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Stewardship Code

The UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Brooklands is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s UK 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.

As a fiduciary and alternative investment fund manager, Brooklands has a duty to act in the best interests of all investors and our aim is to protect and enhance returns in line with a fund’s investment guidelines and objectives and any specific risk tolerances specified within a fund’s Offering Memorandum. The Firm pursues various types of strategies, predominantly being long short equity that invest in global equities, including UK equities. The Code is therefore relevant to some aspects of the Firm’s trading. While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The Firm also invests in a variety of jurisdictions globally and has a consistent investment strategy and approach to engagement with company management in all of the jurisdictions in which it invests.

Shareholders Rights Directive II Disclosure

SRD II establishes requirements in relation to the exercise of certain shareholder rights attached to voting shares in general meetings of companies which have their registered office in an EU Member State and the shares are traded on a regulated market situated or operating within a Member State. The requirements apply to intermediaries, proxy advisers, institutional investors, asset managers and issuers. Institutional investors and asset managers must comply with the requirements of SRD II or publicly disclose a clear and reasoned explanation as to why they have chosen not to comply with one or more of the requirements

As a fiduciary and alternative investment fund manager, Brooklands manages funds that invest predominantly in global equities, including only a proportion in the EU and as a result, the SRD II disclosure requirements are not relevant to Brooklands business activities at present.