The UK Stewardship Code 2020 (the “Code”) is a part of UK company law and issued by the Financial Reporting Council (“FRC”). It sets high stewardship standards for asset owners and asset managers, and for service providers that support them.
The Code does not prescribe a single approach to effective stewardship. Instead, it outlines a set of ‘apply and explain’ Principles. This allows firms to meet the expectations in a manner that is aligned with their own business model and strategy. The Code is aimed mainly at equity holdings in UK-listed companies.
The application of the Code by Vitruvian Partners LLP (the “Firm”) is voluntary, notwithstanding and pursuant to the FCA Handbook (COBS 2.2.3R), the Firm is required to disclose the nature of its commitment to the Code or, where it does not commit to the Code, its alternative investment strategy.
The Firm’s main business activity is to act as investment manager to alternative investment funds (“AIFs”), which invest primarily in private markets and have an alternative investment strategy. From time to time, the AIFs may invest in or become the owner of listed securities, however, these do not form a material part of their assets under management.
Whilst the Firm is supportive of its objectives, it has not become a signatory of the Code due to the very nature of the AIFs investment strategy, which renders the application of the Code incompatible with the goals envisaged by the FRC.
In event of a change in the investment activities or strategies managed by the Firm, the relevance of the application of the Code will be revisited and this disclosure updated accordingly.