Regulatory Disclosures
MIFIDPRU 8
Management Committee Diversity
Bell Rock Capital Management LLP (Bell Rock) maintains a comprehensive policy relating to the role and composition of the management committee, including promoting diversity. This policy includes recruitment processes and record-keeping requirements and we review the composition of the management committee on at least an annual basis.
Shareholder Rights Directive
Bell Rock has carefully considered the EU Shareholder Rights Directive II (2017/828) ("SRD"), as implemented by the FCA, and has decided not to publish a shareholder engagement policy.
COBS 2.2B of the FCA Handbook (SRD requirements) does not apply to the majority of investments made by Bell Rock. In the limited cases where it does, Bell Rock has decided not to publish such a policy because it does not generally exercise any rights as a shareholder; the relative nature and size of the relevant investments does not warrant the creation of such a policy; and Bell Rock provides its clients on request with all relevant information that would be covered by such a policy.