Rule 2.2B.5.R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook requires an authorised firm to disclose whether it has an engagement policy in relation to the issuers of investments traded on a regulated market in the EEA or comparable overseas market (the "Engagement Policy") or, where it does not comply with such requirements, to disclose why it has chosen not to do so.
Pharo Management (UK) LLP (the ‘Firm’) manages assets across a number of emerging markets strategies. The Firm does not however invest in individually listed equities. Consequently, while the Firm supports the general objectives that underlie the rationale for the development of an Engagement Policy, the nature of its investment strategy is such that its requirements are not relevant to the type of trading currently undertaken by the Firm. If the Firm's investment strategy changes in such a manner that the requirements become relevant, the Firm will amend this disclosure accordingly.