DELFT
INVESTMENTS LIMITED
Stewardship Code Disclosure
Best Execution Policy
Complaints Policy
Data Protection Privacy Notice
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Shareholder Rights Directive
MIFIDPRU 8 Disclosure
Section 172 Statement
Our Complaints Policy can be accessed here.
Our Data Protection Privacy Notice can be accessed here.
Under Conduct of Business Rule 2.2B.5R, a firm must either develop a formal engagement policy that meets the requirements of COBS 2.2B.7R or publicly disclose a clear and reasoned explanation of why it has chosen not to comply with any of the requirements.
Delft Investments invests in various asset classes in different jurisdictions globally. The nature of Delft’s investment strategy does not allow it to engage with investee companies through formal shareholder engagement. Delft does not exercise any voting rights or engage with other shareholders. Delft does not actively engage with investee companies as part of its investment proposition. On that basis, Delft has not developed a formal engagement policy for public disclosure.
Delft Investments Limited MIFIDPRU 8 Disclosure
Our MIFIDPRU 8 disclosure can be accessed here
The directors of the company always endeavour, individually and collectively, to act in a way to promote the success of the company for the benefit of its members as a whole. In doing so, they consider the likely consequence of any decisions in the long-term, having regard to an approach that is fair and equitable to all members of the company.
Underlying their decision-making process, the directors consider the impact on the company’s employees and are mindful of how the company’s business operations impact the community and environment. The directors’ overarching responsibility is to maintain a reputation for high standards of business conduct and seek to build strong business relationships with suppliers, customers and other key counterparties.
The shareholders of the company are its key stakeholders. As is common with businesses of the size and scale of
the company, key shareholders are represented on the Board of the company, ensuring that shareholders are
integral to all strategic decisions that are made.
During the year under review, there were no key decisions made that could impact its shareholders or other
potential interested parties.
Under Rule 2.2.3R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, Delft Investment (“Delft” or “the Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include 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, explain its considered choice based on the Firm’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.
Delft invests in a variety of asset classes in a variety of jurisdictions globally and exposure to UK- listed companies is relatively limited. Therefore, whilst Delft generally supports the objectives that underlie the Code, the nature of its investment strategy do not allow it to formally engage with investee companies through voting rights. The Firm has therefore chosen not to commit to the Code at this time.
Delft Investments Limited (“Delft”) is authorised and regulated by the Financial Conduct Authority (FCA). FRN 949232
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Delft is a MiFID firm providing advisory and discretionary investment management services to a number of segregated accounts.
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