Contact
Melqart Asset Management
5 St James’s Square,
London SW1Y 4JU
5 St James’s Square,
London SW1Y 4JU
T +44 (0)20 3826 4470
info@melqart.com
T +44 (0)20 3826 4470
info@melqart.com
Melqart Asset Management (UK) Limited’s SRD II Disclosure
The Shareholders Rights Directive EU 2017/828 (“SRD II”) amended the original Shareholder Rights Directive to strengthen shareholder engagement and increase transparency for asset managers and owners. It came into force on 09 June 2017 and most of its provisions were implemented into national law by 10 June 2019 and those on the identification of shareholders and communication with shareholders through intermediaries by 3 September 2020.
The firms in scope under SRD II are asset managers with a trading strategy that includes investing in shares traded on EEA and other comparable markets. Asset managers for these purposes include MiFID managers, full scope AIFMs, and UCITS schemes and management companies and these will set out as per COBS 2.2B.7R an engagement policy as regards to engagement with investee companies, the related processes and requirements relevant to UK firms.
Transparency for SRD Institutional Investors
Melqart Asset Management (UK) Ltd (“Melqart” or the “Firm”) has elected not to comply with the requirements and obligations of SRD II, but where it manages assets on a discretionary basis in a segregated account or through a collective investment undertaking for ‘SRD institutional investors’ (broadly, EEA occupational pension schemes or life assurance clients), additional client-by-client disclosures are required irrespective of whether the Firm elects to disclose an engagement policy.
As a result, the Firm, on an annual basis, undertakes an evaluation to determine if it has any SRD institutional investors and if appropriate, will disclose to the relevant SRD institutional investor, how its investment strategy and its implementation:
In addition, the annual disclosure must include the following information:
Where the presence of such an investor cannot be readily ascertained, the Firm must be able to provide this information upon request.
The annual disclosure (COBS 2.2B.7 R) should include a summary of the implementation of the firm’s engagement policy, together with a general description of voting behaviour in the period, an explanation of the most significant votes and reporting on the use of the services of proxy advisors.
The Firm’s Voting Behaviour
The Firm is authorised, in its absolute discretion, to exercise or refrain from exercising any voting or other rights attaching to the investments comprising the relevant client’s portfolio. The exercise (or otherwise) of voting or other rights as are applicable to the shares of investee companies is considered in the performance of the Firm’s investment strategy. Each such exercise of a voting or other right is assessed in light of each client’s objectives at that time as well as the Firm’s opinion of the matter on which voting rights are capable of exercise. Therefore, the Firm’s voting policy is not prescribed as each vote is considered on an individual basis, taking into account many factors.
The Firm’s investment team reviews various different aspects of the investee companies. These include, amongst other things, matters of financial and non-financial performance, capital structure, social and environmental impact and corporate governance. The Firm’s investment team may actively monitor and engage with the management of its investee companies and regularly meet the representatives of such companies. These meetings are useful, not only to better understand the companies’ perceptions of matters, but also to allow the Firm to provide constructive feedback. The Firm considers the meetings with the executive management of investee companies to be a highly effective mechanism for raising matters that are of concern.
Occasions on which the Firm participates in collective action are likely to be infrequent as one-to-one meetings are usually an effective means of drawing the attention of companies to the Firm’s concerns. Melqart will consider consulting and/or cooperating with other shareholders where such action is believed by the Firm to be in the best interests of the Firm’s clients and having considered potential conflicts of interest in relation to the Firm’s engagement. For example, the Firm may feel that a one-to-one discussion with an investee company is not achieving adequate progress or the matters are of such severity that a collective approach is considered to be the most effective way of influencing a company’s directors; prior to such participation the Firm will consider whether it is to the overall benefit of Melqart’s clients and that action outweighs potential adverse consequences that may arise from such involvement.
Melqart, as a Full Scope AIFM, has evaluated the SRD II requirements and does not consider it in the best interests of the Firm’s clients to publicly disclose its policy in relation to shareholder engagement; however, the Firm does take these matters seriously in how it conducts its business on behalf of its clients and the Firm’s general approach has been outlined above.
The Firm aims to its conduct business according to the principle that it must at all times act in the best interests of its clients and manage conflicts of interest fairly, both between the Firm and its clients and between one client and another.
