PGR Capital

Regulatory Disclosures

PGR Capital LLP ("PGR")

UK Stewardship Code

Under Rule 2.2.3R of the FSA’s Conduct of Business Sourcebook (“COBS”), PGR Capital LLP (“PGR”) is required to disclose the nature of its commitment to the Stewardship Code (“the Code”), which was updated by the UK Financial Reporting Council (“FRC”) in September 2012.

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. The Code sets out good practice on engagement with investee companies to which the FRC believes institutional investors should aspire and operates on a 'comply or explain' basis. The FSA handbook rules in COBS require UK authorised asset managers to produce a statement of committment to the Code, or where it does not commit to the Code, its alternative investment strategy.

PGR does not currently comply with the Code since it does not currently invest in listed companies in the UK. PGR acts only as an investment manager, with a strategy to invest in exchange-traded futures on stock indices, bonds, interest rates, energies, metals, foreign exchange and agricultural markets. Should PGR’s investment strategy change then PGR will review its commitment to the Code at that time.

Further information on the Code is available from the link below

UK Stewardship Code

Shareholder Rights Directive

In line with the FCA’s recent Policy Statement (PS19/13) and the Shareholder Rights Directive II, PGR Capital LLP is currently considering whether it is appropriate for the firm to have a shareholder engagement policy and will update this statement in due course.

For queries, please contact the PGR Compliance Officer:

PGR Capital LLP is authorised and regulated by the Financial Conduct Authority with number 503401.
PGR Capital LLP is a limited liability partnership registered in England and Wales with registration number OC346820.