Axebrook Capital LLP: Shareholder Rights Directive (“SRD II”)

SRD II aims to promote effective stewardship and long-term investment decision making in respect of shares traded on EEA regulated markets and comparable regulated markets outside the EEA. It came into effect on 10 June 2019.

The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:

• Publish their shareholder engagement policy or explain why they don’t have one (COBS 2.2B.5R).
• Make annual public disclosures relating to the implementation of their shareholder engagement policy (COBS 2.2B.5R).
• Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets (COBS 2.2B.9R).

Axebrook Capital LLP (“Axebrook” or the “Firm”) pursues a predominantly credit-focused strategy with limited exposure to global equities. Given the de minimis levels of trading of shares on regulated markets, whilst the Firm generally supports the objectives of SRDII, it does not currently consider a shareholder engagement policy to be relevant to its investment activities nor consistent with its stated investment strategy. This approach will be kept under review.