Stewardship Code

Under the Financial Conduct Authority’s (‘FCA’) Conduct of Business Rules 2.2A.5, Pamplona Capital Management LLP is required to make a public disclosure on its website in relation to the nature of its commitment to the Financial Reporting Council’s (‘FRC’) Stewardship Code.

The Code was first published by the FRC in July 2010 and it was updated in September 2012 with a further update in June 2025. Subsequently, the FRC published the new UK Stewardship Code 2026 (“2026 Code”), which took effect from 1 January 2026, and consists of six Principles for asset managers and asset owners, and four Principles for service providers.

The Code applies on a ‘comply or explain’ basis and is voluntary, aiming at enhancing the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.

The FRC defines ‘stewardship’ as “the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries.”

The 2026 Code Principles for asset managers and asset owners are:

  1. Signatories integrate stewardship and investment to deliver long-term sustainable value for their clients and beneficiaries.
  2. Signatories identify and respond to market-wide and systemic risks to promote well -functioning financial markets.
  3. Signatories engage to maintain or enhance the value of assets.
  4. Signatories actively exercise their rights and responsibilities.
  5. Signatories integrate stewardship considerations into their selection and oversight of external managers.
  6. Signatories monitor and hold to account stewardship service providers

Whilst supporting the objectives underlying the Code and adhering to the highest standards of corporate governance and due diligence in respect of its investments the Firm, having considered the 2026 Code, believes that the Principles are not applicable to its investment activities at this time. Should that change in the future, the Firm will review its commitment to the Code and update this disclosure accordingly. This disclosure will be reviewed at least annually. For any questions regarding this disclosure email info@pamplonafunds.com

Disclosure last updated: 03/11/2025