UK Financial Reporting Council’s Stewardship Code Disclosure Statement

FCA COBS Rule 2.2.3R requires FCA authorised firms to disclose the nature of their commitment to the UK Financial Reporting Council’s Stewardship Code (the “Stewardship Code”), which was first published by the Financial Reporting Council (“FRC”) in July 2010, and then revised in 2020 and 2026.

The Stewardship Code sets out the principles of effective stewardship by investors. It sets out good practice and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Stewardship Code will be relevant to all signatories and that smaller institutions may judge some of the principles and guidance to be disproportionate. The seven principles of the Stewardship Code, so as to protect and enhance the value that accrues to the ultimate beneficiary, are that institutional investors should:

• Integrate stewardship and investment to deliver long-term sustainable value for their clients and beneficiaries.
• Identify and respond to market-wide and systemic risks to promote well-functioning financial markets.
• Engage to maintain or enhance the value of assets
• Actively exercise their rights and responsibilities.
• Integrate stewardship considerations into their selection and oversight of external managers.
• Monitor and hold to account stewardship service providers.

NPGCUK acts as investment manager to certain private investment funds and managed accounts. Its investment strategy primarily involves credit and credit-related investments and only infrequently involves voting interests in listed companies and interaction with the management of companies listed in the UK. Therefore, while the Firm generally supports the principles of the Stewardship Code, it does not consider it appropriate to conform to the Stewardship Code at this time.