Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCAs Conduct of Business Sourcebook (COBS), Whitman Asset Management Limited (the “Company”) are required to disclose the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code 2020 (the “Code”) or where it does not commit to the Code, its alternative strategy.

The Code has 12 principles that signatories to the Code must address:

  1. Their purpose, investment beliefs, strategy and culture to enable stewardship that creates long term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
  2. Governance, resources and incentives available to support stewardship.
  3. How they manage conflicts of interest to put the best interests of clients and beneficiaries first.
  4. Their identification and response to market-wide and systemic risks to promote a well-functioning financial system.
  5. Review their policies, assure their processes and assess the effectiveness of their activities.
  6. Take account of their client and beneficiary needs and communicating their activities and outcomes of their stewardship and investment to them.
  7. How they systematically integrate stewardship and investment, including taking account of material environmental, social and governance issues, and climate change to fulfil their responsibilities.
  8. How they monitor and hold to account managers and/or service providers.
  9. How they engage with issuers to maintain or enhance the value of assets.
  10. Where necessary, how they participate in collaborative engagement to influence issuers.
  11. Where necessary, how they escalate stewardship activities to influence issuers.
  12. How they actively exercise their rights and responsibilities.

The Company acts as discretionary investment adviser to a UK collective investment scheme (a UK UCITS), and individual client accounts. These entities and these accounts all hold long equity positions in their portfolios. The UK UCITS invests in liquid listed UK smaller companies as part of a benchmarked strategy against the IA UK Smaller Companies Sector and the Numis Smaller Companies (NSC) Index Plus Aim (ex-investment companies). The Company aims to vote on these positions in the UK UCITS’ strategy.

The individual client accounts trade in listed stocks. The Company actively monitors and often engages with the management of these companies. Voting on these companies is assessed on the individual merits of each motion based on the accounts’ objectives at the time as well as the Company’s opinion of the situation.

Whilst the Company is supportive of the Code, at the present time it does not consider it necessary to commit to a voluntary code of practice and has, therefore, chosen not to sign up to the Code.

This disclosure document was approved by Whitman Asset Management on 1st November 2022.