CIFC Asset Management Europe Ltd (“CIFC UK”) is authorised and regulated by the Financial Conduct Authority.
UK Stewardship Code
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, CIFC UK is required to disclose in an accessible form a statement 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. 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.
CIFC UK pursues a multi-strategy approach to investing and invests in a variety of asset classes and in a variety of jurisdictions globally, with a principal focus on credit markets. While CIFC UK generally supports the objectives that underlie the Code and has adopted a group-wide ESG policy, CIFC UK has chosen not to commit to the Code. CIFC UK’s policies in relation to engagement with issuers and their management are determined globally on a group-wide basis. The group takes a global approach to engagement with issuers and their management in all of the jurisdictions in which it trades and, consequently, CIFC UK does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. CIFC UK will keep its approach towards the Code under periodic review and if that approach changes it will amend this disclosure accordingly.
Shareholder Rights Directive
Under Rule 2.2B.3R of the FCA’s Conduct of Business Sourcebook, CIFC UK is required 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) (“SRD II”); 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.
As noted in the UK Stewardship Code section, CIFC UK pursues a multi-strategy approach to investing and invests in a variety of asset classes and in a variety of jurisdictions globally, with a principal focus on credit markets. Consequently, it is relatively rare for the assets which CIFC UK manages to include equities with a listing on an EEA market or on a comparable market outside the EEA. For that reason, while CIFC UK supports the general principles of engagement with issuers and has adopted a group-wide ESG policy, it does not at this time consider it appropriate to adopt an engagement policy or make the relevant public disclosures under SRD II. CIFC UK will keep its position under review and will update this section of its website accordingly, if there is a change in its approach.
Modern Slavery Act
CIFC UK is not subject to the Modern Slavery Act but is supportive of its aims.