UK Stewardship Code Statement

BlueCove Limited – UK Stewardship Code Statement

This statement sets out BlueCove Limited’s (“BlueCove”) approach to the UK Stewardship Code.

The UK’s Financial Reporting Council introduced the Stewardship Code in 2010 (the “Code”) to set a benchmark for institutional investors to meet ownership responsibilities in respect of their equity holdings in UK listed companies.
The Code applies to institutional investors and the firms who manage assets on their behalf.

The Code requires that institutional investors should:

  1. Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  2. Have a publicly disclosed and robust policy on managing conflicts of interest in relation to stewardship;
  3. Monitor their investee companies;
  4. Establish clear guidelines on when and how they will escalate their stewardship activities to protect and enhance shareholder value;
  5. Be willing to act collectively with other investors where appropriate;
  6. Have a clear policy on voting and disclosure of voting activity; and
  7. Report periodically on their stewardship and voting activities.

Compliance with the Code is voluntary. However, under the FCA’s Conduct of Business Rules, all UK asset managers must provide a statement as to whether they commit to it and, if not, why not.

BlueCove is a scientific asset management firm with a primary focus on fixed income instruments. BlueCove takes a quantitative approach to investment decisions based on objective financial models.  The firm would therefore not expect to seek direct engagement with investee companies.  Instances in which BlueCove would manage equity exposures are expected to be primarily investments in ETFs or other collective exposures to the equity market, rather than individual company holdings.  Should individual equity company holdings arise, they may be in the context of hedging equity risk from specific fixed income instruments of the same issuer family.

Due to this specialist investment strategy, the principles of the Code are not relevant or applicable to BlueCove’s business model. Consequently, although BlueCove supports the aims of the Code, it does not formally commit to it.
This statement will be reviewed periodically and updated if necessary.

For further information, please contact the BlueCove Compliance Department at the following address: BlueCove Limited, 10 New Burlington Street, London, W1S 3BE.

February 2019