Commitment to the UK Stewardship Code and the Shareholder Rights Directive
SHAREHOLDER RIGHTS DIRECTIVE
Under Rule 2.2B of the Financial Conduct Authority's ("FCA") Conduct of Business Sourcebook, Glen Point Capital LLP ("Glen Point" or the "firm") is required to develop and publicly disclose an engagement policy as described in the revised Shareholder Rights Directive (the "SRD II") or provide a clear and reasoned explanation of why it has chosen not to develop and adopt a shareholder engagement policy.
UK STEWARDSHIP CODE
Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Glen Point is required to include on its website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy.
GLEN POINT'S INVESTMENT APPROACH
The firm is an emerging markets focused global macro specialist which manages an emerging markets focused global macro hedge fund strategy and an absolute return emerging markets fixed income strategy. As such, the firm invests in a wide variety of asset classes, principally in fixed income, credit, currency and commodity products on behalf of its clients. The firm also invests in equity asset classes, primarily listed ETFs and futures and options on equity indices, but may also invest from time to time a small portion of its overall assets in single name equity securities as part of its global macro hedge fund strategy. The firm has determined that generally, given the very small position sizes and short holding periods it takes in any single name equity securities, it would be impractical for the firm to have active engagement with company management or participate in the proxy voting process. In addition, the firm believes that the operational cost and time involved in such activities would outweigh any potential benefit to the trading strategies deployed by the firm on behalf of its clients.
APPLICATION TO GLEN POINT
The firm is supportive of the objectives that underlie the Code and the SRD II, however, the firm does not consider it appropriate to adopt a shareholder engagement policy as described by SRD II or to commit to the voluntary Code. The firm has determined that its investment strategies and operational structure, as described above, are incompatible with shareholder engagement activities including voting in proxies.