Disclaimer

Target Audience

This website is intended for use only by investors who are resident in the UK and by financial advisers only. In particular, this website is not for use by residents of the United States of America, or other US persons (as defined in the Securities Act 1933).

Information

Information on this site has been obtained from sources which we believe to be accurate but cannot be guaranteed. Whilst all reasonable care has been taken to ensure the facts stated and any opinions expressed are fair, no member (staff or Account Executive) of the Walker Crips group (the Group) shall in any way be responsible for the site contents. Prices are factual details and are deemed to be correct at the time of publication but may change subsequently.

Fluctuations in the rate of exchange may have an adverse effect on the value, price or income of non-sterling denominated investments. Walker Crips Group plc, its associates, employees and/or clients may own or have a position in securities referred to on this website or may have provided advice or investment services in relation to any such security.

Nothing on this website is intended to exclude or restrict any duty or liability which the authorised and regulated subsidiaries of the Walker Crips Group plc may have under the Financial Services and Markets Act 2000 (or any replacement legislation) or the rules and regulations for the conduct of business made thereunder.

For the purposes of the Financial Services and Markets Act 2000 this website has been approved by Walker Crips Investment Management Limited which is authorised & regulated by the Financial Conduct Authority.

External Links

This site may contain links to and from third parties. We do not accept any responsibility for information contained within such third party sites. The information and services offered within these third party sites have been produced by companies independent of the Group. These companies may not be authorised nor regulated by the FCA. Any information, views or opinions obtained from these sites, via links from the Walker Crips website, are solely those of the relevant provider and not necessarily shared by the Group. Reference to or any reliance on, information provided by external websites shall be entirely at your own risk.

Non-offer, Non-Recommendation

This website is solely for the provision of information and does not constitute an offer to buy nor to sell any stock, share or any other product mentioned herein. No advice is given nor implied. This website serves only to help clients (or prospective clients) to make their own investment decisions. Accordingly, it may not be suitable for all users and does not constitute a personal recommendation to invest.

You should seek your own professional advice as to the suitability of any such investment or service before you enter into any transaction.

Past Performance

Past performance is not necessarily a guide to future performance. The value of investments and the income from them can fall as well as rise and investors may get back less than they originally invested. In the case of higher volatility investments, these may be subject to large or sudden falls in value. All estimates and prospective figures are forecasts and cannot be guaranteed. Price forecasts are not guaranteed. If you have any doubts as to the suitability of this service you should seek advice from your personal investment adviser.

Taxation Matters

Matters relating to levels and basis of tax relief are based on our current understanding of current tax legislation. Walker Crips are not specialist tax advisers and you should seek specialist advice regarding your personal tax situation and the consequences any investment decisions may have on your personal circumstances.

Regulatory Information

Walker Crips Group plc (Registered in England. Registered number: 1432059 Registered Office: Old Change House, 128 Queen Victoria Street, London, EC4V 4BJ) incorporates the following companies.

Walker Crips Investment Management Limited. Registered in England. Registered Number: 4774117. Registered Office: Old Change House, 128 Queen Victoria Street, London, EC4V 4BJ. Authorised and regulated by the Financial Conduct Authority. Member of the London Stock Exchange. FCA number: 226344

Walker Crips Wealth Management Limited. Registered in England. Registered Number: 3790291. Registered Office: Apollo House, Eboracum Way, York, YO31 7RE. Authorised and regulated by the Financial Conduct Authority. FCA number: 114778

Walker Crips Pensions is a trading name of Ebor Trustees Limited. Ebor Trustees Limited is registered in England. Registered Number: 351426. Registered Office: Apollo House, Eboracum Way, York, YO31 7RE. Authorised and regulated by the Financial Conduct Authority. FCA number: 462002

Walker Crips Structured Investments, Walker Crips Alternative Investments and Walker Crips Investment Management are trading names of Walker Crips Investment Management Limited.

Stewardship code – Disclosure Statement

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook regulated firms that manage investments for institutional clients are required to disclose by a statement on their website the nature of their commitment to The Stewardship Code ("the Code").

