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UK Stewardship Code Disclosure Statement

The FCA’s Conduct of Business Sourcebook rule 2.2.3R, requires Square Capital LLP, as an Investment Manager, to include a disclosure on its website stating the nature of its commitment to the UK Stewardship Code (“the Code”) issued by the Financial Reporting Council. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy.
The Code sets out various principles relating to the level of engagement by investors with UK equity issuers. The Code aims to enhance the quality of engagement between institutional investors and companies that they invest in.

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.
It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

Square Capital LLP’s Stewardship Code disclosure

Square Capital is an independent wealth manager established to cater to the very specific investment management and advisory needs of high net worth individuals, families, trusts and charities.
Clients’ portfolios are managed on a discretionary basis where day to day decisions are made within an agreed framework and risk profile. We invest across all asset classes multi-jurisdictionally, focused on delivering returns and managing liquidity. Thereby the firm takes a consistent approach to engaging with the issuers and their management in all the jurisdictions the firm invests in. It is therefore not deemed appropriate to comply with any voluntary codes of practice in any individual jurisdictions

Therefore, although the firm supports the objectives set out within the Code due to the current nature of its investment strategy it has opted not to comply with its provisions.

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