UK STEWARDSHIP CODE

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This statement outlines the Frank Investments’ (the “Firm”) position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in September 2012.

The Code aims to enhance the quality of engagement between investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “comply or explain” basis. It also describes steps that asset owners can take to protect and enhance the value that accrues to the ultimate beneficiary.

The FRC recognises that not all parts of the Code will be relevant to all investors and that smaller asset managers may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy.

The seven principles of the Code provide that, so as to protect and enhance the value that accrues to the ultimate beneficiary, institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  • Have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed;
  • Monitor their investee companies;
  • Establish clear guidelines on when and how they will escalate their stewardship activities;
  • Be willing to act collectively with other investors where appropriate;
  • Have a clear policy on voting and disclosure of voting activity; and
  • Report periodically on their stewardship and voting activities.

The Firm’s Position on the Code

The Firm recognises the values and aims of the Code and is generally supportive of good stewardship as contained within the Code. As such, in practice, the Firm would take into consideration the principles as set out in the Code. However, the firm has not made a formal commitment of compliance with the Code.

The Firm provides discretionary portfolio management services to retail and professional clients, as well as private equity management of funds. For discretionary portfolio management, the Firm does not regularly exercise voting rights on behalf of Investors but does actively monitor and engage with the management of its investee companies. Voting requests are assessed on their individual merits and in light of the relevant portfolio’s objectives at that time as well as the investment manager’s opinion of the situation, whilst always acting in the best interest of the Investor. The Firm takes an active role to vote in investments in private equity fund management. The Firm’s voting policy is not prescribed, and the Firm does not report on its stewardship or voting activities.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time.

For further details on any of the above information please contact the Firm’s Compliance Officer Amy Grovit.

SHAREHOLDER RIGHTS DIRECTIVE II DISCLOSURE

The EU Directive (EU) 2017/828 (“SRD II”) was implemented in the UK on 10 June 2019. The objective of SRD II is to encourage long-term shareholder engagement with investee companies regarding performance on strategy, governance, environmental and social issues.

We are required to develop and publicly disclose an engagement policy which complies with the requirements set out in the FCA’s Conduct of Business Sourcebook and publicly disclose on an annual basis how that engagement policy has been implemented in a way that meets the requirements (including disclosure of certain voting activities in respect of shares in investee companies) or to publish a clear and reasoned explanation of why we have chosen not to comply with any such requirements. The engagement policy must describe how Frank Investments:

  • Integrates shareholder engagement in its investment strategies;
  • Monitors investee companies on relevant matters (e.g. strategy, financial, non-financial performance and risk, capital structure, social and environmental impact and corporate governance);
  • Conducts dialogues with investee companies;
  • Exercises voting and any other shareholder rights;
  • Cooperates with other shareholders;
  • Communicates with relevant stakeholders of investee companies;
  • Manages actual and potential conflicts of interests in relation to Frank Investment’s engagement.

Frank Investments has considered the engagement policy and concluded that it does not require an engagement policy at the moment because it does not manage funds for institutional investors that deal in UK and EU listed securities.

Annual MIFIDPRU Disclosures

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Frank Investments Complaints Policy

Complaints can be made through a variety of mediums including Email, Written Letters, & Phone calls, or In Person. Frank Investments has an internal complaint handling policy which will then be followed when any complaint is received.  You will receive written acknowledgment of your complaint within 5 business days of receipt, the acknowledgment will also enclose more details of our complaint procedure.  This is also available on request. The complaint will be handled by the Head Of Compliance or a director should the Head Of Compliance be involved in your complaint. Your complaint will be acted on promptly and with due care and diligence and the findings will be communicated to you as soon as possible.

If you are not satisfied with the resolution of the complaint and you are eligible you can also refer your complaint to the Financial Ombudsman Service.

Complaints should be issued to:

Amy Grovit

Head Of Compliance

Frank investments

Holborn Town Hall

Level 3,193-197 High Holborn

Email: Amy@frankinvestments.co.uk

London WC1V 7BD

Phone: 0203 994 9775