For further information on the Firm’s approach contact: compliance@melqart.com
Melqart Asset Management (UK) Limited’s ESG Policy
Melqart Asset Management (UK) Ltd (“Melqart” or the “Firm”) has implemented an Environmental, Social and Governance policy (“ESG Policy”) which will apply at both a firm level and also in respect of its investment management activities when investing on behalf of its clients. The purpose of this ESG Policy is to outline the methods through which Melqart has implemented its ESG Policy and adheres to the principles within its internal corporate operations as well as within its fund management activities. ESG issues are a reality and have been wrongly tolerated for a long time both by society generally and specifically the investment management community. Melqart believes that continuing in this laissez faire fashion will create significant problems for future generations and therefore wants to be part of shaping the future for the better.
By holding investee companies and service providers accountable for the impact they have with respect to ESG factors, the Firm hopes to influence them to change their behaviour positively; specifically to make them actively address the ESG issues that each faces such that each of them makes a positive contribution to the future. It is also important that the Firm exercises its right to divest holdings in investee companies and terminate service provider relationships to ensure that each understands the importance that the Firm attaches to ESG issues.
Melqart is a voluntary adherent to the UNPRI principles which are set out in Schedule 1 and is currently looking at how its ESG Policy may evolve in the future and how Melqart may become a signatory to the UNPRI principles.
This ESG Policy is reviewed at least annually by both the Firm’s Risk Committee and Board of Directors. The CIO is ultimately responsible for the implementation of the ESG Policy with respect to the investment portfolios. The Firm’s Risk Committee is responsible for the implementation of the ESG policy with respect to the operations of the Firm.
ESG assessment is a core component of developing an investment thesis and is integrated into the Firm’s risk management framework.
Investment Management
This ESG Policy sets out how we adhere to the following principles as they relate to responsible investing whilst carrying out investment management activities on behalf of our clients:
In applying these principles, we strive to be both principled and pragmatic whilst taking into account industry norms, corporate performance, competitive issues, regulatory requirements and other factors necessary to put specific issues into a fair and practical context.
With respect to portfolio construction, Melqart aspires to integrate the ESG Policy into the investment management processes for all asset classes within the portfolio as responsible corporate behaviour with respect to ESG factors can generally have a positive influence on long-term financial performance. Each investment case prepared by Melqart’s investment team must include an assessment of the environmental, social and governance impact and therefore ESG factors form an integral part of the investment process. Due to the size of the Firm’s business there is no dedicated personnel for ESG matters but every member of the investment team is responsible for incorporating ESG factors into their research and the CIO is responsible for oversight and implementation of the policy from an investment management perspective.
Melqart is currently in the process of evaluating the following third-party services for ESG data evaluation with a view to integrating one of these into the Firm’s investment process shortly:
When the Firm has finished its evaluation, the chosen third-party service provider will be used by the investment team to assess the ESG factors inherent within each investment thesis. Further to the completion of the evaluation process and implementation of the system, ESG risk limits are to be determined by the Risk Committee and integrated into the Firm’s risk management framework and monitored by the CIO and Risk Manager on a daily basis and reviewed by the Risk Committee on a monthly basis.
The Firm’s investment team reviews various different aspects of the investee companies. These include, amongst other things, matters of financial and non-financial performance, capital structure, social and environmental impact and corporate governance. The Firm’s investment team may actively monitor and engage with the management of its investee companies and regularly meet the representatives of such companies. These meetings are useful, not only to better understand the companies’ perceptions of matters, but also to allow the Firm to provide constructive feedback. The Firm considers the meetings with the executive management of investee companies to be a highly effective mechanism for raising matters that are of concern.
Occasions where the Firm participates in collective action are likely to be infrequent as one-to-one meetings are usually an effective means of drawing the attention of companies to the Firm’s concerns. Melqart will consider consulting with other shareholders where such action is believed by the Firm to be in the best interests of the Firm’s clients, having considered potential conflicts of interest in relation to the Firm’s engagement. For example, the Firm may feel that a one-to-one discussion with an investee company is not achieving adequate progress or the matters are of such severity that a collective approach is considered to be the most effective way of influencing a company’s directors; prior to such participation the Firm will consider whether it is to the overall benefit of Melqart’s clients and that action outweighs potential adverse consequences that may arise from such involvement.
