UK Financial Reporting Council’s Stewardship Code

Aurum Funds Ltd. (“AFL”) is a London-based investment research and marketing company authorised and regulated by the Financial Conduct Authority. AFL provides investment research services to Aurum Fund Management Limited (“AFML”) in Bermuda which is the Investment Adviser to a range of Bermudan and Irish domiciled funds (the “Aurum Funds”). AFML is regulated by the Bermudan Monetary Authority.

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, AFL is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.

The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.

Commitment to the UK Stewardship Code

AFL generally supports the objectives that underpin the Code, but cannot comply with the Code in its entirety in respect of investment research services supplied to AFML in relation to the Aurum Funds.

In particular, the Aurum Funds are fund of funds products which invest in hedge funds managed by external managers. Aurum Funds do not generally invest directly in securities of companies, and the responsibility for engaging with companies resides with the external investment managers which manage the funds in which the Aurum Funds invest.

These external investment managers are based in a range of different countries and regulatory jurisdictions and they are required to implement a mixture of investment strategies in order to comply with the investment objectives of the various Aurum Fund portfolios. Consequently, due to particular investment strategies and structures, not all of the external managers recommended by AFL can fully comply with the Code.

The Anti-Bribery Act

AFL and its affiliated companies value their reputation for socially responsible, ethical behaviour and for financial probity and reliability. In conducting its operations, such entities will not award or seek business or make particular business commitments based on improper personal incentives (whether cash or other inducements).

AFL and its affiliated companies follow a globally consistent approach to managing anti-bribery at all levels of our business and in all regions in which we operate in compliance with the UK Bribery Act (2010) and related legislation. Our approach is implemented via and outlined in our anti-bribery policy.

Proximity Access Policy

The board of Aurum Fund Management Ltd. has determined that, in the interests of ensuring fair and transparent treatment of all customers and clients across the Aurum group, access to the Proximity proprietary reporting package will only be made available to the following entities:

Investors in each of Aurum’s Institutional Funds;
Investors in an Aurum bespoke managed portfolio; and
Investment Advisers who have introduced assets in Aurum funds in excess of $10m and who continue to have an underlying interest in those funds.

Access will be granted after executing Aurum’s standard Proximity Agreement and Electronic Access Agreement. A copy of Aurum’s standard Proximity Agreement and Electronic Access Agreement is available to eligible entities on request.

MiFID II Product Governance Disclosures

Information on Aurums’ approach to the product governance disclosures required by MiFID II can be accessed here.

General Privacy Statement

Can be accessed here.

Investment Manager Privacy Notice

Can be accessed here.

Remuneration Policy

Can be accessed here.

ESG Policy

Can be accessed here.