Under Rule 2.2.3R of the FSA's Conduct of Business Sourcebook, Pendragon Capital LLP (the ‘Firm’), as an investment manager is required to include on its 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.

The Firm pursues primarily an event driven strategy that involves it investing in global equities, including UK equities. The Code is therefore relevant to some aspects of the Firm's trading. While the Firm generally supports the principles set out in the Code, the Firm has chosen not to commit to the Code. The Firm invests in a variety of asset classes and in a variety of jurisdictions globally. The Firm takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

Pendragon Capital LLP is authorised and regulated by the Financial Services Authority.

 

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