Regulatory

UK Stewardship Code & EU Shareholder Rights Directive

Under COBS 2.2A.5R of the FCA Handbook, SPX International Asset Management Ltd. (“SPX UK”) is required to disclose the nature of its commitment to the Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code sets out a number of principles relating to engagement by investors in UK-listed companies, and commitment to the Code is voluntary.

SPX UK invests in a variety of asset classes across a range of jurisdictions globally. While SPX UK generally supports the objectives that underlie the Code, the nature of its investment strategy is considered to be incompatible with shareholder engagement activities including voting in proxies. SPX UK has therefore chosen not to commit to the Code at this time. Should SPX UK’s activities change such that the Code becomes relevant, SPX UK will amend this disclosure as appropriate.

SPX UK is currently considering whether it will adopt an engagement policy pursuant to Article 3g of the amended EU Shareholder Rights Directive (Directive 2007/36/EC). When that decision has been made, this webpage will be updated accordingly.

Section 172(1) Statement

This statement describes how the directors of SPX International Asset Management Ltd. (the “Company”) have had regard to the matters set out in subsection (1) (a) to (f) of section 172 (“Duty to promote the success of the company”) of the Companies Act 2006, during the most recent completed financial year.

The directors meet regularly to make operational and strategic decisions – such as those around investment management, product governance and outsourcing – and to review their likely long-term consequences. The directors also pay due consideration to the interests of the Company’s stakeholders, including taking due steps to: maintain a workforce that is diverse, motivated and fit and proper; pay suppliers on time; and treat customers fairly.

More broadly, the directors are committed to ensuring that the Company has a positive impact on the community and the environment by, for example, promoting initiatives that support charitable causes or the reduction of the Company’s plastic waste or carbon footprint.

In implementing the above measures, the directors are acutely conscious of their responsibilities as stewards of the Company’s reputation. To this end, they also insist upon the highest standards of business conduct as a rule in all the Company’s dealings.

The directors’ approach in all the matters described in this statement is driven by applicable FCA requirements and guidance and (where more stringent) industry best practice.

MiFID Complaints

SPX International Asset Management Ltd. (“SPX UK”) handles any complaints about its provision of investment services to its clients under the EU Markets in Financial Instruments Directive (“MiFID Complaints”) in accordance with its Complaints Management Policy. This provides that, in summary, SPX UK will duly consider and escalate MiFID Complaints as appropriate, reply to the MiFID Complaint without undue delay, and inform the complainant about SPX UK’s position on the MiFID Complaint and the complainant’s options for redress. MiFID Complaints can be submitted to SPX UK’s Compliance team at compliance.uk@spxcapital.com.

MIFIDPRU 8 DISCLOSURE

ABOUT SPX UK

SPX International Asset Management Ltd. (“SPX UK”) is a company registered in England and Wales with company number 09799467, registered office at 130 Jermyn Street, London SW1Y 4UR, United Kingdom, and main trading address at 1 New Burlington Place, London W1S 2HR, United Kingdom. Its contact e-mail address is compliance@spxuk.com. SPX UK is authorised and regulated by the UK Financial Conduct Authority with firm reference number 737180. VAT number 242 4324 37.

Modern Slavery Act: Slavery and Human Trafficking Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement (“Statement”) of SPX International Asset Management Ltd. (“SPX UK”) for the financial year ending 31 December 2023.

Organisational Structure

SPX UK is a privately-owned limited company incorporated in England and Wales and authorised by the Financial Conduct Authority (“FCA”) to conduct investment management business.

Approach to Modern Slavery

SPX UK does not tolerate slavery, servitude, forced labour or human trafficking (“Modern Slavery”) and strives to ensure that our business is untainted by Modern Slavery.

As an FCA-authorised investment manager, SPX UK maintains relevant policies and procedures that support this philosophy, including a Code of Ethics and Conduct, Service Providers Due Diligence and Engagement Policy, and Whistleblowing Policy.

Supply Chain

SPX UK has a relatively short supply chain that focuses on professional services (e.g., financial data provision) as opposed to physical goods production/distribution. Accordingly, we consider that our supply chain is inherently not materially susceptible to Modern Slavery.

We acknowledge, however, that Modern Slavery can take place in any supply chain and in any sector. To address this risk, we exercise appropriate vigilance and oversight with our ancillary contractors (e.g., cleaners) as well as core service providers.

Approval

This statement has been approved by the board of directors of SPX UK and signed by Daniel Schneider.

Last updated 03/01/2024