Shareholder Engagement policy

Policy Statement

These requirements apply to Gresham House Asset Management Ireland Limited where it invests on behalf of discretionary clients (i.e., Funds it manages) in companies whose shares are traded on regulated markets in the European Economic Area.

Policy Scope Applicability

This policy looks to meet the requirements of Directive (EU) 2017/828 which is designed to encourage shareholder engagement between discretionary clients and investee companies.

Policy Requirement

For our discretionary clients, our service includes the delegation by the client to Gresham House Asset Management Ireland Limited the responsibility for making investment decisions in relation to their respective portfolios. The investment decisions made by Gresham House Asset Management Ireland Limited on the client’s behalf will be informed by that specific client’s financial situation, risk tolerances, sustainability preferences and investment objectives. The client portfolios that Gresham House Asset Management Ireland Limited is responsible for are managed, with the overall objective being to deliver an investment strategy to meet the client’s individual objectives, requirements and risk tolerance.

This policy describes Gresham House Asset Management Ireland Limited’s approach to shareholder engagement where Gresham House Asset Management Ireland Limited decides to invest in companies on behalf of its clients as part of its discretionary investment management services. This Policy does not apply to other investment services that Gresham House Asset Management Ireland Limited may provide, such as providing investment advice.

This Policy only applies to the specific holdings in companies over which Gresham House Asset Management Ireland Limited has discretionary investment management responsibility and control.

Where there is a discretionary client relationship, Gresham House Asset Management Ireland Limited seeks to integrate relevant engagement procedures for the size and scale of Gresham House Asset Management Ireland Limited’s activities into our investment process. Gresham House Asset Management Ireland Limited understands that the long-term success of investee companies is supported by effective investor stewardship, high standards of corporate governance and transparent engagement policies. The Investment Committee undertakes a fundamental investment research process at the outset and throughout with the aim to develop a deep understanding of investee companies’ strategy, financial/non-financial risk, capital structure, social and environmental impact, and corporate governance.

The initial decision to add a company to the Gresham House Asset Management Ireland Limited core list is likely to include reviewing a company’s published materials, third party brokers’ written research, conversations with third party analysts and where possible meetings with company management. The review that takes place at the start of the investment process forms the basis on which Gresham House Asset Management Ireland Limited builds its stewardship activities. As part of Investment Committee oversight Gresham House Asset Management Ireland Limited looks to fully understand the investments, their opportunities, and associated risks. On an ongoing basis, the Investment Team would seek opportunities to meet/engage with all these parties on relevant matters relating to the management and governance of the company, as appropriate.

Gresham House Asset Management Ireland Limited is not yet of the size and scale of activities to begin engaging directly with investee companies management/board and Gresham House Asset Management Ireland Limited does not collaborate with other shareholder groups in this regard.

As a regulated entity, Gresham House Asset Management Ireland Limited is required to identify, manage and disclose conflicts of interest that may arise in the context of providing services to our clients, as well as to establish appropriate criteria for determining the types of conflicts of interest whose existence may give rise to a material risk of damage to the interests of a client, taking appropriate action, including in some cases not proceeding with the activity. We therefore have a separate Conflicts of Interest Policy in place to manage this. A summary of this policy is available on the Gresham House Asset Management Ireland Limited website.

The Investment team are responsible for compliance with engagement. The below section outlines the relevant obligations:

• integrate shareholder engagement in its investment strategy;
• monitor investee companies on relevant matters, including:
  • strategy;
  • financial and non-financial performance and risk;
  • capital structure; and
  • social and environmental impact and corporate governance;
• conduct dialogues with investee companies;
• exercise voting rights and other rights attached to shares;
• cooperate with other shareholders;
• communicate with relevant stakeholders of the investee companies; and
• manage actual and potential conflicts of interests in relation to the Firm’s engagement

The investment team may engage the independent proxy voting services of a service provider to assist with voting research, voting recommendations, vote execution, recordkeeping, and reporting. When engaging a service provider, it must be ensured that all proxies are voted in accordance with the proxy voting policy published by Gresham House Asset Management Ireland Limited.

Summary of Gresham House Asset Management Ireland Limited’s Voting Behaviour for 1 January 2023 through 31 December 2023

Disclosure on how the Firm has cast votes (excluding votes for insignificant subject matters) in the general meetings of companies in which it holds shares- including shareholdings in non-EEA companies (excluding insignificant holding sizes):

For further voting information in respect of a particular investee company please contact your usual Gresham House Asset Management Ireland Limited contact.