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The Stewardship Code


Hay Hill Wealth Management Limited (“HHW”) fully supports the UK Stewardship Code (“The Code”) which was first published in July 2010, revised in September 2012 and sets out good practice for institutional investors (and investment managers) when engaging with the UK listed companies in which they invest, and is intended to enhance this relationship.

In line with the FCA’s requirements HHW’s Stewardship Code Statement discloses how they apply the Code’s Principles set out below.

Principle 1

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

HHW is a boutique investment manager and as such the holdings that it has in UK companies are small as a proportion of the issued share capital.  HHW will only exercise voting rights where it believes such voting to be in the best interest of its clients.

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

HHW is an independent boutique investment business and so there is a low risk of conflict of interest. In the event that a potential conflict of interest is identified the governing body of the firm will meet and determine the appropriate course of action in accordance with its conflicts of interest policy.

Principle 3

Institutional investors should monitor their investee companies

HHW undertakes research and constantly monitors the companies that form part of the client portfolios.

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

As a boutique manager the influence that HHW is able to bring to bear on investee companies is limited. In the event that HHW loses confidence in the management of an investee company the investment will be divested.


Principle 5

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

HHW is willing to work collectively with other investors and will determine on a case by case basis whether such collaboration is in the best interests of its clients.

Principle 6

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

HHW’s policy is to exercise voting rights where it believes, taking into account the size of the holding, it is in the interests of the underlying clients for such rights to be exercised. 


Principle 7

Institutional investors should report periodically on their stewardship and voting activities

If requested to do so HHW will send details of voting record to clients. 

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