Stewardship Code

Stratton Street Capital - UK Stewardship Code Disclosure

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Stratton Street Capital LLP (the "Firm") is required to include on this 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 sets out a number of principles relating to engagement by investors with UK equity issuers, as follows:

The seven principles of the Code are that institutional investors should: • Publicly disclose their policy on how they will discharge their stewardship responsibilities; • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship; • Monitor their investee companies; • Establish clear guidelines on when and how they will escalate their activities; • Be willing to act collectively with other investors where appropriate; • Have a clear policy on voting and disclosure of voting activity; and • Report periodically on their stewardship and voting activities.

The Firm pursues an investment strategy to which the aims of the Code are not relevant. Our strategy invests in bonds and currencies following an investment philosophy based on:

• Investment in credit requires a top-down macro understanding of the world as well as the ability to analyse the merits of individual bonds and bond issuers. • The extra “credit spread” over government bonds does not always reflect the underlying investment risk based on an issuer’s fundamentals. • The Net Foreign Asset position is an essential component in the investment decision. • The Firm’s credit selections are not constrained by indices. They use a Global Pricing Model to work out fair value and then focus on those credits which are mispriced / undervalued.

The Firm has designed a number of fundamental models to aid rather than drive their investment process. Bond selection is aided by “Sophisticated Screening” using our proprietary “Relative Value Model” (RVM). The RVM comprises a global database of circa 8,000 bonds and enables the Firm to efficiently focus on the most undervalued credits. Corporate bonds highlighted as being undervalued by the RVM are then further screened for financial strength by the Corporate Credit Model, prior to further analysis.

Consequently, while the Firm supports the general objectives that underlie the Code, the provisions of the Code are not relevant to the type of trading currently undertaken by the Firm. If the Firm's investment strategy changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.

For further information on the Firm’s approach contact:

Hiren Patel – Compliance Officer.