Engagement policy statement

We are required to develop and publicly disclose an engagement policy which complies with the requirements set out in the FCA’s Conduct of Business Sourcebook and publicly disclose on an annual basis how that engagement policy has been implemented in a way that meets the requirements (including disclosure of certain of voting activities in respect of shares in investee companies) or to publish a clear and reasoned explanation of why we have chosen not to comply with any such requirements. The engagement policy would describe how TAM:

• integrates shareholder engagement in its investment strategies;
• monitors investee companies on relevant matters (e.g. strategy, financial and non-financial performance and risk, capital structure, social and environmental impact and corporate governance);
• conducts dialogues with investee companies;
• exercises voting and any other shareholder rights;
• cooperates with other shareholders;
• communicates with relevant stakeholders of investee companies;
• manages actual and potential conflicts of interests in relation to TAM’s engagement.

Since direct equity investments make up a small proportion (less than ten percent) of the assets we manage, we have decided not to publish an engagement statement, as we believe that it is unlikely to provide a useful resource for investors to judge how we have added value to the portfolios we manage.

However we have a robust investment process which seeks to achieve similar aims. Investments are selected by our investment committee. The members of the committee are an experienced, highly qualified and diverse group. They have access to sufficient qualitative and quantitative data sources to reach informed decisions. Debate and independent thought is encouraged and remuneration is not linked to investment performance. We have effective policies in place to manage conflicts of interest.

We monitor the assets in the portfolios we manage for their level of risk, including non-financial risk, and their alignment with the portfolio mandate and the needs and preferences of the underlying investors. We will engage with external fund managers and with companies where we believe that such action is in the interest of our investors, and are happy to cooperate with other firms in such activity. We will seek to vote on issues where we believe such action will potentially have a material impact on the risk or return of an investment, and will exercise other rights (including conversion and subscription rights) in the best interest of our clients.

06 September 2024