Regulatory Information

UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Tyrus Capital Alternatives LLP (the “firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's (“FRC”) Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.

The Code was first published by the FRC in July 2010 and it was updated in September 2012. Subsequently, the FRC published the new UK Stewardship Code 2020 (“2020 Code”), which took effect from 1 January 2020, and consists of 12 “Principles for asset owners and asset managers” and 6 “Principles for service providers”.

The Code generally applies on a “comply or explain” basis. As a voluntary standard, it aims to enhance the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders, and to provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.

The FRC defines “stewardship” as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.”

Whilst the firm may invest in shares traded on a regulated market (or comparable market), the resultant holdings are of an insignificant size and voting power to the extent that the firm does not actively engage with investee companies. The firm predominantly provides investment management and advisory services with a strategy of investing in real estate and fixed-income assets as well as some equities.

While the firm supports the objectives underlying the Code and adheres to the highest standards of corporate governance and due diligence in respect of its investments, the firm, having considered the 2020 Code, believe that the Principles of the Code are not applicable to its investment activities at this time. Should that change in the future, the firm will review its commitment to the Code and update this disclosure accordingly. This disclosure will be reviewed at least annually. For any questions regarding this disclosure email compliance@tyruscap.com.

Pillar 3 Disclosure

For Pillar 3 disclosure please click here.

Best Execution

For best execution disclosure please click here.

Shareholders Rights Directive II (EU) 2017/828 (“SRD II”)

Tyrus Capital Alternatives LLP is a BIPRU MiFID Manager.

Article 3g of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as Tyrus Capital Alternatives LLP to either: (a) develop and disclose an engagement policy describing how the firm integrates shareholder engagement in its investment strategy; or (b) disclose why the firm has chosen not to comply with those requirements.

If applied, an engagement policy would require a firm to describe how it:

  • integrates shareholder engagement in its investment strategy;
  • monitors investee companies on relevant matters, including: strategy, financial and non-financial performance and risk, capital structure, and social and environmental impact and corporate governance;
  • conducts dialogues with investee companies;
  • exercises voting rights and other rights attached to shares;
  • cooperates with other shareholders;
  • communicates with relevant stakeholders of the investee companies; and
  • manages actual and potential conflicts of interests in relation to the firm's engagement.

An engagement policy, if any, is limited to the extent that a firm invests on behalf of investors in shares traded on a regulated market (or on third country markets that meet comparable requirements and where the shares dealt in are of a quality comparable to those in a regulated market in the UK). Whilst the firm may invest in shares traded on a regulated market (or comparable market), the resultant holdings are of an insignificant size and voting power to the extent that the firm does not actively engage with investee companies.

Tyrus Capital Alternative LLP does not engage in meetings with investee companies and does not participate or influence the decision making of investee companies. While Tyrus Capital Alternatives LLP supports the objectives that underlie SRD II, for the reason stated the firm has chosen not to produce an engagement policy at this time.

Complaints

A “MiFID complaint” as defined by the FCA, may arise in relation to the Firm's MiFID business, which for Tyrus Capital Alternatives LLP is the provision of investment advisory and investment management services.

Please email compliance@tyruscap.com if there is any aspect of the provision of services by the firm that you are dissatisfied with.

Complaints are taken seriously and will be handled in accordance with the relevant FCA rules.

Tyrus Capital Alternatives LLP has a written complaints handling policy, details of which are available upon request from the Compliance Officer at the address listed above.

Tyrus Capital Alternatives LLP is authorised and Regulated by the Financial Conduct Authority. Tyrus Capital Alternatives LLP is registered in England and Wales at 5 Savile Row, London W1S 3PB. Companies House Number: OC368757