UK Regulatory Disclosure

Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Aperture Investors UK, Ltd (“Aperture UK” or the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code, first published in 2010 and subsequently subjected to updates in 2012 and 2020.  The most recently published UK Stewardship Code 2020, sets high standards by way of Principles which should be applied by asset owners and service providers (in some cases), as well as asset managers, such as Aperture UK .

Aperture UK pursues a number of different investment strategies across its investment mandates, there is currently limited engagement with issuers and their management.  As a consequence, the 2020 Code, as presented, is not considered to be appropriate to Aperture UK’s investment approach, and therefore, the Firm has chosen not to commit to the Code.  We agree with the aspirations of the latest Code and that its application has a role to play in creating long-term value for clients and the ultimate beneficiaries of the assets managed, with the potential to lead to sustainable benefits for stakeholders in the issuers we invest in.  We consider Stewardship issues on a case-by-case basis and where relevant, make decisions in the best interests of our clients.  Should an investment strategy change in such a manner that the provisions of the Code become more relevant, Aperture UK will reconsider its position under the Code.

Shareholder Rights Directive II Disclosure

COBS 2.2B.5 R of the FCA handbook requires firms, such as Aperture UK  to either publicly disclose an engagement policy that meets the requirements of COBS 2.2B.6R and make an annual disclosures of the satisfactory implementation of that engagement policy, or provide a clear and reasoned explanation of why it has chosen not to do so.

Aperture UK  has chosen not to implement and disclose an engagement policy at this time, as it does not consider that it is proportionate.  Aperture UK was recently authorised in 2020 and is still in the early stages of its growth, with multiple strategies, only some of which are invested in equities.  At this time, it considers the interests of its clients would be best promoted by focusing on stock selection and active management of their portfolios. However, Aperture UK intends to keep this decision under review.

EU Sustainable Finance Disclosure Regulation

The European Commission has introduced Regulation 2019/2088 relating to the transparency and disclosure obligations for investors, funds and asset managers in relation to ESG factors (the “EU Sustainable Finance Disclosure Regulation” or the “EU SFDR”). Whilst the EU SFDR does not have legal effect in the UK post-Brexit, given that the Aperture Investors SICAV Sub Funds (“Sub-funds”) are domiciled in Luxembourg, Aperture UK has elected to comply with those elements of the EU SFDR that apply at the level of the Sub funds to help ensure that the objectives of the EU SFDR are met. The relevant Sub-fund-related disclosures are available in the Aperture Investors SICAV fund prospectus which can be accessed [email protected].

Pillar III disclosures

As part of the Capital Requirements Directive, introduced by the European Union in 2007, regulated firms have a requirement to publish a document describing the risks they face in their normal course of business, alongside a description of the capital held to support the business.

Pillar 3 complements the minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2), and its aim is to encourage market discipline by developing a set of disclosure requirements. These allow market participants to assess key pieces of information on a firm’s capital, risk exposures and risk assessment processes. The third pillar greatly increases transparency and the disclosures firms must make, and is designed to allow the market and investors to have a better understanding of the overall firm risk.

RTS28 Best Execution Report

The recast MIFID and Regulation (together, “MiFID2”), and Regulatory Technical Standard 28 (“RTS 28”) (Delegated Regulation (EU) 2017/576), as implemented in the UK, requires Aperture UK to publish on its website on an annual basis:

• a list of the firm’s top 5 execution venues (including brokers) in terms of trading volumes for all executed client orders per class of financial instruments;

• a list of the firm’s top 5 execution venues (including brokers) in terms of trading volumes for all executed client orders in securities financing transactions per class of financial instruments; and

• for each class of financial instrument, a summary of the analysis and conclusions the firm draws from monitoring the quality of execution obtained on execution venues (including brokers) where Aperture UK executed all client orders in the previous year.

Regulatory Documents