Furthermore, the CIO assesses the exposure to climate risk of each position in the portfolio, both at the time the position is originally put on and on an ongoing basis. The Firm does not monitor the carbon footprint of the investment portfolio as reliable data sources for quantifying the carbon footprint of the portfolio are not currently available.
Melqart does not screen stocks or eliminate investments based on ESG factors but Melqart considers the securities of any issuer whose businesses are lawful as eligible for investment.
Melqart will not knowingly invest directly in securities (equity or debt) of listed companies involved in the manufacture, development or trade of anti-personnel mines or cluster munitions or components or services of the core weapon system which are considered tailor-made and essential for the lethal use of the weapon. These weapons are subject to international and national laws and are of concern due to humanitarian consequences and the unacceptable harm caused to civilians through their use.
The Anti-personnel Landmines Convention 1997 bans the use, stockpiling, production and transfer of anti-personnel mines and prohibits assisting others in these prohibited acts. This treaty is enforced in UK law through the Landmines Act 1998.
The Convention on Cluster Munitions 2008 bans the use, production, stockpiling and transfer of cluster munitions. Countries that have signed the Convention undertake “never under any circumstances to assist, encourage or induce anyone to engage in any activity prohibited”. This treaty is enforced in the UK via the Cluster Munitions (Prohibitions) Act 2010.
This ESG Policy applies to any fund where Melqart has the discretion over security selection and applies to long and short positions in companies that manufacture, develop or trade in the core weapon systems which are components or services that are tailor-made and essential for the lethal use of the weapon.
Melqart is authorised, in its absolute discretion, to exercise or refrain from exercising any voting or other rights attaching to the investments comprising the relevant client’s portfolio. The exercise (or otherwise) of voting or other rights as are applicable to the shares of investee companies is considered in the performance of the Firm’s investment strategy. Each such exercise of a voting or other right is assessed in light of each client’s objectives at that time as well as the Firm’s opinion of the matter on which voting rights are capable of exercise. Therefore, the Firm’s voting policy is not prescribed as each vote is considered on an individual basis, taking into account many factors.
Corporate Responsibility
Melqart aims to manage and minimise its corporate environmental footprint by engaging in activities and initiatives which are environmentally responsible. Melqart builds environmental awareness internally by encouraging all employees to recycle where possible by providing the resources needed to do so. Melqart also discourages the use of single use plastics such as cups and cutlery by providing glassware and crockery which are reused. Printing is discouraged unless necessary.
Melqart will promote respect for and protection of human rights and safe and healthy work conditions. Melqart will not tolerate violations and abuse of human rights, discrimination based on race, gender, sexual orientation, religion or age or business practices considered generally unethical and unacceptable. All staff undertake Equality and Diversity training modules upon joining the Firm, and thereafter on an annual basis which reinforces the Firm’s culture with regards to how employees should behave.
Melqart advocates responsible management throughout the Firm and views openness, honesty and accountability as key parts of its governance framework. This is covered in the Staff Handbook.
Schedule 1 – UNPRI Principles for Responsible Investment
The six Principles for Responsible Investment are a voluntary and aspirational set of investment principles that offer a menu of possible actions for incorporating ESG issues into investment practice.
The Principles were developed by investors, for investors. In implementing them, signatories contribute to developing a more sustainable global financial system. They have attracted a global signatory base representing a majority of the world’s professionally managed investments.
Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.
Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.
Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.
Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.
Principle 5: We will work together to enhance our effectiveness in implementing the Principles.
Principle 6: We will each report on our activities and progress towards implementing the Principles.
For further information on the Firm’s approach contact: compliance@melqart.com
Complaints Handling Procedure
Melqart Asset Management (UK) Ltd.’s complaints handling procedure is in line with Financial Conduct Authority’s rules regarding complaints handling. A copy of Melqart’s Complaints Policy is available upon request, please contact: compliance@melqart.com
Complaints may be made to Melqart by the following means:
By email: compliance@melqart.com
In writing addressed to:
Compliance Officer
Melqart Asset Management (UK) Ltd
5 St James’s Square
London
SW1Y 4JU
United Kingdom
A complainant may also have the right to take their complaint to the Financial Ombudsman Service. More information can be found in the Complaints Policy.
