UK Stewardship Code (2026) Disclosure Statement

January 2026
Palliser Capital (UK) Ltd
(“Palliser” / the “Firm”)

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, 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 sets out a number of principles relating to engagement by asset managers or asset owners across all asset classes including, for example, listed equity, fixed income, private equity, infrastructure investment and in investments outside the UK.

Adherence to the Code is voluntary.

The six principles of the Code for Asset owners and Asset Managers (in our case, Asset Managers) are as follows: 

Purpose and governance

1. Purpose, strategy and culture
   Asset Managers should articulate a clear purpose, strategy and culture that support effective stewardship and the creation of long-term value for clients and beneficiaries, leading to sustainable benefits for the economy, the environment and society. 
   
2. Conflicts of Interest & Duty to Clients/Beneficiaries
   Asset Managers should identify, manage and disclose conflicts of interest in a manner that prioritises the best interests of clients and beneficiaries.
   
3. Systemic Risk & Market Stewardship
   Asset Managers should identify, monitor and respond to market-wide and systemic risks, contributing to the promotion of well-functioning and sustainable financial markets. 
   
4. Governance, Oversight & Effectiveness
   Asset Managers should maintain effective governance, resourcing and oversight of their stewardship activities, and regularly review, assure and assess the effectiveness of their policies, processes and outcomes. 
   
5. Stewardship in Investment & Integration
   Asset Managers should integrate stewardship into their investment approach, taking account of client and beneficiary needs and communicating clearly the activities undertaken and outcomes achieved through stewardship.
   

1. Engagement, Escalation & Rights
   Asset Managers should undertake effective engagement with issuers, escalate stewardship activities where necessary, and exercise rights and responsibilities to promote long-term value across all relevant asset classes. 
   

While Palliser generally supports the objectives that underlie the Code, The Firm determines its approach to stewardship on a case by case basis taking into account the best approach to optimising the returns on its investments.

For further details on any of the above information, please contact Jeremy White.

The Firm will review this position annually and update this disclosure accordingly if the provisions of the Code become relevant.