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At 4D Infrastructure, Responsible Investment is fully integrated into our investment process and a core component of our investment stewardship.

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook (“COBS”), BennBridge Ltd (“BennBridge” or the "Firm"), to the extent that it is managing investments for a professional client (as defined by the FCA), is required to disclose on its website 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, explain the rationale for this choice based on the Firm’s investment approach.

The Code is a voluntary code aimed at enhancing the quality of engagement by asset managers and owners with corporate issuers and sets out 12 principles relating to how investment and stewardship is integrated, including environmental, social and governance (collectively, “ESG”) issues.

BennBridge, in partnership with its boutiques, provides investment management services to funds which pursue a variety of strategies involving equities on a global basis and with a variety of timeframes. Although, the Code is therefore applicable to some aspects of these strategies, it is not applicable to all, which are typically across a variety of jurisdictions globally. Furthermore, BennBridge recognises the emergence of Stewardship Codes in other jurisdictions and, where appropriate, will apply similar processes outlined within this disclosure to other such Stewardship Codes. BennBridge is the investment manager to the Funds and is regulated by the Financial Conduct Authority (“FCA”), Firm Reference Number 769109.

The UK Stewardship Code sets out, through 12 principles, the best practice in engaging with investee companies which the Financial Reporting Council (“FRC”) believes institutional investors, by which is meant asset owners and asset managers with equity holding in UK listed companies, should use as guidance. The principles can be summarised as follows:

 

Purpose and governance

01. Purpose, strategy and governance

02. Governance, resources and incentives

03. Conflicts of interest

04. Promoting well-functioning markets

05. Review and assurance

Investment approach

06. Client and beneficiary needs

07. Stewardship, investment and ESG integration

08. Monitoring managers and service providers

Engagement

09. Engagement

10. Collaboration

11. Escalation

Rights and responsibilities

12. Exercising rights and responsibilities


Consequently, while BennBridge generally supports the objectives that underlie the Code, the provisions of the Code are not considered to be appropriate to the activities currently undertaken by the Firm. The Firm has therefore chosen not to commit to the Code at this time. If BennBridge’s activities change in such a manner that the provisions of the Code become relevant across its boutiques, the Firm will amend this disclosure accordingly.
 

Shareholder Rights Directive II


Under COBS 2.2B.5R, BennBridge is required to either develop and publicly disclose an engagement policy that meets the requirements of the Shareholder Rights Directive (“SRD II”) or to publicly disclose a clear and reasoned explanation of why it has chosen not to develop an engagement policy that meets the SRD II requirements.

BennBridge has chosen not to develop an engagement policy that complies with the requirements of the SRD II, as the Firm is a multi-boutique investment firm which strategically partners with specialist investment teams which are then hosted within distinct boutiques under BennBridge. As such, BennBridge will support certain non-UK investment strategies where it may not be appropriate to apply an engagement policy.

For further details on any of the above information, please compliance@bennbridge.com.

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