Quay Partners Investments is a trading name of Vittoria & Partners Ltd, registered in England and Wales (OC400454) with its registered office at 10 Stanford Road, London, England, W8 5QJ
Regulatory Status
Quay Partners Investment is authorised and regulated by the Financial Conduct Authority (FRN 709710) Our FCA Permissions (full scope AIFM with MIFID permissions)
Stewardship Code
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Quay Partners Investments (the “Firm”) is required to make a public disclosure in relation to its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with ait in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance.
The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term 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 firms on a “comply or explain” basis. 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.
The seven principles of the Code are that institutional investors should:
• Publicly disclose their policy on how they will discharge their stewardship responsibilities;
• Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
• Monitor their investee companies;
• Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
• Be willing to act collectively with other investors where appropriate;
• Have a clear policy on voting and disclosure of voting activity; and
• Report periodically on their stewardship and voting activities.
The Firm does not currently comply with the Code for the following reasons:
• Our business model typically involves managing funds for temporary periods. It is often not practical to engage in meaningful engagement with investee companies during this period;
• The investment strategies we manage are diverse meaning that it is not possible to have a single policy that covers all situations; and
• We determine our approach to stewardship on a case-by-case basis, taking into account the actions that will lead to the most favourable outcome for the value of our investments. Should any of the above factors change, we will review our commitment to the Code at that time and make appropriate disclosure.