Under the UK Financial Conduct Authority’s (“FCA”) Conduct of Business rule 2.2.3, all firms which are authorised by the FCA to manage funds are required to make a public disclosure in relation to the nature of their commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code, last published by the FRC in September 2012 (“Code”).
The Code aims to enhance the quality of engagement between institutional investors and such firms, to help improve long term returns to shareholders and the efficient exercise of governance responsibilities.
The FRC recognises however, that not all parts of the Code will be relevant to all firms, and that smaller firms may judge some or all of the seven principles and guidance to be disproportionate to the scale and complexity of their businesses. Accordingly, where a FCA regulated firm does not feel it appropriate to commit to the Code, an explanation of non-compliance is required with its alternative investment strategy stated in general terms.
Consequently, as Caerus is an investment and asset manager which acts solely as an operator of collective investment schemes investing in direct commercial real estate, full compliance with the Code is currently deemed not relevant as the firm does not provide any advice on or deal in the trading of any listed equities or other forms of listed securities. However, the firm does maintain a robust policy on managing conflicts of interest, while also having clear policies on voting, reporting and complaints handling procedures.
Caerus will continue to review the Code’s applicability to our business operations, and should any material changes occur to the aforementioned strategy (which would make the Code relevant), this disclosure notice shall be amended appropriately at such time.