REGULATORY DISCLOSURES – June 2022
East Lodge Capital Partners LLP UK Stewardship Code Disclosure
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, East Lodge Capital Partners LLP (the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers.
The Firm’s strategy is to seek to achieve attractive risk-adjusted returns whilst limiting volatility by investing in global structured and corporate credit opportunities as well as investing in commercial real estate loans and other direct lending opportunities whilst also overlaying a hedging strategy. This strategy does not involve the Firm taking an activist shareholder approach.
Consequently, while the Firm supports the general objectives that underlie the Code, the provisions of the Code are not relevant to the investment strategy currently undertaken by the Firm.
East Lodge Capital Partners LLP Pillar 3 Disclosure & Complaints Policy
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MiFID II Best Execution Disclosure for 2022 for East Lodge Capital Partners LLP
East Lodge Capital Partners LLP (“East Lodge”) is registered with the UK Financial Conduct Authority as a full-scope Alternative Investment Fund Manager with top-up permissions in respect of its activities in relation to managed accounts. The MiFID II best execution disclosure requirements outlined in RTS28 therefore only apply to East Lodge in respect of its MiFID business which, for the year 2022, consists solely of acting as investment manager to a single managed account, Boston Patriot Federal Street (“BPFS”) and being the delegated investment manager of a European Irish ICAV. Further, the disclosure requirements relate only to order placement and transmission activities and not to direct executions.
East Lodge transacts in a number of instrument types consisting of bonds (predominantly asset- backed securities), derivatives (CDS and TRS) and derivative options, repo financing trades, and foreign exchange trades. In all cases, East Lodge transacts via direct execution and not order placement via third parties (indirect execution). As such, we believe that East Lodge has no reporting obligation under RTS28.