UK Stewardship Code

Under section 2.2.3R of the Conduct of Business Sourcebook ("COBS?) of the Financial Conduct Authority ("FCA?), AGC Equity Partners Limited (the "Firm?) being registered and authorised by the FCA with reference number 480570 is required to make a public disclosure in relation to the nature of its commitment to the UK Stewardship Code ( the "Code?). The Code is voluntary and was published by the Financial Reporting Council (?FRC?) in July 2010 and subsequently revised in September 2012.

The Code aims to enhance the quality of engagement between institutional investors and companies to assist in improving long-term risk-adjusted returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by institutional investors on a "comply or explain? basis. The Code is directed in the first instance to institutional investors, such as asset managers with equity holdings in UK listed companies. The FRC recognises that not all parts of the Code will be relevant to all asset managers and that smaller institutions may judge some of the principles and guidance to be disproportionate. Furthermore, the FRC further recognises as legitimate that some institutional investors will not engage with companies, depending on their investment strategy and in such cases, institutional investors are required to "explain? why it is not appropriate to comply with a particular principle.

The seven principles of the Code state that institutional investors should:

1. Publicly disclose their policy on how they will discharge their stewardship responsibilities;

2. Have a 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 stewardship activities;

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.


The Firm only acts as an adviser to AGC Equity Partners Investment Management Limited, which is an exempted company with limited liability registered in the Cayman Islands in relation to their managed accounts and investment fund mandates. In this capacity, the investment decision process of the Firm is not engaged in Stewardship activities. As such, while the Firm generally supports the underlying objectives of the Code, the Firm does not consider it must commit to this UK voluntary practice for UK listed equities.

Should any of the above change, the Firm will review its commitment to the Code at that time and make appropriate disclosures.

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