Shareholder Rights Directive II (“SRD II”) SRD II aims to improve stewardship and corporate governance by firms including a full scope Alternative Investment Fund Managers that invest in shares traded on a regulated market in the EEA as well as ‘comparable’ markets situated outside of the EEA.
Under FCA COBS 2.2.B SRD, we are required to:
a) develop and publicly disclose an engagement policy that meets the requirements of COBS 2.2B.6R; and
b) Publicly disclose on an annual basis how our engagement policy has been implemented in a way that meets the requirements of COBS 2.2B.7R; or
c) Publicly disclose why we have chosen not to comply.
The engagement policy must describe how a firm:
1) integrates shareholder engagement in its investment strategy:
2) monitors investee companies on relevant matters, including:
a. strategy;
b. financial and non-financial performance and risk;
c. Capital structure; and
d. social and environmental impact and corporate governance;
3) conducts dialogues with investee companies;
4) exercises voting rights and other rights attached to shares;
5) cooperates with other shareholders;
6) communicates with relevant stakeholders of the investee companies; and
7) Manages actual and potential conflicts of interests in relation to the firm’s engagement.
On an annual basis, the firm must disclose a general description of voting behavior, an explanation of the most significant votes and reporting on the use of services of proxy advisors. The disclosure must include how votes have been cast unless they are insignificant due to the subject matter of the vote or to the size of the holding in the company. Katamaran Capital LLP believes firmly in the importance of effective stewardship and long-term decision-making, involving transparency of engagement policies between institutional investors and the investee companies.
Disclosure
In the last year, the Funds managed by Katamaran Capital LLP have not held equity positions in EEA listed companies above 3% of any investee companies issued share capital.
Accordingly, Katamaran Capital LLP is deemed to exercise an ‘insignificant’ influence over the management of its investee companies and does not expect that this will change in the near future. There were no significant votes to disclose during the period mentioned given the relatively small size of the holdings the Firm has in investee companies and noting it has not voted against investee company management in the period.
Katamaran Capital LLP will update this disclosure should there be any significant changes to the size of its equity holdings and/or at least on an annual basis.
Last Updated: March 2026