The Financial Ombudsman Service can be contacted at:
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk
Privacy Notice
Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Melqart Asset Management (UK) Ltd (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.
How we collect information about you
We may collect personal data about you through:
We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks
Why we collect information about you
We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.
We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we or a third party determine that is necessary for our legitimate interests to collect and use your personal information.
The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.
What are the consequences of failing to provide your personal information?
As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).
We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.
A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.
The types of personal data we may collect and use
The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, as well as special categories of data, such as biometric data, information about a person’s ethnic origin, religious beliefs, health, or other sensitive information.
Do we use automated decision-making processes?
No.
Do we share your personal information with third parties?
We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:
Transfers of personal information to countries outside of the European Economic Area (EEA)
Due to the international nature of our business, your personal data may be transferred to countries outside of the UK or the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation, the UK Data Protection Act 2018 and other data protection rules applicable to us (collectively, “Data Protection Laws”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of such Data Protection Laws, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.
For how long do we keep your personal information?
We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.
The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.
We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.
What are your rights?
You have certain rights under Data Protection Laws in respect of the personal data we hold about you and which you may exercise. These rights are:
How to contact us
If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Compliance Officer by email at compliance@melqart.com or by writing to Melqart Asset Management, 5 St James’s Square, London SW1Y 4JU, United Kingdom.
Complaining to ICO
You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website https://ico.org.uk/
Recording and monitoring of communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of:
Recording of Telephone Conversations and Electronic Communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of: (1) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (2) ensuring compliance with our regulatory obligations; and (3) detecting and preventing the commission of financial crime. Copies of recordings will be stored for a period of five years, or such longer period as may be determined by Melqart. For further information relating to how we use the information we collect, please refer to our Privacy Notice.
Melqart Asset Management (UK) Limited Pillar 3 Risk Disclosure
Melqart Asset Management (UK) Limited (“Melqart” or the Firm) is required by the FCA to disclose information relating to the capital it holds and each material category of risk it faces in order to assist users of its accounts and to encourage market discipline.
The Capital Requirements Directive (CRD) created a revised regulatory capital framework across Europe covering how much capital financial services firms must retain. In the United Kingdom, rules and guidance are provided in the General Prudential Sourcebook (GENPRU) for Banks, Building Societies and Investments Firms (BIPRU).
The FCA framework consists of three “Pillars”:
Rule 11 of BIPRU sets out the provisions for Pillar 3 disclosure. The rules provide that companies may omit one or more of the required disclosures if such omission is regarded as immaterial. Information is considered material if its omission or misstatement could change or influence the decision of a user relying on the information. In addition, companies may also omit one or more of the required disclosures where such information is regarded as proprietary or confidential. The Firm believes that the disclosure of this document meets its obligation with respect to Pillar 3.
Firm Overview
Melqart is incorporated in the UK and is authorised and regulated by the FCA as a Full Scope Alternative Investment Fund Manager and is categorised by the FCA for prudential regulatory purposes both as a Collective Portfolio Management Firm (“CPMI”) and a BIPRU firm.
The Board of Melqart has the daily management and oversight responsibility. It generally meets quarterly and is composed of:
The Board is responsible for the entire process of risk management, as well as forming its own opinion on the effectiveness of the process. In addition, the Board decides Melqart’s risk appetite or tolerance for risk and ensures that Melqart has implemented an effective, ongoing process to identify risks, to measure its potential impact and then to ensure that such risks are actively managed. Senior Management is accountable to the Board for designing, implementing and monitoring the process of risk management and implementing it into the day-to-day business activities of Melqart.
Capital Resources and Requirements
Pillar 1
Melqart was authorised by the FCA on 22 September 2015 and holds regulatory capital resources of £500,000, comprised solely of core Tier 1 capital of share capital contributions.
The Firm has calculated its BIPRU capital resources in accordance with GENPRU 2.2:
As a limited company its capital arrangements are as follows:
| £000 | |
| Share Capital | £500 |
| Audited reserves | £0 |
| Hybrid Capital | £0 |
| Tier 2 Capital | £0 |
| Total | £500 |
The firm is required to as a CPMI firm to maintain at all times ‘own funds’ which equal or exceed the higher of:
As at 31 December 2016, the Firm’s Pillar 1 capital requirement was £306,630.
