Stewardship code disclosure

Bluetrain Capital Limited (“The Firm”) is a company registered in England and Wales with company number 15494726. The Firm is authorised and regulated by the Financial Conduct Authority (“FCA” as a Full-scope Alternative Investment Manager (“Full-Scope AIFM”) with Firm Reference Number 1011322.

Under the FCA’s rules set out in the Conduct of Business Sourcebook (“COBS”), the Firm is required to publish a disclosure about the nature of its commitment to the UK Financial Reporting Councils Stewardship Code (Code) or, where it does not commit to the Code, its alternative investment
strategy. The Code applies on a ‘comply or explain’ basis and is voluntary.

The Code aims at enhancing the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.  

The 2020 Code (which took effective from 1 January 2020) sets out 12 Principles for asset managers and asset owners and 6 Principles for service providers relating to engagement by investors with UK equity issuers, as follows:

1. Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients and beneficiaries leading to sustainable Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society. 
2. Signatories’ governance, resources and incentives support stewardship. 
3. Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first. 
4. Signatories identify and respond to market-wide and systemic risks to promote a well-functioning financial system. 
5. Signatories review their policies, assure their processes and assess the effectiveness of their activities. 
6. Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them. 
7. Signatories systematically integrate stewardship and investment, including material
   environmental, social and governance issues and climate change to fulfil their responsibilities.
8. Signatories monitor and hold to account managers and/or service providers. 
9. Signatories engage with issuers to maintain or enhance the value of assets.
10. Signatories, where necessary, participate in collaborative engagement to influence issuers. 
11. Signatories, where necessary, escalate stewardship activities to influence issuers. 
12. Signatories actively exercise their rights and responsibilities.

Whilst supporting the objectives underlying the Code and adhering to the highest standards of corporate governance and due diligence in respect of its investments, the Firm, determines its approach to stewardship on a case by case/ investment by investment basis. As a result, we have not made a formal commitment of compliance to the Code at this time.

Although the Firm has not made an application to become a signatory of the Stewardship Code, the Firm and its staff have a fiduciary duty to act in the best interests of its clients, by following the highest legal, ethical and professional standards in its business, and the Firm is fully aware of the objectives of stewardship as set out in the Code. This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice.  Should the Firm’s position change we will review our commitment to the Code and make an appropriate disclosure at that time.

For further information on the Firm’s approach please contact the Firm’s Compliance Officer, Ian Bickerstaffe at ib@bt-cap.com