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UK Regulatory Disclosures

Apera Asset Management LLP (the “Firm”)




This statement outlines the Firm’s position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in 2012 and 2020. Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, the Firm is required to make a public disclosure about the nature of its commitment and level of compliance to the Code or, where it does not commit to the Code, to explain its alternative investment strategy.

The Code is a voluntary code, which aims to enhance the quality of engagement between asset owners/asset managers and listed companies in the UK, to help improve long-term risk-adjusted 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 “apply and explain” basis. It also describes steps that asset owners can take to protect and enhance the value that accrues to the ultimate beneficiary.

The FRC recognises that capital is invested in a range of asset classes over which investors have different terms and investment periods, rights and levels of influence. Hence the Code does not solely apply to equity investments. 

The FRC also 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.

The Code comprises twelve Principles that can be summarised as follows: 

Purpose and governance

    1. Purpose, strategy and governance
    2. Governance, resources and incentives
    3. Conflicts of interest
    4. Promoting well-functioning markets
    5. Review and assurance

Investment approach

    1. Client and beneficiary needs
    2. Stewardship, investment and ESG integration
    3. Monitoring managers and service providers


    1. Engagement
    2. Collaboration
    3. Escalation

Rights and Responsibilities

    1. Exercising rights and responsibilities


Whilst the revised Code covers a broader range of assets, the Firm does not consider it appropriate to commit to any particular voluntary code of practice and feels that the Code is not proportionate to the Firm’s business model. However, in practice, the Firm would take into consideration the principles as set out in the Code.

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 the Code and make appropriate disclosure at that time.

For further details on any of the above information please contact the Firm’s Compliance Officer.

MIFIDPRU 8 Disclosures

Year ending 2022


The Firm is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm acts as an investment adviser and makes investment recommendations to a third-party investment manager with respect to funds. The Firm also acts as a discretionary portfolio manager.

The Firm is categorised as a “SNI MIFIDPRU investment firm” by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s MIFIDPRU 8 disclosure fulfils the Firm’s obligation to disclose to market participants’ key information on a firm’s remuneration policies and practices

In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities.

This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model.


The Firm is subject to the Remuneration Code (the “Code”) for MIFIDPRU Firms as codified in Section 19G of the SYSC sourcebook of the Financial Conduct Authority handbook.

This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.

A.  Qualitative Information

The Firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote effective risk management and do not encourage excessive risk taking.

The Firm ensures that the remuneration policy and its practical application are consistent with the Firm’s business strategy, objectives and long-term interests.

Given the nature and size of our business, remuneration for all employees is set by the Firm’s management body.

Staff receive a salary which reflects their market value, responsibilities and experience.

All staff may also receive variable remuneration, such as an annual bonus, where the individual operates within the risk appetite of the company and has demonstrated appropriate behaviour. Other potential incentive plans include participations in carried interest vehicles.

Variable remuneration is intended to reflect contribution to the Firm’s overall success. Staff are assessed throughout the year and rated based on company, department and individual performance. The performance assessment considers both financial measures and non-financial measures.

The Firm’s linkage between variable remuneration and performance is based upon the following tenets:

  • Ensuring an appropriate balance of financial results between staff and shareholders
  • Attraction and retention of staff members
  • Aligning the interest of senior staff members via long-term incentive awards
  • Discourage excessive risk-taking
  • Ensure client interests are not negatively impacted

B.  Quantitative Information

For additional information, please contact:
William Binks at