Statement in Relation to the Shareholder Rights Directive II
Promeritum Investment Management LLP (“Promeritum”, the “Company”) is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Alternative Investment Fund Manager (‘AIFM’)(CPM firm). The Company is required to comply with applicable FCA rules.
Rule 2.2B.5R in the Conduct of Business Rules Sourcebook (“COBS”) of the FCA, which implements Article 3(g) of Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC (together with the relevant national implementing regulations, the “SRD”) requires UK asset managers to adopt on a “comply or explain” basis an engagement policy describing how an asset manager integrates its investment strategy relating to shareholder engagement in companies whose shares are listed on EU regulated markets or comparable markets outside of the EU (“investee companies”).
Promeritum is an investment manager for the purposes of COBS and the SRD. The regulatory permissions allow it to provide investment management services to Alternative Investment Funds. Promeritum does not actively invest as part of its investment strategy in the shares of investee companies, but may on an infrequent basis invest in listed equities as an investment ancillary to, or as a result of a debt investment. Promeritum has determined that due to the nature and size of such investments, at this time is not appropriate to adopt an engagement policy for the purposes of COBS or the SRD. This policy will be kept under review.
Updated 1 September 2020