not considered to be relevant to the activities currently undertaken by the Firm. However, the Firm has chosen an alternative approach to stewardship consistent with its overall approach to ESG.

 

Perbak Capital Partners LLP may determine its approach to stewardship on a case-by-case basis, taking into account the best approach to optimising the returns on its investments. Should our activities change in such a manner that the provisions of the Code become relevant, the Firm will consider committing to the Code and will amend this disclosure accordingly. 

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For further details on any of the above information, please contact enquires@pcap.info