This statement outlines the Nekton’s position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in 2012, 2020 and 2026. Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Nekton is required to make a public disclosure about the nature of its commitment and level of compliance to the Code or, where it does not commit to the Code, to explain its alternative investment strategy.
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The Code is a voluntary framework that promotes the responsible allocation, management and oversight of capital to create long term sustainable value for clients and beneficiaries. It aims to enhance the quality of engagement between investors and the entities in which they invest. The Code encourages investors to consider long-term risks and opportunities, including impacts on the economy, environment, and society on which beneficiaries’ interests depend. It is applied on an “apply and explain” basis and it outlines how asset owners and asset managers can protect and enhance the value of the investments entrusted to them.
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The FRC recognises that there has been significant growth in investment in assets other than listed equity and capital is invested in a range of asset classes (e.g., fixed income, private equity, real estate, and infrastructure) over which investors have different terms and investment periods, rights and levels of influence. Hence the Code does not solely apply to equity investments.
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The FRC also 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.
The Code comprises six Principles that can be summarised as follows:
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Principle 1 – Signatories integrate stewardship and investment to deliver long-term sustainable value for their clients and beneficiaries
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Principle 2 – Signatories identify and respond to market-wide and systemic risks to promote well-functioning financial markets
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Principle 3 – Signatories engage to maintain or enhance the value of assets
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Principle 4 – Signatories actively exercise their rights and responsibilities
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Principle 5 – Signatories integrate stewardship considerations into their selection and oversight of external managers
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Principle 6 – Signatories monitor and hold to account stewardship service providers
Nekton’s approach in relation to engagement with issuers and their management, is determined on a global basis. A consistent global approach is taken to engagement with issuers and their management in all of the jurisdictions in which we invest and, consequently, Nekton does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction and feels that the Code is not appropriate to its business model.
​However, whilst we have not made a formal commitment of compliance with the Code, Nekton’s investment approach is such that we are generally supportive of the spirit and aims of good stewardship as contained within the Code. As such, in practice, Nekton would take into consideration the principles as set out in the Code.
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This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should our position change, we will review our commitment to the Code and make appropriate disclosure at that time.
For further details on any of the above information please contact Nekton’s Compliance Officer.