MIFIDPRU 8 Disclosures – 2024

Modern Slavery Statement 2024

*TFG Asset Management UK LLP includes Tetragon Financial Group Limited and its subsidiaries, including TFG Asset Management UK Limited, TFG UK RE Ltd, and TFG Asset Management UK LLP. TFG Asset Management UK LLP is authorised and regulated by the UK Financial Conduct Authority.

FCA COBS Rule 2.2B.3R requires every FCA authorised asset manager that invests in listed equities to:

(1) develop and publicly disclose on its website, a copy of its engagement policy which includes the content specified in the amended EU Shareholder Rights Directive (Directive 2007/36/EC); and

(2) publicly disclose on an annual basis how its engagement policy has been implemented, including a general description of its voting behaviour, an explanation of its most significant votes and details of its use of the services of proxy advisors, or, in either case, to publicly disclose a clear and reasoned explanation of why it has chosen not to comply with those requirements.

TFG Asset Management UK LLP has considered carefully whether it wishes to adopt an engagement policy and to make the disclosures described above and has, for the time being, decided not to do so. The reason that it has made that decision is that TFG Asset Management UK LLP manages assets in accordance with a strategy that involves a wide variety of assets and timeframes. For the portion that is more focussed on equities, the relevant exposure to equities is often obtained through swap positions (particularly in relation to European issuers, which represents TFG Asset Management UK LLP’s main geographical focus). Where equities exposures are held via a swap position, the opportunities for shareholder engagement are more limited, when compared with physical shareholdings (for example, a swap holder is not entitled to vote at general meetings of the issuer). Therefore, while TFG Asset Management UK LLP supports the general principles of shareholder engagement, it does not at this time (for the reasons set out above) consider it appropriate to adopt an engagement policy or make the relevant public disclosures.  TFG Asset Management UK LLP will keep its position under review and will update this section of its website accordingly, if there is a change in its approach.

Under the FCA’s Conduct of Business Sourcebook (“COBS”), COBS 2.2.3R, TFG Asset Management UK LLP is required to include on its website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with the companies or other assets in which they are invested.

TFG Asset Management UK LLP acts as the investment manager to certain private investment funds and other accounts (collectively, the “TFG Asset Management UK Funds”). TFG Asset Management UK LLP’s pursues a multi-strategy investment approach, investing in a variety of jurisdictions globally. While TFG Asset Management UK LLP generally supports the objectives that underlie the Code, it has chosen not to commit to the Code.  TFG Asset Management UK LLP’s approach in relation to engagement with issuers (and members of their management teams) in all of the jurisdictions in which the TFG Asset Management UK Funds invest is determined on a case-by-case basis. Consequently, TFG Asset Management UK LLP does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. TFG Asset Management UK LLP will keep its approach towards the Code under periodic review and if that approach changes it will amend this disclosure accordingly.