Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Emerging Markets Investment Management Limited, Duet Private Equity Limited and Duet Alternative Investments (UK) Limited (together the Duet Group or the “Group”) are required to disclose a statement about the nature of their commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where they does not commit to the Code, explain their alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance. The Group on behalf of its fund clients, seeks global investment opportunities pursuant to a variety of investment strategies. Investments may be made in a variety of asset classes and in a variety of jurisdictions globally, including UK equities. The Code may therefore be relevant to some aspects of the Group’s trading.
Depending on the investment strategy, security or instrument type, corporate governance can be an important factor to take into account in the investment process. The Group’s general policy is to exercise its underlying clients’ rights as a shareholder in a manner that serves the best interests of its clients, as determined by the Group in its discretion, taking into account relevant factors, including, but not limited to, the impact on the value of the securities and the anticipated costs and benefits associated with any proposal to be put to a vote. The Group takes a global approach to investing and, while the Group generally supports the objectives that underlie the Code, the Group does not consider it appropriate to commit to a particular voluntary code of practice relating to a specific jurisdiction.