Shareholder Rights Directive II
The disclosure below is pursuant to the FCA’s Conduct of Business Sourcebook, in relation to the Shareholder Rights Directive II (EU) 2017/828 (“SRD II”). SRD II applies to firms which manage shares traded on a regulated market – which includes OxFORD Asset Management (“OxFORD”) – and is concerned with how shareholder engagement is integrated within their investment strategies.
OxFORD’s trading strategies are predominantly systematic which are managed by proprietary algorithms and software. The firm applies computational models to financial markets, analysing a range of data and information, and exploiting relationships among financial instruments such as stocks, futures, and currencies. Although the large majority of the firm’s trades are managed by proprietary algorithms and software, OxFORD also carries out some discretionary trading activities.
OxFORD’s discretionary trading activities involve researching into and monitoring companies. Positions held do not give significant influence over an investee company’s management staff.
Dialogue with an investee company’s management staff, stakeholders and other shareholders is expected to occur infrequently.
The monitoring of an investee company depends upon the particular strategy for that investee company, rather than being a set list of criteria.
OxFORD regards environmental, social and governance standards to be relevant for the long-term prospects of an investee company, although the firm’s trading strategies are generally short to medium-term.
OxFORD has the authority to exercise any voting rights vested in its client’s securities and has adopted proxy voting policies and procedures. In deciding whether and how to vote, OxFORD will act in the best interests of its client. It is OxFORD’s policy not to vote on administrative or governance matters. OxFORD is not required to vote every proxy and will exercise its right to vote proxies only where it believes the results of the vote may materially affect the value of the relevant securities. The firm does not vote in the vast majority of cases.
While OxFORD supports the general objectives of SRD II, it pursues investment strategies to which the aims of SRD II are not relevant. If the investment strategies change so that the provisions of SRD II become relevant, OxFORD will update this disclosure accordingly.
UK Financial Reporting Council’s Stewardship Code
The disclosure below is pursuant to the FCA’s Conduct of Business Sourcebook, in relation to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code sets out a number of principles relating to shareholder engagement by firms managing equity holdings in UK listed companies.
OxFORD’s alternative investment strategies are described in the section titled ‘Shareholder Rights Directive II’ (above). While OxFORD supports the general objectives of the Code, it pursues investment strategies to which the aims of the Code are not relevant. If the investment strategies change so that the provisions of the Code become relevant, OxFORD will update this disclosure accordingly.
For further information on the Firm’s approach in relation to SRD II or the Code, please contact:
Chief Compliance Officer
+44 (0)1865 248 248