About us

Stewardship Codes 2019

New College Capital Limited’s (“NCC”) main activity is providing investment advice to high net worth individuals, managing funds and investment portfolios.

We recognise our wider stewardship responsibilities and to this end support the introduction of the FRC UK Stewardship Code (“Code”), which sets out the responsibilities of Investment managers. This statement sets out how NCC applies the seven principles of the Code.

Principle 1

Investment managers should publicly disclose their policy on how they will discharge their stewardship responsibilities.

This document records NCC’s policy in relation to the Code and is publicly available on our Website.

Principle 2

Investment managers should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.

NCC has a robust policy on managing conflicts of interest with the overriding requirement that NCC acts in the best interests of its clients and prevents any conflicting interests. Copies of the conflicts of interest policy are provided to all clients and can be provided to potential clients on request.

Principle 3

Investment managers should monitor their funds and porfolio companies.

A core part of our investment research process is to research and analyse all aspects of the business of our funds and portfolio companies. We continue to monitor and analyse the managers of our funds and the directors of our portfolio companies after the initial decision to invest, as well as continuing to monitor the fundamentals based on publicly available information, company reports, external research, and news flows etc.

Principle 4

Investment managers should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.

Whilst great emphasis is placed on monitoring and analysing the funds, NCC’s approach is generally not to engage in shareholders’ activism campaigns against individual funds or portfolio companies. When a company proposes or takes a course of action which we consider to be detrimental to the interests of shareholders, we may attempt to open discussions, however we would probably sell our investments in the company.

Principle 5

Investment managers should be willing to act collectively with other investors where appropriate.

Where we consider it appropriate on a case by case basis, NCC may act in co-operation with other investors to promote good governance of the funds. However as noted above we do not as a matter of course engage in shareholder activism.

Principle 6

Investment managers should have a clear policy on voting and disclosure of voting activity.

NCC does not vote routinely. We will vote where we believe it is important to shareholder value. NCC does not publicly disclose voting records as we believe that information to be confidential to our clients.

Principle 7

Investment managers should report periodically on their stewardship and voting activities.

Where we have agreed with or have been instructed by our clients we would provide details of our voting activities to the clients concerned.

We report at least annually to our Board of Directors on the applicability of this document to NCC’s stewardship activities, and make any changes recommended by the Board at those meetings.

Where the Firm invests in UK listed equities on behalf of its clients, it has the general policy of voting with management.

NCC’s alternative approach to stewardship and governance surrounding its consulting and fiduciary management activities are as follows:

NCC Investment Product Evaluation Team (PET) aims to formulate and maintain a list of investment products. Continuous review of the products universe ensures suitability of products to the needs, objectives and constraints of our clients' investment objectives. Members of the PET team review the sustainability of the strategy, team structure and governance of individual funds through regular manager meetings and a thorough a due diligence process.

NCC is continually striving to improve the performance of its clients' portfolios and sees stewardship and governance as integral to its approach in achieving this.