UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Castlebar Capital LLP (“Castlebar” or 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 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 (in our case, 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.
   
   Investment Approach:

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.
   
   Engagement:

9. Engagement
   Asset Managers should engage with issuers to maintain or enhance the value of assets.

10. Collaboration
    Asset Managers, where necessary, should participate in collaborative engagement to influence issuers.

11. Escalation
    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.

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Whilst Castlebar fully supports the general objectives that underlie the Code and observes high standards of corporate governance and due diligence in respect of its investments, we determine our approach to stewardship on a case by case basis taking into account the best approach to optimising the returns on its investments.  As a result we have not made a formal commitment of compliance with the Code at this time and should our position change, we will review our commitment to the Code and make appropriate disclosure at that time.