Stewardship Code

The UK Stewardship Code was published in July 2010 and subsequently revised in 2012 and in 2020 (‘the 2020 UK code’) by the Financial Reporting Council (‘FRC’), the UK’s independent regulator responsible for promoting high quality corporate governance and reporting to encourage investment.

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. 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.

In accordance with the FCA rules, Marsham is required to publish a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "UK Stewardship Code"). Whilst Marsham supports the aims of the UK Stewardship Code it is not current a signatory to it. Marsham may become a signatory in the future dependent upon its clients’ needs and expectations.

Marsham has instead committed to comply with the principles contained in the European Fund and Asset Management Association (“EFAMA”) Stewardship Code (the “EFAMA Code”) for asset managers seeking to comply with the revised EU Shareholder Rights Directive. More information on our commitment to the EFAMA Code and our Voting Policy and can be found in our Voting Policy upon request.