- Fiduciary Management
The Pillar 3 and Remuneration disclosures are set out in the accounts of SECOR Investment Advisors (UK), LLP and are available from here.
The FCA’s Conduct of Business Sourcebook rule 2.2.3R, requires SECOR Investment Advisors (UK) LLP (‘SIA UK’), as an Investment Manager, to include a disclosure on its website stating the nature of its commitment to the UK Stewardship Code (“the Code”) issued by the Financial Reporting Council. If SIA UK does not commit to the Code, it must state in general terms its alternative investment strategy. The Code sets out various principles relating to the level of engagement by investors with UK equity investments.
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.
SECOR Asset Management LP (‘SECOR AM’), SIA UK’s Parent, is a global asset management firm providing innovative investment advisory, portfolio and strategic risk management, and alternative investment solutions for its clients. As SECOR AM’s strategy does not envisage SIA UK directly investing in UK equities, the Code is not applicable to SIA UK’s trading policies. Accordingly, whilst SIA UK supports the Code’s objectives, SIA UK has decided not to commit to the principles of the code.
SECOR AM’s policy in engaging with issuers and their management is determined on a global basis. Thereby SECOR AM takes a consistent approach to engaging with the issuers and their management in all the jurisdictions it invests in. Hence, it is not deemed appropriate to comply with any voluntary codes of practice in any individual jurisdictions. Should any of the above factors change, we will review our position in relation to the Code at that time and make appropriate disclosure.
SECOR Investment Advisors (UK), LLP (an affiliate of SECOR Asset Management, LP) is authorised and regulated by the Financial Conduct Authority (FCA firm reference number 544237).