Version control: Last Reviewed December 2025
1. UK Stewardship Code 2026 Statement
The UK Stewardship Code 2026 (the Code) establishes the core Principles of effective stewardship and sets a high standard of transparency for asset owners and asset managers, and for the service providers that support them.
The principles of the Code are:
- Signatories integrate stewardship and investment to deliver long-term sustainable value for their clients and beneficiaries.
- Signatories identify and respond to market-wide and systemic risks to promote well-functioning financial markets.
- Signatories engage to maintain or enhance the value of assets.
- Signatories actively exercise their rights and responsibilities.
- Signatories integrate stewardship considerations into their selection and oversight of external managers.
- Signatories monitor and hold to account stewardship service providers.
- Signatories communicate with clients to understand their objectives and deliver services to support their stewardship.
- Proxy advisors ensure the quality and accuracy of their research, recommendations and voting implementation.
- Investment consultants identify and respond to market-wide and systemic risks to promote well-functioning financial markets.
- Engagement service providers engage on behalf of their clients to maintain or enhance the value of assets.
2. Statement of Commitment
The Firm supports the objectives of the Code and has chosen to commit to it. The Firm recognises that effective stewardship supports the long-term sustainable value of investments and the protection of client interests where the Firm exercises ownership rights or influence.
The Firm operates a multi-strategy approach to investing that involves investing across a range of asset classes and geographies, including investments in UK listed equities. As such, the relevance and application of stewardship activities vary across strategies and funds. The Firm applies the principles of the Code in a manner that is proportionate and appropriate to each strategy, in line with the Code’s “apply and explain” approach. For strategies that involve short-term trading, quantitative or systematic models, or instruments where the Firm does not exercise ownership rights or meaningful influence, stewardship activities such as engagement and voting are not considered relevant and are therefore not applied. For strategies which hold longer term equity positions in the United Kingdom, portfolio managers are responsible for stewardship activities relevant to their investments, including monitoring investee companies, exercising voting rights, and engaging with company management and boards where appropriate. Engagement activities may include participation in shareholder meetings and dialogue intended to influence governance, strategy, risk management, or long-term value creation.
Sturgeon Ventures LLP
Reg No: OC319614
VAT No: 884562876
