UK Stewardship Code

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This statement outlines the Lombardi Capital’s position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in 2012 and 2020. Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Lombardi is required to make a public disclosure about the nature of its commitment and level of compliance to the Code or, where it does not commit to the Code, to explain its alternative investment strategy.

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The Code is a voluntary code, which aims to enhance the quality of engagement between asset owners/asset managers and listed companies in the UK, to help improve long-term risk-adjusted returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a “apply and explain” basis. It also describes steps that asset owners can take to protect and enhance the value that accrues to the ultimate beneficiary.

The Code comprises twelve Principles that can be summarised as follows:

• Purpose, strategy, and governance
• Governance, resources, and incentives
• Conflicts of interest
• Promoting well-functioning markets
• Review and assurance
• Client and beneficiary needs
• Stewardship, investment, and ESG integration
• Monitoring managers and service providers
• Engagement
• Collaboration
• Escalation
• Rights and Responsibilities
• Exercising rights and responsibilities

The Firm’s approach in relation to engagement with issuers and their management, is determined on a global basis. A consistent global approach is taken to engagement with issuers and their management in all of the jurisdictions in which we invest and, consequently, Lombardi does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

However, whilst we have not made a formal commitment of compliance with the Code, Lombardi Capital’s investment approach is such that we are generally supportive of the spirit and aims of good stewardship as contained within the Code. As such, in practice, the Firm’ would take into consideration the principles as set out in the Code.

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