Financial Reporting Council UK Stewardship Code

Disclosure of our commitment to the Code

Introduction

We are required under FCA rules (COBS 2.2.3 FSA Handbook) to make a disclosure explaining the extent of our commitment to the UK Stewardship Code.

Background to the Firm’s operations

Saracen Fund Managers Limited is a relatively small investment management firm which manages one OEIC, with 3 sub-funds, with a total funds under management (FUM) of £140m.

Of the three sub-funds, 2 consist entirely of UK equities. However, the combined FUM of these sub-funds is only £12m. Consequently, although some of the companies in which these sub-funds are invested are small cap, the maximum percentage of company shares held is less than 0.4% of the total shares in issue.

The other sub-fund is a global fund with a small proportion of its investments in UK firms. The global companies invested in are mostly very large capitalised organisations and the fund’s exposure to any one of them would be very small in relation to their total equity capital.

The degree of influence we would command would be very small indeed.

Our commitment to the code

Although we are pleased to endorse the principles of the code, in practice we are not able to influence the UK companies in which we might be invested.

Annual review

We acknowledge that our exposure to UK companies could change and therefore we will monitor that exposure on an annual basis and publish the outcome of the review on this website.