UK Stewardship Code - Statement of Compliance
Ahli United Bank (UK) PLC (“AUBUK”)
AUBUK supports the Financial Reporting Council Stewardship Code (as revised in September 2012) which aims to promote the long term success of companies in such a way that the ultimate providers of capital also prosper.
There are seven principles with which we either “comply or explain” as follows:
Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
AUBUK sponsor and act as appointed adviser to the management of various non-UK collective investment schemes. In addition we may from time to time establish our own collective investment schemes although at the date of publication there are no such schemes open to investors.
We also offer management of segregated investment portfolios to key clients. Under such arrangements AUB UK may delegate the investment management to specified third party fund managers. The terms of the delegation require the fund managers to maintain up to date knowledge of investee companies, including meetings where relevant. Periodically we will seek confirmation of this process from the delegated fund managers, including due diligence visits if necessary.
In addition to following the Stewardship Code ourselves, we expect and require all delegated third party fund managers to follow the Stewardship Code. Where deemed necessary we would expect the delegated third party fund manager to obtain an independent opinion on their engagement and voting processes, and require that AUBUK is given access to such assurance reports.
Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.
Our primary responsibility as an investment management firm is to try to add value over the long term bearing in mind ownership responsibilities as agents for our clients. A detailed Conflicts of Interest Policy is maintained along with a Conflicts of Interest Register with actions taken to mitigate these conflicts. These implicitlyinclude potential conflicts over voting that impact AUBUK, its delegates and the funds under management.
Institutional investors should monitor their investee companies.
As noted at Principle 1 above the delegated third party fund managers perform this activity
Institutional investors should establish clear guidelines on when and how they will escalate their stewardship activities.
As part of the delegation to any third party fund managers we implicitlyimpose upon them the requirement to monitor the activities and management of investee companies for circumstances requiring dialogue with the management of investee companies. If we deem it necessary we will provide a list of major event types requiring such dialogue to the third party fund managers.
Institutional investors should be willing to act collectively with other investors where appropriate.
As noted at Principle4 above we require thatany third party fund managers identify circumstances requiring dialogue with the management of investee companies. If necessary and where applicable we expect this to include other investors.
Institutional investors should have a clear policy on voting and disclosure of voting activity.
Voting is at the discretion of the delegated third party fund managers so as to act in the best interests of the delegated funds. A record of all voting on behalf of our delegated funds is maintained and is made available to us for all relevant periods.
Institutional investors should report periodically on their stewardship and voting activities.
The voting activity of the UK equities held within the various funds will be made available to the investors in those funds upon request.
The AUBUK Statement of Compliance with the UK Stewardship Code will be made available on AUBUK’s website and will be updated where necessary. It will be reviewed for update at least annually.