Regulatory Information

Remuneration Code and the firm’s Remuneration policy

The Partners of the firm ensure Piton’s remuneration arrangements are consistent with and promote sound and effective risk management and do not encourage excessive risk taking.   They review and approve the remuneration of all staff including any that may fall into the scope of the FCA’s Remuneration Code, although currently none.  As a €50,000 Limited Licence firm Piton Capital is a Tier 4 level of firm invokes it’s right to disapply certain rules.

UK Stewardship Code Disclosure Statement

The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.Under COBS 2.2 of the FSA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the above Code, which was published by the Financial Reporting Council (‘FRC’) in July 2010.
The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term 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 “comply or explain” basis.

The seven principles of the Code are that institutional investors should:

Publicly disclose their policy on how they will discharge their stewardship responsibilities;
Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
Monitor their investee companies;
Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
Be willing to act collectively with other investors where appropriate;
Have a clear policy on voting and disclosure of voting activity; and
Report periodically on their stewardship and voting activities.
Piton Capital LLP does not currently comply with the Code for the following reasons:

We do not currently invest in listed companies in the UK
We determine our approach to stewardship on a case by case basis, taking into account the actions that will lead to the most favourable outcome for the value of our investments.