Stewardship Code

The Fund Incubator Stewardship Code

UK Stewardship Code Disclosure Statement (the “Code”):

The Code which was first published by the Financial Reporting Council in 2010 aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. The Code is a voluntary code that sets out good practice on engagement with investee companies and is to be applied to firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate.

The Code sets out seven principles that institutional investors should follow:

  1. Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  2. Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
  3. Monitor their investee companies;
  4. Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
  5. Be willing to act collectively with other investors where appropriate;
  6. Have a clear policy on voting and disclosure of voting activity; and
  7. Report periodically on their stewardship and voting activities.

Whilst TFI supports the objectives set out within the Code but  has taken the decision not to commit to the principles of the Code. Funds managed by TFI pursue a range of investment strategies involving a wide variety of investments and timeframes. Most investments are minority investments into companies that are not listed or are primarily listed outside of the UK. The Code is therefore applicable to a very small proportion of TFI’s activities.

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

(August 2022)