The FCA’s Conduct of Business Sourcebook rule 2.2.3R, requires Optimus Capital, as an Investment Manager, to include a disclosure stating the nature of its commitment to the UK Stewardship Code (“the Code”) issued by the Financial Reporting Council. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy. The code sets out various principles relating to the level of engagement by investors with UK equity investors.Details of the Code can be found at the following: https://www.frc.org.uk/investors/uk-stewardship-code
Optimus Capital LLP does not comply with the Stewardship Code. Optimus manages a suite of model portfolios, which invest in collective investment schemes, namely Exchange Traded Products (ETPs) and OEIC Funds. Optimus does not invest in, nor provides its advisory clients with advice on, single issues. Optimus does not have the capability to monitor every company within the collective investment schemes it invests in or provides advice on.
Optimus does not employ research analysts and does not spend time researching single issues. For this reason, the company’s expertise lie outside of single issue selection and there is insufficient staff, time and knowledge for the company to analyse single companies, monitor governance activities and engage with companies on strategy, performance risk, capital structure, culture and remuneration.
Therefore, the requirements of Principle 1 and 2 are disproportionate to Optimus’ capability. As Optimus does not hold single issues, it has no voting rights so potential for conflicts of interest to rise as described in Principle 2 is nil. As Optimus does not own shares in its own name – the fund manager or passive fund house, which manages the collective investment schemes Optimus invests in, will own single issues in their own name – Optimus is unable to access management or attend general meetings, so is unable to carry out guidance in Principle 4, 6 and 7, nor is it able to engage with other investors as set out in Principle 5.
As Optimus does not commit to the Code, its alternative investment strategy will carry out due- diligence on all collective investment schemes and providers of the collective investment schemes, for passive and active investment schemes. This due diligence will cover the investment strategy, historic performance and risk controls each house and investment scheme employs. It is through this due diligence and, where investments are made, dialogue with the provider that Optimus promotes delivery of its clients’ investment objectives. Dialogue includes requesting new share classes, lobbying for access to institutional share classes, discussing fees charged, requesting and attending meetings with fund managers and passive fund providers.