SRD II
GREENTRAIL PARTNERS LLP
STATEMENT IN RELATION TO THE SHAREHOLDER RIGHTS DIRECTIVE II
02/2025
Introduction
The Second Shareholder Rights Directive ("SRD"), which took effect in the UK on 10 June 2019, aims to improve shareholder engagement and increase transparency around stewardship. Greentrail Partners LLP (the "Firm") invests in listed equities globally, and as such, we are required to disclose and make publicly available our policies on how we engage with other shareholders and the companies in which we invest, and how our strategies create long-term value.
SRD AND THE FRC STEWARDSHIP CODE
The UK Stewardship Code (the "Code") was established by the Financial Reporting Council in 2010. UK-authorised asset managers have been required under the rules of the Financial Conduct Authority to produce a statement of commitment to the Code or explain why it is not appropriate to their business model.
Unlike SRD, which applies to investments in listed equities globally, the Code focuses on investments in UK companies only. The Firm’s response to the Code is detailed in a separate statement, which is available via the website.
THE FIRM'S APPROACH
Greentrail Partners LLP is a UK-based investment manager that specialises in global equities. Our investment philosophy is focused on identifying high-quality companies with strong fundamentals, sound governance, and long-term growth potential. We integrate environmental, social, and governance (ESG) factors into our investment process and seek to engage constructively with investee companies to enhance shareholder value.
The Firm has elected to publicly disclose its Engagement Policy, which is set out below.
This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm’s position change, we will review our commitment to SRD and make appropriate disclosure at that time.
ENGAGEMENT POLICY
(a) Integration of Shareholder Engagement in Investment Strategy
Greentrail Partners LLP employs a fundamental, research-driven approach to investing in global equities. Our engagement strategy includes:
- Regular monitoring of investee companies’ financial and non-financial performance, governance structures, and risk factors.
- Direct dialogue with company management teams to understand their strategic priorities and advocate for long-term value creation.
- Exercising our shareholder rights, including voting at general meetings, to support governance best practices.
(b) Monitoring Investee Companies on Relevant Matters
The Firm closely monitors investee companies in relation to:
- Business strategy and long-term value creation.
- Financial and operational performance.
- Capital allocation and capital structure decisions.
- Social and environmental impact, including climate-related risks and opportunities.
- Corporate governance standards, including board structure, executive remuneration, and shareholder rights.
Our monitoring process is led by our portfolio managers and research analysts, who conduct ongoing due diligence and engage with senior management as needed.
(c) Dialogue with Investee Companies
Greentrail Partners LLP maintains an active dialogue with investee companies through:
- Regular management meetings and investor presentations.
- Participation in shareholder consultations and industry discussions.
- Formal engagement on governance and sustainability topics.
(d) Exercising Voting Rights and Other Rights Attached to Shares
As a fiduciary, Greentrail Partners LLP exercises voting rights in the best interests of its clients. Our Proxy Voting Policy is designed to:
- Support management initiatives that align with long-term shareholder value.
- Promote transparency and accountability in corporate governance.
- Oppose proposals that may erode shareholder rights or misalign management incentives.
We utilise independent research and voting recommendations from third-party proxy advisors but retain full discretion over voting decisions.
(e) Cooperation with Other Shareholders and Communication with Stakeholders
Greentrail Partners LLP may collaborate with other institutional investors on governance and sustainability initiatives where it aligns with our engagement objectives. We participate in industry working groups and forums to advocate for responsible investment practices.
(f) Management of Actual and Potential Conflicts of Interest
The Firm has a documented Conflicts of Interest Policy to ensure that engagement activities are conducted fairly and transparently. Potential conflicts may arise in:
- Aggregation and allocation of orders.
- Proxy voting decisions.
- Investments across different client mandates.
Conflicts are reviewed by the Firm’s governance team and escalated to the relevant oversight committees as necessary.