UK Stewardship Code

Gore Street Capital Limited(“GSC”) is authorised and regulated by the Financial Conduct Authority. As set
out in the FCA Handbook, under 2.2.3R requires, GSC is required to make a public disclosure in relation to
the nature of our commitment to the UK Stewardship Code (“Code”), which was published by the Financial
Reporting Council (‘FRC’) in July 2010. The FRC is the UK’s independent regulator responsible for
promoting high quality corporate governance and reporting to encourage investment in UK listed companies.


The Code aims to enhance the quality of engagement between institutional investors and companies to help
improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets
out good practice on engagement with investee companies (including through the asset managers) and is to
be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will
be relevant to all institutional investors and that smaller institutions may judge some of the principles and
guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with
companies, depending on their investment strategy, and in such cases firms are required to explain why it is
not appropriate to comply with a particular principle.


The seven principles of the Code that institutional investors should follow are:


• Publicly disclose their policy on how they will discharge their stewardship responsibilities
• Have a publicly disclosed, robust policy on managing conflicts of interest in relation to stewardship
• Monitor their investee companies
• Establish clear guidelines on when and how they will escalate their activities as a method of protecting and
enhancing shareholder value
• Be willing to act collectively with other investors where appropriate
• Have a clear policy on voting and disclosure of voting activity and
• Report periodically on their stewardship and voting activities


GSC pursues a strategy that involves investing in unlisted European and UK companies. While the firm
supports the objectives that are underlying to the Code, it is therefore not appropriate to the business model
of GSC. However, in practice GSC will be broadly following the courses of action arising from the principles
(when relevant), as set out in the Code. GSC determines its approach to stewardship on a case by case basis,
taking into account our duties to the funds that we manage, the nature of the company (in which the funds
are invested) and the actions that will lead to the most favourable outcome for the value of our investments.
Furthermore, the firm takes a consistent approach to engagement with companies in which the funds invest,
in all of the relevant jurisdictions. GSC has therefore determined that it does not consider it appropriate to
commit to any particular code relating to any individual jurisdiction.
Should any material changes occur to the strategies which would make the Code appropriate to GSC, we
will review our commitment to the Code at that time and make appropriate disclosure. For further details on
any of the above information, please contact GSC