UK Stewardship Guide
Tenax Capital Ltd UK
Stewardship Code Disclosure Statement
Under COBS 2.2 of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our 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 should 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 that some of the principles and guidance to be disproportionate. It is of course legitimate for some firms 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 seven principles of the Code are that institutional investors should:
• Publicly disclose their policy on how they will discharge their stewardship responsibilities;
• Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
• Monitor their investee companies;
• Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
• Be willing to act collectively with other investors where appropriate;
• Have a clear policy on voting and disclosure of voting activity; and
• Report periodically on their stewardship and voting activities.
Tenax Capital Ltd Limited (“Firm”) provides discretionary investment management services to the Tenax Financials Fund, the Tenax Financials UCITS Fund, Strategy Portfolios Holdings (Cayman) SPC, which are highly focused fundamentally driven long/short equity funds investing in large and mid-cap financial stocks; and to the Tenax Credit Opportunities Fund a European credit fund with an investment strategy focusing on acquiring discounted loans and bonds to generate equity-like absolute returns on an unlevered basis, with a high degree of downside protection and reduced volatility. The Firm has considered the Code and notes that its principles are not generally applicable to the Firm’s investment activities.
The Firm’s trading and investment strategy is such that we do not typically consider it appropriate to engage with companies and vote on issues that affect the value of a company. For example, the Firm would not engage with a company or vote where:
the percentage of shares controlled and voted by the Firm is a small percentage of the companies’ issued share capital and where the Firm is less likely to have a material influence, and/or
the relevant securities are held on a short to mid-term basis.
We may engage with companies on matters relating to environmental, social or governance (“ESG”) matters where this forms part of our agreed investment strategy. Further information on our approach to ESG can be found in our Responsible Investing Policy.
Where the Firm determines that company engagement or voting is required, the Firm will re-assess its commitment to the Code at that time and make an appropriate disclosure. For further details on any of the above information, please contact Dean Blagden at Blagden@tenaxcapital.com or 020 7003 8700.
Tenax Capital Ltd