Regulatory

Capital Generation Partners LLP is a limited liability partnership registered in England and Wales. Registered number: OC331835. Registered office: Berkeley Square House, Berkeley Square, London W1J 6BX.

Capital Generation Partners LLP is authorised and regulated by the Financial Conduct Authority. 

Capital Generation Partners LLP is a Registered Investment Adviser regulated by the US Securities and Exchange Commission.

Capital Generation Partners Services Limited is registered in England and Wales. Registered number: 01602869. Registered office: Berkeley Square House, Berkeley Square, London W1J 6BX.

Stewardship Disclosure

The Firm supports the principles enshrined in the Financial Reporting Council’s (“FRC”) Stewardship Code which sets out good practice for investor engagement with the UK listed companies in which they invest. The Financial Conduct Authority (“FCA”) requires all authorised asset managers to publicly disclose either a statement of compliance with the Stewardship Code or where they do not commit, their alternative investment strategy.

The FCA and the FRC have acknowledged that certain aspects of the Stewardship Code are not directly relevant to all managers. The Firm does not generally advise or manage in relation to UK listed investments. Consequently, compliance with the Stewardship Code is not relevant to the Firm.

The Firm’s Partners will continue to review the Code’s applicability.

Shareholder Rights Directive (“SRD”)

The Second Shareholder Rights Directive (“SRD”), which took effect in the UK on 10 June 2019, aims to improve shareholder engagement and increase transparency around stewardship.

The Firm invests on an unconstrained multi-asset basis with dynamic asset allocation that is agnostic to investment strategy, style, geography, and asset class. It does not invest directly in listed equities as a core strategy but it may invest directly in listed equities from time-to-time. It is not considered to be an integral component of our investment strategy and therefore, it is not necessary for the Firm to disclose our Engagement Policy.

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 SRD and make appropriate disclosure at that time.

MiFIDPRU8 Disclosure

The Financial Conduct Authority (“FCA” or ​“Regulator”) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Capital Generation Partners LLP (“CapGen”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8” or the ​“public disclosures requirements”) sets out the specific public disclosure obligations with which CapGen must comply, further to those prudential obligations.

Please view our latest MIFIDPRU8 Disclosure here.