Altana Wealth Commitment to the UK Stewardship Code
November 2022
Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Altana Wealth (the "Firm") is required to include on this website 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 equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance. We have detailed below the reasons why the firm has chosen not to commit to the Code.
The Firm pursues a strategy that involves investing in a diversified portfolio of sovereign debt, foreign currencies, financial and commodity futures, equity, credit instruments, gold, and related derivatives. Consequently, while the Firm supports the general objectives that underlie the Code, the provisions of the Code are not relevant to the type of trading currently undertaken by the Firm. If the Firm’s investment strategy changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.
Shareholder Rights Directive (SRD II)
SRD II aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on a regulated market. For these purposes a regulated market isa UK RIE (or a market outside the United Kingdom which meets comparable requirements and where the financial instruments dealt in are of a quality comparable to those in a regulated market in the United Kingdom). It came into effect on 10 June 2019.
The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:
Publish their shareholder engagement policy (or explain why they don't have one) – COBS 2.2B.5R.
Make annual public disclosures relating to the implementation of their shareholder engagement policy– COBS 2.2B.5R.
Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R.
Altana Wealth firmly believes in the importance of effective stewardship and long-term decision making, involving transparency of engagement policies between institutional investors and the investee companies. The Firm does not pursue an activist strategy/deems disclosure to be in the best interests of its clients. As such, the Firm does not currently maintain and will not publish an engagement policy as specified by SRD II. The Firm shall periodically review its investment strategies to determine whether its investment activities have changed to the extent that the Firm should adopt an engagement policy under SRD II.