The information on this website is directed only at persons resident in the UK. It does not constitute an open invitation to buy or sell in any jurisdiction other than in the UK. In particular, the distribution of the information contained on this website in certain jurisdictions may be restricted by law. Accordingly, persons who are not residents of the UK and who access the Wren Investment Office website are required to inform themselves of and to comply with any such restrictions.
Wren Investment Office is committed to maintaining your personal data in accordance with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation, and will take all reasonable steps to ensure that your personal details are kept secure against unauthorised access, loss, disclosure or destruction. The information that you supply may be made available to external servicing companies for the purpose of communicating.
Links to third parties sites
Wren Investment Office is not responsible for the accuracy or completeness of the information supplied by third party sites. Wren Investment Office takes care to ensure that the information provided by third party sites is correct but it does not warrant, represent or guarantee the contents of the information. Additionally, it does not accept any responsibility for errors, inaccuracies, omissions or any inconsistencies herein.
The Stewardship Code
The Stewardship Code is part of UK company law and contains seven principles that institutional investors are expected to follow. Its requirements are directed towards asset managers who hold voting rights for shares in UK companies. Principally, it aims to make institutional investors, who manage “other people’s money”, be active and engage in corporate governance in the interests of the underlying shareholders.
The seven principles are:
- Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
- Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.
- Institutional investors should monitor their investee companies.
- Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.
- Institutional investors should be willing to act collectively with other investors where appropriate.
- Institutional investors should have a clear policy on voting and disclosure of voting activity.
- Institutional investors should report periodically on their stewardship and voting activities.
Although Wren Investment Office (the firm) does not invest directly in the shares of UK companies on behalf of its customers, it supports the principles and aims to adhere to them as follows:
- Our policy is detailed in this disclosure.
- All authorised firms are required to act in the best interests of their customers and failure to do so could result in action being taken by the FCA. To ensure compliance with its regulatory responsibilities, the firm has a Conflicts of Interest policy and maintains a register of potential conflicts. Please contact Stephen Doherty ([email protected]) if you would like to see a copy of the firm’s policy.
- The firm invests primarily in Collective Investment Schemes (CIS) on behalf of its customers. Before investing, extensive due diligence is performed on each CIS manager which, amongst other factors, examines the manager’s governance structure, investment strategy, culture and philosophy. Once invested, ongoing due diligence is performed, and regular updates are held.
- The firm has regular and ongoing dialogue with CIS managers and concerns are raised as soon as they are encountered. If concerns are not addressed, and the firm believes it is in the best interests of its customers, the position could be sold.
- As the firm invests primarily in CIS, there is little scope to act collectively with other investors. If the firm’s customers’ interests were aligned with the interests of other investors, the firm would consider whether collaboration was possible and appropriate.
- The firm has a policy, which is reviewed annually, that sets out its guidelines for proxy voting. As most investments are in CIS, there are relatively few occasions when proxy votes are required. When they do occur, the best interests of customers are always considered. Due to confidentiality considerations, the firm’s current policy is not to disclose its voting records.
- The firm’s engagement with CIS managers is documented and, where appropriate, is discussed periodically with its customers. The firm has a high level of transparency and is happy to disclose relevant details to its customers upon request.
Shareholder Rights Directive (SRD II)
The FCA requires delegated Investment Managers, UCITS Management Companies and AIFMs to disclose their approach to the Shareholder Rights Directive (SRD II). Wren Investment Office is currently reviewing the requirements of SRD II and is considering whether to have a specific policy. An update will be published on our website in due course.
Conflict of Interest Policy
Wren Investment Office Limited maintains a Conflicts of Interest Policy, a copy of which is provided to clients as part of our account opening process. If you would like to see a copy of the policy, please contact Stephen Doherty at [email protected]
Copyright and confidentiality
Any information accessed via Wren Investment Office’s website is confidential and is protected under copyright law.
Wren Investment Office Limited’s registered office is 66 Lincoln’s Inn Fields, London, WC2A 3LH