Northlander Commodity Advisors LLP - SRD II Disclosure
Shareholder Rights Directive II (“SRD II”) came into effect on 10 June 2019, promoting effective stewardship and long-term investment decision making, in respect of shares traded on EEA regulated markets and comparable regulated markets outside the EEA.
The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:
• Publish their shareholder engagement policy (or explain why they don't have one) – COBS 2.2B.5R.
• Make annual public disclosures relating to the implementation of their shareholder engagement policy, from 10 June 2020 – COBS 2.2B.5R.
• Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R.
Northlander does not manage investments in shares traded on an EEA regulated market, or on a comparable regulated market outside the EEA, and so the SRD II rules do not apply to it. We have therefore not developed a shareholder engagement policy and nor are we required to make the disclosures outlined above.
If the Firm's investment strategy changes in such a manner that the provisions of SRD II become relevant, the Firm may amend this disclosure accordingly.