PGIM Wadhwani LLP (“PGIMW”) is a Full Scope UK AIFM which employs a quantitative multi-asset macro approach across its investment strategies.
Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2B.5, PGIMW is required to develop and publicly disclose an engagement policy as described in the revised Shareholder Rights Directive (“SRD II”) or provide a clear and reasoned explanation as to why it has chosen not to develop and adopt a shareholder engagement policy at this time. PGIMW will review this on an ongoing basis.
PGIMW supports the objectives underlying SRD II and adheres to the highest standards of corporate governance and due diligence in respect of its investments. However, PGIMW believes that its investment strategies and operational structure are incompatible with shareholder engagement activities.
PGIMW’s investment strategies are global quantitative macro strategies, primarily managed futures and foreign exchange. The strategies do not invest in individual equity securities, trade directly in listed companies in the UK or hold shares that carry voting rights.
Therefore, whilst PGIMW generally supports the objectives that underline the rationale for development of an Engagement Policy, the nature of its investment strategies is such that its provisions are not materially relevant.