UK Stewardship Code Disclosure Statement:

Under COBS 2.2 of the FCA Handbook, Susa Fund Management LLP ("the Firm") is required to make a public disclosure in relation to the nature of its commitment to the above Code, which was published by the Financial Reporting Council ('FRC') in July 2010.

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 and is to be applied by firms on a "comply or explain" basis. 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.

The code is complementary to the UK Corporate Governance Code.

The seven principles of the Code are that institutional investors should:


Susa Fund Management LLP operates a strategy that seeks to achieve capital appreciation and maximum risk-adjusted absolute returns by employing a fundamental, value approach to European Long/Short equities.

The Firm supports the objectives of the Code and has committed to the Code. Its statement of how the principles of the Code have been applied and, where appropriate, an explanation of those principles which have not been complied with, is set out below:

Policy on discharging stewardship responsibilities

Investment decisions are based on the Firm's own research into the prospects of those businesses in which it is intending to invest. This research may be supplemented by meetings with the senior management of those businesses together with independent reports and other data, in order to arrive at the Firm's own assessments of business strategies and likely turnout.

The process emphasises the long-term intent of the investment decision and includes an on-going monitoring review and internal challenge of the investment thesis. Engagement with the senior management of the businesses is followed through where considered necessary to augment the initial investment and subsequent review process.

Due consideration is given to the FRC's UK Corporate Governance Code when assessing the responses of investee companies to the Firm's queries.

Policy on managing conflicts of interest in relation to stewardship

In compliance with FCA rules, the Firm ensures that all potential and actual conflicts are identified, evaluated, managed, monitored and recorded. It is the Firm's policy and duty to act in the best interest of all of its clients. Should a conflict of interest arise, the firm's senior management would take appropriate steps to ensure fair treatment of all clients, including disclosure of the conflict to the affected clients, if appropriate.

Monitoring of investee companies

Comprehensive and continuous research and monitoring of investee companies is essential to the Firm's investment process. The Firm monitors its investee companies to determine when dialogue with management may be necessary. The Firm utilises various research and support tools to meet this principle. The Firm does not wish to be made insiders in normal circumstances, and therefore expects investee companies and their advisers to ensure that information that could affect the Firm's ability to deal in the shares of the company concerned is not conveyed to the Firm without its prior agreement from the Firm's compliance officer.

Guidelines on escalation

It is not the Firm's intention to interfere in management of of investee companies however, where there are concerns about any aspect of an investee company's investment strategy, performance, governance or any other matter, this may be escalated to the management of the company.

Examples of the way in which such matter could be escalated include:

Where the Firm believes that it is no longer in the best interests of its clients to continue to hold the shares of a company, it will reduce or eliminate the position.

Acting collectively with other investors

There may be situations where it is appropriate to act collectively with other shareholders in order to engage with an investee company in the most effective manner. This would only be considered if a material issue arose and there were no perceived conflicts in accordance with regulatory and compliance requirements.

Policy on voting and disclosure of voting activity

The Firm recognises that not all investments are identical and employs a discretionary policy with regards to attending General Meetings of investee companies and voting its shares. Where the Firm holds an investment via a derivative-based CFD this does not confer the ability to vote.

Due to underlying client confidentiality and investment strategy reasons, the Firm will not normally disclose voting actions at a detailed level. Upon request from a client or as required by law or regulation, the Firm will disclose the manner in which voting rights were exercised on behalf of the client in relation to specific companies.

Reporting on stewardship and voting activities

The Stewardship Code Disclosure will be reviewed and updated, if necessary, on an annual basis. The Firm will respond appropriately to requests on voting activities, for the reasons explained above, it doesn't have a voting record on which to report.

For further information on the Firm's approach to the Stewardship Code, please contact:
Graeme White,
Chief Operating Officer