Rule 2.2.3R of the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (“COBS”) requires an FCA-authorised firm to disclose the nature of its commitment to the Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.

The Code aims to enhance the quality of engagement between institutional investors and companies to assist in improving long-term returns to investors and the efficient exercise of governance responsibilities. It is to be applied by firms on a “comply or explain” basis.

Adherence to the Code is voluntary.

Pygmalion Capital Advisers LLP (“Pygmalion”, the “Firm”) has chosen not to commit to the Code for the following reasons:

• The Firm has chosen an alternative approach to stewardship consistent with its overall approach to ESG, sustainable finance, or responsible investment;
• The Firm provides investment management to a Luxembourg AIFM on a delegated basis and therefore does not engage in stewardship practices distinct from those of the Luxembourg AIFM
• The Firm determines its approach to stewardship on a case-by-case basis, taking into account the best approach to optimising the returns on its investments.

Whilst Pygmalion agrees with the aspirations of the Code and the high standards set out in the Code’s Principles, the Firm considers that the Code’s Principles are not presently applicable to its investment strategies.

Consequently, while Pygmalion generally supports the objectives underlying the Code, the provisions of the Code are not considered to be relevant to the activities currently undertaken by the Firm. If Pygmalion’s activities change in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly. Pygmalion will continue to review this disclosure on at least an annual basis and will monitor the applicability of the Code to the firm and its investment activities from time to time.