Rule 2.2.3 of the FCA’s Conduct of Business Sourcebook requires an FCA authorised firm to either disclose its compliance or explain its non-compliance with the principles set out in the UK Financial Reporting Council’s Stewardship Code (the “Code”). Northlight Group LLP (“the Firm”) is regulated by the FCA in the United Kingdom and therefore subject to COBS 2.2.3R. 

The Investment Manager’s strategy focuses on European credit opportunities and generally does not envisage significant investment in public equities. The strategy does, in principle, not result in direct investments in equities listed on the London Stock Exchange or any other UK Stock Exchange. Accordingly, whilst the Firm supports the Code as a mechanism to promote best practice in the institutional shareholder governance of UK listed companies, the Firm does not consider the Code or its principles to be appropriate for the funds’ investment strategies

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice.  Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time.  

For further details on any of the above information please contact the Firm’s Compliance Officer.