Shareholder Rights Directive

Under Rule 2.2B.5R of the FCA’s Conduct of Business Sourcebook, Symmetry Investments UK LLP (the “Firm”) is required to:

  • develop and publicly disclose on its website, a copy of its engagement policy which includes the content specified in the amended EU Shareholder Rights Directive (Directive 2007/36/EC); and

  • publicly disclose on an annual basis how its engagement policy has been implemented, including a general description of its voting behaviour, an explanation of its most significant votes and details of its use of the services of proxy advisors; or

  • in either case, to publicly disclose a clear and reasoned explanation of why it has chosen not to comply with those requirements.

The Firm’s investment strategy is macro focussed and involves the funds whose assets are managed by the Firm (the “Funds”) holding positions in a variety of asset classes, jurisdictions and timeframes and takes a global approach to engagement.

Where a Fund holds shares with a listing on a UK or EEA market or on a comparable market outside the UK or EEA, the level of shareholder engagement is dependent on a number of factors and is considered on an investment-by-investment basis. Therefore, while the Firm supports the general principles of shareholder engagement, it does not at this time consider it appropriate to adopt an engagement policy or make the relevant public disclosures.

The Firm will keep its position under review and will update this section of its website accordingly, if there is a change in its approach.