The Code, which has been published by the Financial Reporting Council, sets out principles for institutional investors in relation to their engagement with the companies in which they have invested. The FCA's regulations oblige any firm subject to the rules to publicly disclose the nature of its commitment to the Code, or where it does not commit to the Code, its alternative approach.

Walker Crips Investment Management’s investment strategy is, in general, such that the firm does not consider it to be appropriate for it to engage directly with companies in which it invests or to actively vote on resolutions at meetings of shareholders. The basis on which the firm manages investments for institutional clients is such that engagement would not be beneficial for those clients and the firm does not consider that engagement with management is expected by our institutional clients.

Shareholder Rights Directive II

The updated European Shareholder Rights Directive II (“SRD II”), which has been implemented into domestic law in the United Kingdom, became effective as of 10 June 2019. The SRD II imposes transparency obligations on institutional investors (such as insurers and pension funds) and asset managers (such as investment firms providing discretionary portfolio management services) to the extent investments are made in shares traded on a regulated market.

Neither Walker Crips Wealth Management Ltd nor Ebor Trustees Ltd provide discretionary portfolio management services and therefore the requirements of SRD II do not apply to these firms.

Walker Crips Investment Management Limited (WCIM) is committed to implementing the requirements of the SRD II, which aims to encourage long-term shareholder engagement.

Engagement Policy & Disclosure Requirements

WCIM is in process of developing the Engagement Policy and will make it available in due course.

Engagement Policy

Under the SDR II, WCIM is required to disclose a shareholder engagement policy or provide a clear and detailed explanation of why we are not. The policy must provide information on how we:

1. Integrate shareholder engagement in our investment strategy;

2. Monitor investee companies on relevant matters, including:

(a) strategy;

(b) financial and non-financial performance and risk;

(c) capital structure; and

(d) social and environmental impact and corporate governance;

3. Conduct dialogues with investee companies;

4. Exercise voting and any other shareholder rights;

5. Cooperate with other shareholders;

6. Communicate with relevant stakeholders;

7. Manage actual and potential conflicts of interests in our engagement.

Annual Disclosures

As part of the SRD II’s disclosure requirements, WCIM is obliged to report annually on the following:

  • The engagement policy’s implementation;

  • A general description of voting behaviour;

  • An explanation of the most significant votes;

  • The use of proxy advisors;

  • How it has cast votes in the general meetings of companies in which it holds shares unless these votes are considered insignificant due to the subject matter of the vote or the size of the holding in the company.

Annual Disclosures to institutional investors

WCIM is required to provide the following annual disclosures to SRD institutional investors when it

invests on a discretionary basis or through a fund:

  • How the investment strategy and its implementation comply with the mandate in place; and

  • How it contributes to the medium to long-term performance of the institutional client’s assets

The disclosure must include reporting on:

  • The key material medium to long-term risks associated with the investments;

  • Portfolio composition;

  • Turnover and turnover costs;

  • The use of proxy advisors for the purpose of engagement activities;

  • Our policy on securities lending and how that policy is applied to support the firm’s engagement activities if applicable, particularly at the time of the general meeting of the investee companies;

  • Whether and how we make investment decisions based on evaluation of medium to longterm performance of an investee company, including non-financial performance; and

  • Whether conflicts of interests have arisen in connection with engagement activities and how we have dealt with these conflicts.

The use of proxy advisors

WCIM does not use a proxy voting adviser

Portfolio turnover and turnover costs

As required by the SRD II annual disclosure requirement, information on portfolio turnover will be included in the annual client report. Portfolio composition and turnover costs already form part of the client reporting and we will continue to provide them on a quarterly basis.

Investors should be aware that past performance is not a reliable indicator of future results and that the price of shares and other investments, may fall as well as rise and the amount realised may be less than the original sum invested.


Walker Crips Group plc (Old Change House, 128 Queen Victoria Street, London EC4V 4BJ), registered in England, registered number 1432059, incorporates the following companies which are authorised and regulated by the Financial Conduct Authority: Walker Crips Investment Management Limited registered in England number 4774117 member of the London Stock Exchange, Walker Crips Wealth Management Limited registered in England number 3790291, Ebor Trustees Limited registered in England number 3514268, Barker Poland Asset Management LLP registered in England and Wales number OC341149.