Shareholder Rights Directive Disclosure

Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”) (COBS 2.2B.6R), as applied in the UK, Perbak Capital Partners LLP as a firm which trades shares on regulated and comparable markets, is required to either develop and publicly disclose an engagement policy or disclose a clear and reasoned explanation of why it has chosen not to do so.

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Perbak Capital Partners LLP has chosen not to develop an engagement policy that complies with the requirements of the SRD II, as the Firm considers that it has an investment strategy that is not commensurate with the outcomes sought thereunder. Moreover, the Firm ensures that its clients are regularly and routinely apprised of the investment strategies employed by the Firm. As such, it is felt that the Firm’s clients would not expect the Firm to achieve compliance with the core requirements of the SRD II.

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Perbak Capital Partners LLP investment strategy is driven by fundamental research and portfolio construction based on quantitative analysis of individual companies. Perbak Capital Partners LLP does not seek to engage with investee companies in the manner envisaged by SRD II and the Firm does not consider that it would be constructive for the Firm or its investee companies if the Firm were to actively engage with them. However, the firm may determine its approach to stewardship on a case by case basis taking into account the best approach to optimising the returns on its investments

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For further details on any of the above information, please contact enquires@pcap.info