Hudson Bay Capital UK LLP (“HBC UK LLP” or “Firm”)
Stewardship Code Disclosure
Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook (“COBS”), HBC UK LLP is required to disclose clearly on its website the nature of its commitment to the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”).
The current edition of the Code is the UK Stewardship Code 2026, which the FRC published on 3 June 2025 and which applies from 1 January 2026 in place of the UK Stewardship Code 2020. It comprises six ‘apply and explain’ Principles for asset owners and asset managers, supported by a Policy and Context Disclosure, together with a separate set of four Principles for service providers. The full text of the Code is available on the FRC’s website.
The Code is voluntary and operates on an ‘apply and explain’ basis. It is aimed at enhancing the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies, that institutional investors should aspire to.
The FRC define ‘stewardship’ as ‘the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries.’
The Firm supports the objectives underlying the Code. Having considered the Code, the Firm is not a signatory to it and does not currently commit to it. The Firm’s investment activities are carried on for professional clients and are characterised by relatively short holding periods, predominantly hedged and non-directional exposures, and positions that are frequently taken through derivative instruments carrying no voting or other shareholder rights.
The Firm does not generally seek to influence the governance of the issuers to which it has exposure, and it does not manage assets under mandates from UK asset owners of the kind that the Code principally contemplates. The Firm therefore considers that commitment to the Code would not be meaningful in the context of its investment strategy at this time. The Firm remains subject to, and observes, the legal and regulatory requirements applicable to its investment activities, including those governing market conduct and the exercise of any shareholder rights that it holds.
The Firm has also considered COBS 2.2B (Shareholder engagement). To the extent that the Firm invests on behalf of investors in shares traded on a regulated market, it has not developed an engagement policy, for the reasons set out above; shareholder engagement is not generally a component of the Firm’s investment process and the Firm generally does not seek to exercise influence over the governance of issuers. Should that change in the future, the Firm will review its position and update this disclosure accordingly.
This disclosure will be reviewed at least annually.
Any questions regarding this disclosure should be directed to compliance@hudsonbaycapital.com.
Disclosure last updated: September 2026
