Stewardship Code Disclosure
Under Rule 2.2.3R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, Rokos Capital Management LLP (“Rokos Capital” or “the Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to disclose the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, explain its considered choice based on the Firm’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.
Rokos Capital pursues a global macro investment strategy and as such invests across a variety of asset classes and markets globally. Exposure to UK listed issuers as part of that strategy is limited and where such exposure is taken it is not typically through investment directly into individual UK equities. Therefore, whilst Rokos Capital generally supports the objectives that underlie the Code, the nature of its investment strategy is such that its provisions are not materially relevant. The Firm has therefore chosen not to commit to the Code at this time.
If you are dissatisfied with any aspect of the AIF management services provided to you by Rokos Capital Management LLP, you may write to The Compliance Department, Rokos Capital Management LLP, 23 Savile Row, London, W1S 2ET or Compliance@rokoscapital.com. We take every complaint seriously and your complaint will be handled in accordance with the relevant rules of the Financial Conduct Authority (FCA), which may differ depending upon your status, although please note that it is Rokos Capital Management LLP’s policy to aim to resolve every complaint fairly and in a timely manner. Rokos Capital Management LLP has a written internal complaints handling policy, as required by the FCA rules. You can obtain a copy of this on request, and in the event you should have cause for complaint about the AIF management services which Rokos Capital Management LLP provides, a copy of the policy will be sent to you.
In the event we fail to resolve a complaint to your satisfaction, or if we fail to do so within eight weeks of receiving your complaint, you may be entitled to refer your complaint to the Financial Ombudsman Service at Exchange Tower, Harbour Exchange Square, London, E14 9SR. Telephone: 0800 023 4 567 or at www.financial-ombudsman.org.uk.
Should you wish to carry out a market sounding, please first contact Rokos Capital Compliance on: Compliance@rokoscapital.com.
Alternatively, please call the main switchboard on +44(0)20 3668 9000 and ask to be put through to Rokos Capital’s Compliance team.
Under Rule 2.2B.5.R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, Rokos Capital Management LLP (“RCM”), is required to disclose whether it has an engagement policy in relation to the issuers of investments traded on a regulated market 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. Given RCM’s investment approach it has chosen not to have an Engagement Policy for the reasons described below.
RCM pursues a global macro investment strategy and as such invests across a variety of asset classes and markets globally. Exposure to listed issuers on regulated or comparable markets is not a material element of that strategy and where such exposure is taken it is not typically taken on an activist investor basis. Therefore, an Engagement Policy has limited applicability to RCM’s investment strategy given its limited ability to exercise stewardship. Were stewardship issues to arise RCM would take a consistent approach to engagement with issuers and their management in all the jurisdictions in which it invests and in that regard has a proxy voting policy. So whilst RCM supports the objectives that underline the rationale for development of an Engagement Policy, the nature of its investment strategy is such that it means that it is not practical for it to formally engage with investee companies or carry out shareholder engagement activities at this stage although this remains under periodic review.