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.
EU Sustainable Finance Disclosure Regulation
This summary sets out the policies of CIFC Asset Management LLC and CIFC Asset Management Europe Ltd (together, “CIFC” or the “Firm”), on the integration of sustainability in our investment decision-making process.
The Firm has implemented a Sustainability Risks Policy (the “Policy”), which sets out the Firm’s policies in respect of the integration of sustainability risks in its investment decision-making process, as required by the Sustainable Finance Disclosure Regulation (“SFDR”). This summary provides a summary description of the key features of the Policy, for the purposes of disclosure on CIFC’s website and/or in the pre-contractual disclosures for financial products, where applicable.
Under SFDR, “sustainability risk” means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment. The Policy therefore approaches sustainability risk from the perspective of the risk that ESG events might cause a material negative impact on the value of its clients’ investments.
CIFC is a signatory and advocate of the United Nations Supported Principles for Responsible Investment (“PRI”). For reference, the Firm maintains other policies and documentation related to sustainability, including the CIFC Asset Management Corporate Social Responsibility Policy available at www.cifc.com. Also, for additional information on PRI please see: http://www.unpri.org/pri/about-the-pri.
With respect to sustainability risks, the Policy explains that, as part of CIFC’s broader risk management processes, certain procedures are intended to be implemented to identify, measure, manage, and monitor sustainability risks. These processes include, but are not limited to: (i) the review of sustainability risks that are potentially likely to cause a material negative impact on the value of our clients’ investments, should such risks occur; (ii) the measurement of such risks by considering the likelihood of events contemplated by certain risks occurring and the potential severity of impact to the value of the Firm’s clients’ investments should events contemplated by such risks occur; (iii) the holistic integration of sustainability risks into overall risk management processes and the recognition that sustainability risks are, as a group, one of many potential risks that may, depending on the specific investment opportunity, be relevant to a determination of risk; and (iv) the periodic monitoring of existing client portfolios and taking corrective action where necessary and appropriate.
This summary is provided for information purposes only. In the event of any inconsistency between this summary and either (i) the Policy, or (ii) the terms of any agreement between the Firm and any of its clients, such other document shall prevail. No person should take (or refrain from taking) any action as a result of this summary. To the maximum extent permitted by law, no liability is accepted by the Firm in respect of this summary.
No consideration of sustainability adverse impacts. The Firm has carefully evaluated the requirements of the PAI regime in Article 4 SFDR, and in the draft Regulatory Technical Standards which were published in February 2021 (the “PAI regime”).
The Firm is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market, as to how financial market participants integrate consideration of the adverse impacts of their investment decisions on sustainability factors. However, taking account of the Firm’s size, the nature and scale of our activities and the types of products we make available, we consider that it would be disproportionate to comply with the specific regime in the SFDR. In addition, the Firm notes certain of our products involve portfolio management strategies where it is not possible to conduct detailed diligence on the PAIs of our investments on sustainability factors.
Finally, the Firm is also concerned about the lack of reasonably priced / readily available data to comply with many of the technical reporting requirements of the PAI regime, as we believe that issuers and market data providers are not yet ready to make available all necessary data for the PAI regime.
The Firm will keep its decision not to comply with the PAI regime under regular review, and will formally re-evaluate the decision periodically.