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.

MIFIDPRU 8 Disclosure

The Financial Conduct Authority (“FCA”) in the prudential sourcebook for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Aperture Investors UK, Ltd (“Aperture UK” or the “Firm”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which the Firm must comply, further to those prudential requirements. 

Aperture UK is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices. This information can be found via the link below in “Regulatory Documents” entitled “MIFIDPRU 8 Disclosure”.

Research Disclosure

Aperture Investors UK, Ltd discloses its 2022 annual budget for the following funds under management:

1. Aperture Investors SICAV – Credit Opportunities Fund (“COF”)
2. Aperture Investors SICAV – European Innovation Fund (“INNOV”)
3. Aperture Investors SICAV – Short Duration High Yield Fund (“SDHY”)
4. Aperture Investors SICAV – Small Cap Innovation Fund (“Small Cap”)
5. Aperture International Equity Fund (“IEF”)*

(together “Fund”)

*Note that the IEF was managed by Aperture Investors UK, Ltd only up until 1^st July 2022. Therefore, there are no research charges indicated for this fund for the second half of 2022.

The Research Disclosure 2022 table stipulates the following:

1. The estimated research amount on behalf of each Fund (the amount provisionally budgeted by the relevant investment team).
2. The actual research charges incurred on behalf of each Fund (reflecting the amount of research consumed by the relevant investment team).
3. The percentage of AUM each Fund’s research charge represented.

FCA Consumer Duty

Aperture Investors UK, Ltd has made available certain information for intermediaries distributing products it has co-manufactured for the purposes of the FCA Consumer Duty.