Regulatory Disclosures

UK Stewardship Code

Under Rule 2.2.3R of the Conduct of Business Sourcebook of the Financial Conduct Authority, Metronome Capital LLP (the “Firm”) is required to include on its website, or make publically available, a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK-listed equity issuers.

The Firm acts as an Investment Manager to certain private investment funds (the “Funds”) that take long and short positions in global equity securities of listed companies, including those listed in the UK, and related derivatives. The Code is therefore relevant to some aspects of the Firm’s activities. The Firm approaches the issue of engagement with issuers and their management on a case by case basis, taking into account the actions that will lead to the most favourable outcome for the value of the investments managed by the Firm.

While the Firm generally supports the objectives that underlie the Code, the Firm does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. Consequently, the Firm has elected not to formally comply with the Code.

Should any of the above factors change, we will review our commitment to the Code at that time and make appropriate disclosure.

The Second Shareholder Rights Directive

The Second Shareholder Rights Directive (“SRD”), which took effect in the UK on 10 June 2019, aims to improve shareholder engagement and increase transparency around stewardship. Please contact us for more information regarding our engagement policy.

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