Shareholder Rights Directive (SRD) II
Under Rule 2.2B.5 of the Financial Conduct Authority's ("FCA") Conduct of Business Sourcebook and the Second Shareholders Rights Directive ("SRD"), and given that Doxa Partners LLP ("Doxa") invests in liquid equities, we are required to make publicly available our policies on how we engage with other shareholders and the companies that we invest in, and how our strategies create long-term value.
The SRD aims to promote effective stewardship and long term investment decision making, including transparency across the investment community. The SRD applies to listed equities globally, unlike the Stewardship Code (the "Code") which focuses on investments in UK companies only. Doxa's response to the Code is detailed in a separate statement, available here.
As a multi-strategy investment manager, Doxa has elected to publicly disclose its Engagement Policy with sole respect to the listed equities component as set out below. This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should Doxa's position change, we will review our commitment to SRD and make appropriate disclosure at that time.
Engagement Policy
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An appropriate level of engagement is an important part of our role as an investment manager
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This will depend on the size of our holding in a particular company and whether it is appropriate for the investment strategy
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This could involve speaking to company IR or management or taking part in Proxy Voting (explained in our Proxy Voting Policy)
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We do not operate an activist strategy but on occasion we may communicate and act with other shareholders
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We have a documented Conflict of Interest Policy available to clients