The FCA's Conduct of Business rule COBS 2.2A.5 and COBS 2.2.3 requires Euronova Asset Management UK LLP ('Euronova') to disclose on its website the nature of its commitment to the UK Stewardship Code ('the Code'). This is a voluntary code which was published by the Financial Reporting Council ('FRC') in July 2010 and last revised in September 2012. It aims to enhance the quality of engagement between institutional investors and investee companies to help improve long term returns to shareholders and the efficient exercise of governance responsibilities.

For firms that are committed to the Code, this is applied on a 'comply or explain' basis. Compliance with this Code is not mandatory and the FRC recognises that not all parts of the Code will be relevant to all institutional investors.

Following the publication of the Code the FCA require all firms which manage investments on behalf of professional clients (including collective investment vehicles) to disclose the nature of their commitment to the Code or, where it does not commit to the Code, its alternative investment strategy.


There are 7 Principles of the Code which are that institutional investors should:

Euronova's Position

Euronova is an independent Investment Manager which currently has two clients. It provides investment management services to two funds as follows:


The investment objective of the ESCF is to achieve capital growth by investing in smaller capitalisation European companies. Euronova draws upon the extensive experience of its investment team to build a portfolio of fundamental positions, both long and short. The dedicated stock picking is based on knowledge and information obtained by means of extensive company contact and in depth fundamental analysis. We seek to generate Alpha for the ESCF from long and short positions, whilst using index futures to reduce both long and short net exposure, when appropriate.

The ESCF invests in a number of different asset classes, including in Contracts for Differences (CFD's) where voting rights do not apply.

Otherwise we do not have a fixed policy for proxy voting for the ESCF and would only vote where we believe it is in our underlying investor's interest to do so. The ESCF has often voted by proxy via its Custodian, but would not normally vote on a collective basis with other investors


The investment objective of the VEMSCF is to achieve capital growth by investing in smaller capitalisation European companies. Euronova draws upon the extensive experience of its investment team to build a portfolio of investments, all long. By applying active bottom-up stock-picking in smaller, high quality growing companies the managers aim to identify clear investment opportunities, with high returns on capital employed (ROCE) strong cash flow generation that are under-valued & under-researched.

VEMSCF invests primarily in equities.

Euronova is required under its managment contract to follow the proxy voting policy of Vontobel Asset Management, and as such does not have its own proxy voting policy.

Therefore Euronova determines its approach to stewardship on a case by case basis, taking into account the actions that will lead to the most favourable outcome for the value of our client(s) investments.

We have a robust written conflicts of interest policy in relation to any conflicts that may arise between the firm and its clients and also when relevant between different clients and this policy is monitored and reviewed regularly. We monitor investee companies on a regular basis and carry out appropriate due diligence prior to investing. This will normally include meeting the management of the company prior to investment. It may also include discussing the investee company with other investment analysts. Records are kept of any such due diligence including findings on the detailed research carried out on each investee company.

Therefore, although Euronova supports the aims set out within the Code and certain of its Principles and also supports good corporate governance of investee companies, specific provisions of the Code are not deemed to be proportionate to the type of investment strategy and trading currently undertaken on behalf of its clients. We arrange for investments in a variety of different jurisdictions and therefore we do not consider it appropriate to commit further to any particular voluntary code of practice relating to individual jurisdictions at this stage. Should this change in the future, we will review our commitment to the Code at that time and make appropriate further disclosure.

January 2018