Satisfaction of Capital Requirements
Pillar 2
The Firm has adopted the “Structured” approach to the calculation of its Pillar 2 Minimum Capital Requirement as outlined in the Committee of European Banking Supervisors Paper, 27 March 2006 which takes the higher of Pillar 1 and 2 as the ICAAP capital requirement. It has assessed Business Risks by modelling the effect on its capital planning forecasts and assessed Operational Risk by considering if Pillar 2 capital is required taking into account the adequacy of its mitigation.
Since the Firm’s Internal Capital Adequacy Assessment Process (ICAAP or Pillar 2) has not identified capital to be held over and above the Pillar 1 requirement, the capital resources detailed above are considered adequate to continue to finance the Firm over the next year. No additional capital injections are considered necessary and the Firm expects to continue to be profitable.
Risk Management
The Firm has established a risk management process in order to ensure that it has effective systems and controls in place to identify, monitor and manage risks arising in the business. The risk management process is overseen by the Firm’s senior management.
As risks are identified within the business, appropriate controls are put in place to mitigate these and compliance with them is monitored on a regular basis. The frequency of monitoring in respect of each risk area is determined by the significance of the risk. The Firm does not intend to take any risks with its own capital and ensures that risk taken within the portfolios that it provides advice to is closely monitored. The results of the compliance monitoring performed is reported to the partners by the Compliance Officer.
Operational Risk
The Firm places strong reliance on the operational procedures and controls that it has in place in order to mitigate risk and seeks to ensure that all personnel are aware of their responsibilities in this respect.
The Firm has identified a number of key operational risks. These relate to disruption of the office facilities, system failures, trade failures and failure of third party service providers. Appropriate policies are in place to mitigate against risks, including appropriate insurance policies and business continuity plans.
Credit Risk
The main credit risk to which the Firm is exposed is in respect of the failure of its debtors to meet their contractual obligations. The majority of the Firm’s receivable is related to investment management activities. The Firm believes its credit risk exposure is limited since the Firm’s revenue is ultimately related to management fees received from funds. These management fees are drawn throughout the year from the funds managed. Other credit exposures include bank deposits and office rental deposits.
The Firm undertakes periodic impairment reviews of its receivables. All amounts due to the Firm are current and none have been overdue during the year. As such, due to the low risk of non-payment from its counterparties, management is of the opinion that no provision is necessary. A financial asset is overdue when the counterparty has failed to make a payment when contractually due. Impairment is defined as a reduction in the recoverable amount of a fixed asset or goodwill below its carrying amount.
The Firm has adopted the standardised approach to credit risk, and therefore follows the provision within BIPRU 3 standardised credit risk of the FCA handbook. The Firm applies a credit risk capital component of 8% to its non-trading book risk weighted exposure. As the Firm does not make use of an external credit rating agency, it is obligated to use a risk weight of 100% to all non-trading book credit exposures, except cash and cash equivalents which are held by investment grade firms and currently attract a risk weighting of 20%.
The table below sets forth the Firm’s credit exposures and corresponding capital resource requirements as at the date of its ICAAP assessment:
| Capital | £ |
| Funds under management requirement (a) | £203,087 |
| Fixed overheads requirement(b) | £285,969 |
| Credit risk + Market Risk (c) | £72,788 |
| PII defined excess (d) | £20,661 |
| Total Capital requirements (a) or (b) or (c) PLUS (d) | £306,630 |
| Surplus | £193,470 |
| Solo Basis | Credit Exposure | Risk weighted Exposure |
| National Governments | £0 | £0 |
| Tangible fixed assets | £22,952 | £22,952 |
| Due from affiliates – within 3 months | £0 | £0 |
| Due from affiliates – after 3 months | £0 | £0 |
| Cash at bank | £250,761 | £50,152 |
| Prepayments | £627,862 | £627,862 |
| Other | £208,881 | £208,881 |
| —- | —- | |
| Total | £1,110,456 | £909,847 |
| === | === | |
| Credit Risk Capital Component (8% of risk weighted exposure) | £72,788 |
Market Risk
Since the Firm holds no trading book positions on its own account, and all fee income is converted to GBP, the Firm’s exposure to foreign currency risk is not significant. Since the settlement of debtor balances take place without undue delay, the timing of the amount becoming payable and subsequently being paid is such that it is not considered to present a material risk to the Firm. The Firm has excluded Market risk on the basis that it is not a material risk to the Firm.
