Under chapters 2.2B and 2.2.3R of the FCA's Conduct of Business Sourcebook, Evince Asset Management UK Limited (the "Firm" or “Evince”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code and the Shareholders Rights Directive, or, where it does not commit to either or both, its alternative investment strategy.
Stewardship Code (the “Code”)
The Code sets out a number of principles relating to engagement by asset managers or asset owners across all asset classes including, for example, listed equity, fixed income, private equity, infrastructure investment and in investments outside the UK.
The twelve principles of the Code for Asset owners and Asset Managers are as follows:
Purpose and Governance:
1. Purpose, strategy and culture
Asset Managers’ investment beliefs, strategy, and culture to facilitate long term value, via stewardship, for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
2. Governance, resources and incentives
Asset Managers’ governance, resources and incentives support stewardship.
3. Conflicts of Interest
Asset Managers should manage conflicts of interest to put the best interests of clients and beneficiaries first.
4. Promoting well-functioning markets
Asset Managers should identify and respond to market-wide and systemic risks to promote a well-functioning financial system.
5. Review and assurance
Asset Managers should review their policies, assure their processes and assess the effectiveness of their activities.
6. Client and beneficiary needs
Asset Managers should take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.
7. Stewardship, investment and ESG integration
Asset Managers should systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.
8. Monitoring managers and service providers
Asset Managers should monitor and hold to account third-party managers/proxy advisors/research or other service providers.
Asset Managers should engage with issuers to maintain or enhance the value of assets.
Asset Managers, where necessary, should participate in collaborative engagement to influence issuers.
Asset Managers, where necessary, should escalate stewardship activities to influence issuers.
Exercising rights and responsibilities:
12. Exercising rights and responsibilities
Asset Managers should actively exercise their rights and responsibilities across all asset classes.
Shareholders Rights Directive (the “Directive”)
Similarly, the Directive requires firms that invest in shares that trade on an EU regulated market to develop and publicly disclose an engagement policy or publicly disclose a clear and reasoned explanation of why it has chosen not to comply with this requirement.
Evince is authorised by the FCA as an investment manager. The Firm’s sole client is its United States based parent, Evince Asset Management LP, to whom it provides sub-investment management services. As such, Evince Asset Management LP has ultimate investment management responsibility as well as responsibility for any subsequent engagement with investee companies (if applicable).
Consequently, while the Firm supports the general objectives that underlie the Code and the Directive, the provisions of both are not relevant to the Firm at this time. If the Firm's activities change in such a manner that the provisions of either the Code or the Directive become relevant, the Firm will amend this disclosure accordingly.
For further information on the Firm’s approach please contact the Firm’s Compliance Officer, Filippo Altissimo, at: firstname.lastname@example.org.