PGR Capital

Regulatory Disclosures

PGR Capital LLP ("PGR")

UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook (“COBS”), PGR Capital LLP 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 January 2020.

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 FCA 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.

Whilst PGR supports the principles of the Code, PGR does not currently comply with the Code since it does not 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

PGR does not currently invest on behalf of investors in shares traded on a regulated market. 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 and such instruments fall out of scope of the Shareholder Rights Directive II. Should PGR’s strategies change, PGR will at such time consider whether it is appropriate for the firm to have a shareholder engagement policy.

For queries, please contact the PGR Compliance Officer: compliance@pgrcapital.com

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.