Temporis Capital

UK Stewardship Code and SRD II


Commitment to the UK Stewardship Code & Shareholder Rights Directive II

The UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook (“COBS”), a firm managing investments for professional clients that are not natural persons is required to disclose the nature of its commitment to the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Stewardship Code”) or, where it does not commit to the Stewardship Code, its alternative investment strategy.

The Stewardship Code is voluntary and sets out principles for effective stewardship, defined as the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries, contributing to sustainable benefits for the economy, the environment and society.

Temporis Capital Limited (the “Firm”) seeks to achieve attractive risk-adjusted returns whilst limiting volatility. The Firm’s investment activities comprise:

  • private infrastructure assets in the renewable energy and clean technology sectors; and
  • global structured and corporate credit instruments, commercial real estate loans and other direct lending opportunities.

The Firm’s credit investment strategy focuses on the analysis and management of credit risk and does not involve an activist shareholder approach.  The Firm has considered the relevance of the Stewardship Code to its investment activities and has chosen not to become a signatory.  The Firm’s investment strategies and the nature of its investments mean that its approach to stewardship differs from that of investors whose principal activities involve exercising shareholder rights in listed companies.

The Firm’s approach to responsible investment is reflected in its Environmental, Social and Governance (“ESG”) Policy and its investment processes.  The Firm is a signatory to the Principles for Responsible Investment (“PRI”), which are incorporated into its responsible investment approach. Responsible investment considerations inform the Firm’s investment decision-making and its engagement with investors, investee companies and other relevant stakeholders.

 

Shareholder Rights Directive II

The Firm has considered the applicability of the FCA’s rules implementing the Shareholder Rights Directive II (“SRD II”), including the engagement policy and related disclosure requirements in COBS 2.2B.

The Firm does not currently hold shares admitted to trading on a regulated market.  Accordingly, the Firm considers the engagement policy and related disclosure requirements under COBS 2.2B to be outside the scope of its current investment activities.

The Firm will keep this assessment under review should the nature of its investments or activities change.

 

30th September 2026