Gore Street does not comply with the requirements of the Shareholder Rights Directive (“SRD II”), as it
considers that it has an investment strategy that is not commensurate with outcomes sought thereunder.
Moreover, the Firm ensures that its clients are regularly and routinely apprised of the investment
strategies employed by Gore Street. As such, it is felt the clients would not expect the Firm to achieve
compliance with the core requirements of the SRD II.
Gore Street is predominantly a private equity focused investment manager, and therefore, while the
Firm may from time-to-time hold listed equity as a result of debt for equity swaps, such equity holdings
are de-minimis and not material for our clients.
Engagement Policy Disclosure
Gore Street has published a disclosure on the Firm’s website, explaining why it does not comply with
the requirements of SRD II.
Annual Update and Disclosure
This policy and the related disclosure are reviewed on at least an annual basis and presented to the
Management Body. As part of this review, Gore Street will update its annual disclosure to include
consideration of the following:
• A general description of voting behavior;
• An explanation of how it has cast significant votes, including how it has cast votes in the general
meetings of companies in which it holds shares; and
• Reporting on the use of the services of proxy advisors.
The annual disclosure, when applicable, will be made on an annual basis. The annual disclosure
template can be found in Appendix 8A.
Shareholder Engagement and Proxy Voting
The Firm monitors and records the way in which it has engaged with investee companies, including
with regard to, and in accordance with, proxy voting policy and procedure as outlined in Appendix 8.
Gore Street maintains a record of votes exercised and periodically, and on at least an annual basis:
• Review the Firm’s voting record and confirm that a random sample of proxy questions were
voted according to the approved policy; and
• Review any material conflicts that have been documented and determine independently
whether the conflict was resolved in favour of the client’s interests.
Gore Street is not required to disclose votes that are insignificant due to the subject matter of the vote
or the size of the holding in the company. The Firm will consider the significance of each vote on an
ongoing basis and in accordance with its proxy voting policy (as outlined below).
SRD Institutional Investors
When necessary, Gore Street will comply with the disclosure requirements of SRD II with respect to
separately managed accounts of SRD institutional investors and/or, with respect to any such investors
in funds to which it is the AIFM by making such information publicly available on its website. Such
disclosures will be provided and updated on at least an annual basis.
The Firm will also provide this information where requested to by other (non-client) SRD investors when
the Firm is required to do so.