Disclosure

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 LLP (“OxFORD LLP”) – and is concerned with how shareholder engagement is integrated within their investment strategies.

OxFORD LLP’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 LLP also carries out some discretionary trading activities.

OxFORD LLP’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 LLP 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 LLP 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 LLP will act in the best interests of its client. It is OxFORD LLP’s policy not to vote on administrative or governance matters. OxFORD LLP 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. OxFORD LLP does not vote in the vast majority of cases.

While OxFORD LLP 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 LLP 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 LLP’s alternative investment strategies are described in the section titled ‘Shareholder Rights Directive II’ (above). While OxFORD LLP 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 LLP will update this disclosure accordingly.

Contact

For further information on OxFORD’s approach in relation to SRD II or the Code, please contact:

Chief Compliance Officer, OxFORD Asset Management
+44 (0)1865 248 248

January 2024