Conduct of Business Sourcebook rule 2.2.3R, requires Park Square to include a disclosure on its website stating the nature of its commitment to the UK Stewardship Code (“the Code”) issued by the Financial Reporting Council in July 2010. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy. The Code is a voluntary code and sets out various principles relating to the level of engagement by investors with UK equity investors. Investors may either comply with the Code in full or choose not to comply with certain aspects of the Code, in which case an explanation of non compliance is required.
The seven principles of the Code are that institutional investors should:
- publicly disclose their policy on how they will discharge their stewardship responsibilities;
- have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
- monitor their investee companies;
- establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
- 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.
Park Square advises and manages funds which invest in various types of European and US debt securities. Park Square’s strategy does not involve any investment in UK listed companies, and Park Square does not anticipate making any such investments in the future.
For this reason, whilst Park Square supports the Code’s objectives and seeks to align its approach with the broad aims of the Code where applicable, it has decided not to commit to the principles of the Code. As part of its strategy Park Square does not anticipate actively engaging on a regular basis with management of investee companies and were there ever to be concerns over governance which might threaten the value of such investments Park Square would consider exercising its voting power to oppose the board and/or disposing of its investment.
Should Park Square’s investment strategy change, there will be a review of its commitment to the code at that time and appropriate disclosures will be made.
Pillar 3 Disclosure
Park Square is categorized as a IFPRU 125k limited license firm with the FCA, and is required to disclosure Pillar 3 information. The disclosure will be published on an annual basis as soon as practical after Park Square’s annual accounts have been audited and will be based on the position as at the ‘Accounting Reference Date’ which is 31st December.
Please click here for our Pillar 3 disclosure.
Park Square is categorized as a limited license firm with the FCA, and is therefore is subject to FCA rules on remuneration within SYSC Chapter 19A. The disclosure will be published on an annual basis as soon as practical after Park Square’s annual accounts have been audited and will be based on the position as at the ‘Accounting Reference Date’ which is 31st December.
If the circumstances of the business change Park Square will consider whether more frequent publication is necessary. Park Square is not a member of a UK Consolidation Group.
MiFID II – Article 3(3) of RTS 28 and/or Article 65(6)
This disclosure if being made pursuant to Article 3(3) of RTS 28 and/or Article 65(6) of the MiFID II Delegated Organisational Regulation, which require firms to disclose, for each class of financial instruments traded for clients during the period, a summary of the analysis and conclusions drawn from the execution quality monitoring that Park Square has undertaken.
Please click here for our RTS 28 and/or Article 65(6) Disclosure.
For further details on any of the above information please contact a member of the Compliance Team on firstname.lastname@example.org
Park Square Capital, LLP
Last updated 30/04/2018