The UK Stewardship Code  

Colville Capital Partners Ltd (“Colville”) is an independent investment management company. Colville has the permission to carry on regulated activities for professional and eligible counterparty clients.

The Stewardship Code publication by the Financial Reporting Council of the UK Stewardship Code aims to enhance the quality of engagement between institutional investors and companies so as to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and should be applied by firms on a ‘comply or explain’ basis.  

Please find below Colville’s statement of compliance in relation to the seven principles of the Code 

Principle 1

Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

We act as an agent on behalf of our clients, and therefore Colville is not the beneficial owner of the investee company’s shares.  Only upon authorisation by our clients are voting decisions made on their behalf.  Colville considers the corporate governance of any investee company as part of the overall assessment prior to and during the investment process.

We exercise voting rights arising from shareholdings when it is in our clients’ interests to do so.

Principle 2  

Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed

It is our policy and duty to act in the best interests of all of our clients. Colville has a detailed policy on managing potential conflicts of interest in accordance with the standards required by the Financial Conduct Authority. Our policy on managing potential conflicts of interest and the register of potential conflicts are both available on application to the Compliance Officer at the firm’s registered office. All reasonable steps are taken to prevent conflicts of interest arising but in the event that a conflict does arise, the firm always places the interests of its clients above its own and if a conflict arises between clients, then the firm will do its best endeavours to treat all its clients fairly. Specific policies have been implemented to manage conflicts arising in connection with personal account dealing, client order handling, best execution, and use of dealing commissions. Colville does not trade for itself and does not hold proprietary positions.

Principle 3

Institutional investors should monitor their investee companies

Colville continually monitors its investee companies as part of the asset management process conducted on behalf of its clients.  This includes reviewing publicly available information on all investee companies, as well as third party investment research and industry / peer group comparison.  Where applicable and it is in the best interests of our clients, we will monitor an investee company at board level to ensure that the company’s leadership is effective and that the board is adhering to the UK Corporate Governance Code. This may be done by direct engagement with individual board member or attendance at general meetings.

Colville seeks to avoid the situation whereby the firm would become an insider. Our policy is to ensure wherever possible that an investee company does not communicate inside information to any director or employee of the firm without their prior agreement. We have established policies and procedures to cover market abuse and the potential misuse of inside information. 

Principle 4

Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value

Colville retains discretion over how and when it may escalate its activities in respect of intervention. Active intervention may take place if Colville believes that this course of action would be in the best interests of its clients.

Principle 5

Institutional investors should be willing to act collectively with other investors where appropriate

Colville may consider acting collectively with other investors when this is legally permissible and appropriate.  Colville is also prepared to be bound by any restrictions on its freedom to act as a consequence of its participation in a collective agreement. Any enquiries in respect of collective engagement should be addressed to the Compliance Officer at the firm’s registered address.

Principle 6  

Institutional investors should have a clear policy on voting and disclosure of voting activity

Colville votes its shares where it is in its clients’ interests to do so.

As we act as agent for its clients’ assets, any voting record is available to its clients either via their custodian or directly from Colville. We do not publicly disclose voting records as we believe that this information is confidential to our clients.

Principle 7 

Institutional investors should report periodically on their stewardship and voting activities

Colville reports to its clients in accordance with its regulatory reporting requirements and its obligations under its agreements with its clients. The content of these reports will include full disclosure of its stewardship and voting actions tailored to each client’s specific requirements. 

Colville does not disclose its stewardship and voting activities to the public or consider it necessary to seek an independent opinion of its engagement and voting processes. Colville considers the firm’s internal controls to be robust and appropriate for the size and complexity of the company.

Best Execution

Qualitative Disclosure

MiFIR Article 65(6) - Best Execution Qualitative Analysis

April 30th, 2018

Colville Capital Partners LTD (Colville) advises professional clients on managing their investments. Usually Colville’s clients choose their own trading venues to implement their trades and do not seek Colville’s assistance to implement trades.

Year to date only one professional client advised by Colville has asked Colville to place selected trades on their behalf for convenience purposes. The client has given Colville the possibility to place these trades with four highly recognised banks / brokerage firms with whom the Client has had a satisfactory trading relationships for years namely Barclays, HSBC, Lombard Odier and Edmond de Rothschild.  

Colville has ensured that these banks followed best execution policies. Specifically Colville has requested these banks to confirm that they had best execution policies in place and has requested to review these policies.

The securities traded by the client were overwhelmingly highly liquid blue chip publicly listed equities listed on the main exchanges which by nature carry lower risk of price disruption. The trades have been placed at market at specific times well outside the open and the close, which can carry higher volatility. Each time Colville has verified that the execution price was in line with the price observed on Bloomberg at the time of execution.

On one occasion the security traded was a perpetual bond issued by a blue chip company. Colville verified that the price obtained for the trade was well within the bid-ask spread indicated on Bloomberg.

All trade execution outcomes were understood and considered acceptable.

 

Mathieu Philippe

Compliance Officer

Quantitative Disclosure

Class of Instrument Equities
Notification if <1 average trade per business day in the previous year Y
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
Barclays 87% 75% NA NA NA
Lombard Odier 13% 25% NA NA NA
(only used these 2)
Class of Instrument Fixed Income
Notification if <1 average trade per business day in the previous year Y
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
Barclays 100% 100% NA NA NA
(only used this one)

Passive order: an order entered into the order book that provided liquidity

Aggressive order: an order entered into the order book that took liquidity

Directed order: an order where a specific execution venue was specified by the client prior the execution of the order