The UK Stewardship Code
Kola Capital LLP is registered by the Financial Conduct Authority under FCA Register number: 533849.
Registered in England and Wales under Companies House register number: OC355126. This can be confirmed
by visiting the Financial Conduct Authority website at www.fca.org.uk/register or by contacting the FCA on
0800 111 6768.
Kola Capital LLP
UK Stewardship Code Disclosure Statement
COBS 2.2 of the FCA Handbook requires Kola Capital LLP to make a public disclosure demonstrating
our commitment to the above Code (published in July 2010 by the Financial Reporting Council)
The Code aims to enhance the quality of engagement between institutional investors and companies
to help improve long-term returns to shareholders and the efficient exercise of governance
responsibilities. It sets out good practice on engagement with investee companies and is to be applied
by firms on a “comply or explain” basis.
The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that
smaller institutions may judge some of the principles and guidance to be disproportionate. It is of
course legitimate for some asset managers not to engage with companies, depending on their
investment strategy, and in such cases, firms are required to explain why it is not appropriate to
comply with a particular principle.
The seven principles of the Code are that institutional investors should:
1. Publicly disclose their policy on how they will discharge their stewardship responsibilities;
2. Have and publicly disclose a robust policy on managing conflicts of interest in relation to
3. Monitor their investee companies;
4. Establish clear guidelines on when and how they will escalate their activities as a method of
protecting and enhancing shareholder value;
5. Be willing to act collectively with other investors where appropriate;
6. Have a clear policy on voting and disclosure of voting activity; and
7. Report periodically on their stewardship and voting activities.
Kola Capital LLP does not currently comply with the Code for the following reasons:
Kola does not regularly exercise voting rights but does actively monitor and engage with the
management of its investee companies. Voting requests are assessed on their individual merits and in
light of the relevant fund’s objectives at that time as well as the investment manager’s opinion of the
situation. Kola’s voting policy is not prescribed, and it does not report on its stewardship or voting
Shareholder Rights Directive (SRD II)
SRD II aims to promote effective stewardship and long-term investment decision making, in respect
of shares traded on EEA regulated markets and comparable regulated markets outside the EEA. It
came into effect on 10 June 2019.
The rules require asset managers, who invest in shares traded on a regulated market detailed above,
 Publish their shareholder engagement policy (or explain why they don't have one) -
COBS 2.2B.5R.
 Make annual public disclosures relating to the implementation of their shareholder
engagement policy, from 10 June 2020 - COBS 2.2B.5R.
 Make disclosures to asset owners, including how their investment strategies contribute
to the medium to long term performance of their assets - COBS 2.2B.9R.
Kola provides discretionary investment management services to a variety of clients, including
institutional investors.
Under COBS 2.2B.5R of the FCA Handbook we are required to publish our shareholder engagement
policy together with an annual public disclosure in relation to our implementation of this policy on
our website.
Kola’s shareholder engagement policy can be found at the following link
this policy is reviewed at least annually to ensure that it continues to reflect Kola’s approach to
shareholder engagement.