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 made pursuant to the requirement set out in Rule 2.2.3 of the FCA’s Conduct of Business Sourcebook, requiring firms to disclose the nature of their commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code establishes the core principles of effective stewardship and sets a high standard of transparency for asset owners and asset managers, and for the service providers that support them.
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.
MIFIDPRU 8 Disclosure for Financial Year ended 31 March 2026
Introduction
This disclosure statement has been prepared for OxFORD Asset Management LLP (“OxFORD LLP” or the “Firm”) in order to fulfil the regulatory disclosure requirements set out by the Financial Conduct Authority (“FCA”) in the Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) Chapter 8.
This disclosure is prepared on an individual basis and relates to OxFORD LLP. Staff generally are housed in its holding company The Oxford Asset Management Company Limited (the “Company” and, together with OxFORD LLP, “OxFORD”).
OxFORD LLP is a UK incorporated limited liability partnership registered at Companies House (registered number OC317131) and authorized and regulated by the FCA (FCA firm reference number 461545).
The Company is a UK incorporated limited company registered at Companies House (registered number 02808776).
The Firm is classified as an SNI MIFIDPRU investment firm under MIFIDPRU 1.2.1R. This classification means that under MIFIDPRU Chapter 8 a limited set of disclosure requirements apply to the Firm. The Firm, as an alternative investment fund manager, is also classified as a collective portfolio management investment firm, and as such, is also subject to the AIFM Remuneration Code (SYSC 19B).
The Firm’s clients are the fund(s) that it manages and the separately managed account client(s) that is advises. Underlying investors in the fund(s) and separately managed account client(s) are institutional investors, such as pension funds, endowments, and other professional investors.
Unless otherwise stated, all figures are as at 31 March, being the Firm’s financial year end, or relate to that financial year period.
This disclosure has been approved by the Firm’s Management Committee and is published on the Firm’s website (www.oxam.com).
OxFORD is independent and partner-managed.
Remuneration policy and practices
The Firm has adopted a remuneration policy to ensure adherence to the relevant remuneration requirements contained in the FCA Handbook.
The objective is to take a risk-based approach which is consistent with sound and effective risk management. The Firm is dedicated to ensuring that staff are not remunerated for exceeding the risk tolerances of the Firm. When assessing individual performance, the Firm takes account of financial as well as non-financial criteria.
Remuneration is split into fixed remuneration, variable remuneration and guaranteed variable remuneration (if applicable). Variable remuneration reflects both individual contribution to OxFORD and the financial results of both the Firm and any fund managed by the Firm. Guaranteed variable remuneration is expected to be awarded in exceptional circumstances only, if at all.
Staff are offered fixed remuneration in the form of a regular salary. This is determined for an individual based on their relevant job title and associated responsibility. Fixed remuneration is not dependent on performance and is not revocable.
All staff are eligible to receive variable remuneration. OxFORD awards variable remuneration to reward and incentivize financial and non-financial performance as well as contribution in a fair and reasonable way. Variable remuneration is discretionary and determined in a holistic manner by the Management Committee (or remuneration committee) rather than using a granular set of metrics. A proportion of variable remuneration, for eligible staff, is automatically deferred for a period of two years.
OxFORD reserves the right, in certain specified circumstances, to make adjustments to the deferred and unpaid portion of variable remuneration awarded to a member of staff and to require the return of paid variable remuneration.
Deferred variable remuneration is invested in fund(s) managed by the Firm so that the amount of deferred variable remuneration vested in an individual is linked to fund(s) performance. Doing so acts to align interests of staff with those of investors.
Remuneration is determined by the Management Committee (with remuneration for Management Committee members being determined by OxFORD’s Remuneration Committee). In respect of those in risk and compliance control functions, remuneration decisions are reviewed by the Firm’s independent risk adviser.
Remuneration
The total amount of fixed remuneration, and the total amount of variable remuneration and guaranteed variable remuneration, awarded to all staff in the relevant year, is available upon application to the Chief Financial Officer, e: finance@oxam.com.
Contact
For further information on OxFORD’s approach in relation to SRD II, the Code or the MIFIDPRU 8 disclosure, please contact:
Chief Compliance Officer, OxFORD Asset Management
+44 (0)1865 248 248
July 2026