Disclosures and notices
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The PFM Associates Limited (‘Firm’) Pillar 3 disclosure accessed via the link is in accordance with the Capital Requirements Directive (‘CRD’) whereby the European Union established a regulatory capital framework governing the amount and nature of capital institutions and investment firms must maintain. In the United Kingdom, the CRD has been implemented by the Financial Conduct Authority (‘FCA’) and the Firm complies with the FCA’s consequent rules contained in the Prudential Sourcebook for Banks, Building Societies and Investment Firms (BIPRU). This disclosure also includes the Firm’s Remuneration Code.
Meeting our obligations under the Revised Shareholder Rights Directive II (SRD II)
PFM Associates Limited currently run their discretionary management service using collective investments (OEICS, unit-trusts etc) only and do not invest directly in shares traded on regulated markets. However, if the Firm were to do so in the future, we are required by the Revised Shareholder Rights Directive II to explain whether or not we have an engagement policy in relation to the companies we would invest in, where the companies’ shares are admitted to trading on a regulated market. If we did so, we consider that the proportion of shares we might hold in investee companies would be much lower than those held by large institutional investors and we, therefore, would not be able to engage with investee companies to the extent envisaged by SRD II. We do not therefore have a formal engagement policy.