Gore Street Investment Management (“GSIM”) is authorised and regulated by the Financial Conduct Authority. As set out in the FCA Handbook, under 2.2.3R requires, GSIM is required to make a public disclosure in relation to the nature of our commitment to the UK Stewardship Code (“Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010. The FRC is the UK’s independent regulator responsible for promoting high quality corporate governance and reporting to encourage investment in UK listed companies.

The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies (including through the asset managers) and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code that institutional investors should follow are:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities
  • Have a publicly disclosed, robust policy on managing conflicts of interest in relation to stewardship
  • Monitor their investee companies
  • Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value
  • Be willing to act collectively with other investors where appropriate
  • Have a clear policy on voting and disclosure of voting activity and
  • Report periodically on their stewardship and voting activities

GSIM’s investment strategy is to invest in energy storage projects. GSIM does not invest in listed companies and whilst the investment strategy may make use of special purpose vehicles as a means of investment, the stewardship code is not applicable to our business model.

Should any material changes occur to the strategies which would make the Code appropriate to GSIM, we will review our commitment to the Code at that time and make appropriate disclosure. For further details please contact [email protected].