Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Alanda Capital management Limited (“Alanda”) 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 and sets out a number of principles relating to engagement by investors with UK equity issuers.

Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance. As a fiduciary and alternative investment fund manager, Alanda has a duty to act in the best interests of all investors and our aim is to protect and enhance returns in line with a fund’s investment guidelines and objectives and any specific risk tolerances specified within a fund’s Private Placement Memorandum or Prospectus.

Alanda pursues a Long Short strategy which involves investing in global equities, including UK equities. The Code is therefore relevant to some aspects of Alanda’s trading. While Alanda supports the objectives that underlie the Code, we have chosen not to commit to the Code. Alanda invests in a variety of asset classes and in a variety of jurisdictions globally. When we feel it is necessary we take a global approach to engagement with issuers and their management in all of the jurisdictions in which we invest and consequently, we do not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. We have arrangements in place to receive details of forthcoming corporate meetings. These details are provided to the fund management team who are given the opportunity to consider whether to vote or abstain. We do not make use of automated voting services provided by third parties. Our aim as a fiduciary is to consider stewardship issues on a case by case basis, making bespoke decisions in the best interests of investors in light of a particular circumstance and the fund’s mandate in question.