Conduct of Business Sourcebook rule 2.2.3R requires Working Capital Advisors (UK) Ltd. (“the Firm”) to
include disclosure on its website stating the nature of its commitment to the UK Financial Reporting
Council (“FRC”)'s Stewardship Code (the "Code") or, where it does not commit to the Code, its
alternative investment strategy.
The Code was first published by the FRC in July 2010 and has been periodically updated several times
since. The latest version, the UK Stewardship Code 2026 (“2026 Code”), took effect from 1 January 2026.
Its purpose is to establish the core Principles of effective stewardship and to set a high standard of
transparency for asset owners, asset managers, and for the service providers that support them
The 2026 Code consists of 6 Principles for asset owners and managers, and 4 Principles for service
providers. Signatories are required to provide a Policy and Context Disclosure (every 4 years) and an
Activities and Outcomes Report every year.
The Principles for asset owners and managers are as follows:
1. Signatories integrate stewardship and investment to deliver long-term sustainable value for
their clients and beneficiaries.
2. Signatories identify and respond to market-wide and systemic risks to promote well-functioning
financial markets.
3. Signatories engage to maintain or enhance the value of assets.
4. Signatories actively exercise their rights and responsibilities.
5. Signatories integrate stewardship considerations into their selection and oversight of external
managers.
6. Signatories monitor and hold to account stewardship service providers.
Compliance with the Code is voluntary but where investors choose not to comply with one or more of
the Principles, they must publish on their websites statements justifying their non-compliance and
setting out their alternative investment strategy.
Although the Firm generally supports the principles of the Code, it has decided that it would not be
appropriate to commit to it. The Firm provides investment management services to Cayman Island
domiciled funds, investing in long/short equities and equity-like instruments globally, including the UK.
It must, therefore, apply a consistent global approach when engaging with issuers and their
management in all the jurisdictions in which it invests. It would not be appropriate for it to commit to a
voluntary code of practice that applies to a specific jurisdiction.
For further information on the Firm’s investment and governance approach, please contact the Firm’s
Compliance Officer at partnerservices@working-cap.com.