Remuneration Code
The Firm has adopted a remuneration policy and procedures that comply with the requirements of chapter 19B of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (SYSC), and in accordance with ESMA’s Guidelines on sound remuneration policies. The Firm have considered all the proportionality elements in line with the FCA Guidance.
As a UK AIFM the Firm has assessed the proportionality elements and disapplies the Pay Out Rules. Furthermore, the Firm has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the Board sets, and oversees compliance with, the Firm’s remuneration policy including reviewing the terms of the policy at least annually.
Remuneration disclosure
The Firm is a Remuneration Code Proportionality Level 3 Firm and applied the rules appropriate to its Proportionality Level. The Board is responsible for the Firm’s remuneration policy. All variable remuneration is adjusted in line with capital and liquidity requirements.
Remuneration Code Staff Remuneration by Business Area
| Business Area | Total Remuneration |
| Investment Management | £913,364 |
Aggregate Quantitative Remuneration by Senior Management and other Remuneration Code Staff
| Type of Remuneration Code Staff | Total Remuneration |
| Senior Management (SIF) | £123,911 |
| Other Remuneration Code Staff | £789,543 |
| Total | £913,364 |
Melqart Asset Management (UK) Limited’s Commitment to the UK Stewardship Code
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Melqart Asset Management (UK) Limited (the “Firm”) is required to include on this website a disclosure about 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, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance and state in general terms its alternative investment strategy.
The seven principles of the Code are that institutional investors should:
The Firm provides investment management services to various funds (“the Funds”) that pursue investment strategies that involve investing in a wide range of securities and instruments without limitation in various jurisdictions. If the Firm were to invest directly in UK single equities these would represent only a small part of the firm’s business. Hence, while the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The approach of the Firm in relation to engagement with issuers and their management is determined globally. The Firm takes a consistent approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.
For further information on the Firm’s approach contact: compliance@melqart.com
Modern Slavery Statement
Melqart Asset Management (UK) Ltd (“Melqart” or the “Firm”) has made the following statement on modern slavery and human trafficking pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”).
The Act sets out a range of measures on how modern slavery and human trafficking should be dealt with in the UK to combat modern slavery from occurring in business supply chains and organisations.
Business and Organisation Structure
Melqart is an investment manager which is authorised and regulated by the UK Financial Conduct Authority (“FCA”) to undertake investment management activities on behalf of its clients, which are a range of collective investment schemes classified as Alternative Investment Funds (AIFs) under the Alternative Investment Fund Managers Directive (“AIFMD”).
Our policy
Melqart firmly believes in operating its business in an ethical manner and with high standards of integrity as expected of an FCA regulated entity. We are opposed to the use of any supply chains and services which may involve slavery, human trafficking or forced labour. To the best of our knowledge we believe this is not the case, but in the unlikely event that anything of this nature is identified then we reserve the right to take the necessary action, which includes a duty to notify the UK Home Office and termination of the relevant contract.
Supply Chain Review and Due diligence
Melqart does not deal in manufactured items, hard goods, and it does not have offices in any developing countries, nor does it purchase any goods from developing countries.
Our review has concluded that the services we provide and the supply chains which are used by Melqart are highly unlikely to involve any human trafficking or slavery.
As Melqart is involved in investment management, it only has a limited supply chain, and this involves the use of reputable service providers.
Risk Assessment
Melqart has reviewed its existing supply chain and service providers and believes the perceived level of risk is low.
Controls and Review Process
Melqart uses only reputable service providers and suppliers. As part of its on-boarding process we will review any supplier and request information on their hiring process and working practices. We will also confirm with the potential supplier our strict prohibition on the use of any supply chains and services which may involve slavery, human trafficking or forced labour. Melqart will undertake periodic reviews of its suppliers where it appears there is a potential risk involving a service provider.
This statement will be reviewed annually and where necessary this will be updated to reflect any changes in our practices regarding the use of supply chains and services that could be impacted.