Shareholder Rights Directive II

Shareholders Rights Directive II (‘SRD II’ - 2017/828) Statement

Article 3g of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as HBC UK LLP to either:

• develop and disclose an engagement policy describing how the firm integrates shareholder engagement in its investment strategy; or
• disclose why the firm has chosen not to comply with those requirements.
  

The above engagement policy is limited to the extent that a firm invests on behalf of investors in shares traded on a regulated market (or on third country markets that meet comparable requirements and where the shares dealt in are of a quality comparable to those in a regulated market in the UK).

The firm’s investment strategy is such that whilst the firm may invest in shares traded on a regulated market (or comparable market), the resultant holdings are for investment purposes and the firm does not take explicitly activist positions.

While HBC UK LLP generally supports the objectives that underlie SRD II, for the above reason the firm has chosen not to produce an engagement policy at this time. The Firm will keep its approach to the Code under periodic review and if its investment strategies change in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.