Market Soundings
Should you wish to approach the Firm in relation to a market sounding, please contact compliance@dlpartners.com
UK Stewardship Code
Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, an FCA authorised firm managing investments for a professional client is required to disclose a statement about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code is a voluntary code and sets out a number of principles relating to investor engagement. 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 approach. The Firm, on behalf of its clients, seeks global investment opportunities pursuant to a variety of investment strategies. Investments may be made in a variety of asset classes and in a variety of jurisdictions globally. The Code may therefore be relevant to some aspects of the Firm’s business. Depending on the investment strategy, security or instrument type, corporate governance can be an important factor to take into account in the investment process. The Firm’s general approach is to exercise underlying clients’ rights as a shareholder in a manner that seeks to serve clients’ best interests, as determined by the Firm in its discretion, taking into account relevant factors, including, but not limited to, the impact on the value of the securities and the anticipated costs and benefits associated with any proposal to be put to a vote. The Firm takes a global approach to investing and, while the Firm generally supports the objectives that underlie the Code, it is not considered appropriate to commit to a particular voluntary code of practice relating to a specific jurisdiction.
Shareholder Rights Directive II
Under Rule 2.2B.5R of the FCA’s Conduct of Business Sourcebook, an FCA authorised firm investing in shares on behalf of investors is required to:
The Firm, on behalf of its clients, seeks global investment opportunities pursuant to a variety of investment strategies, and a significant part of its business may involve investments in instruments other than shares, including investments in swap positions. In these cases, opportunities for shareholder engagement are more limited than physical shareholdings (for example, a swap holder is not entitled to vote at general meetings of the issuer) and the Firm accordingly does not consider it appropriate to commit to a formal engagement policy or to publicly disclose voting behaviour or related matters. The Firm nonetheless supports the general principles of shareholder engagement and, where it is considered to be in the best interests of its investors, engages with investee companies to provide feedback on matters that are believed to impact investment performance, including on environmental, social and governance issues. Such engagement is typically conducted in the form of calls or meetings with company representatives, correspondence with company management and voting. The Firm’s position remains under review and appropriate updates to this disclosure will be made in the event of a material change in approach.
Form N-PX
Pursuant to Rule 14Ad-1 under the US Securities Exchange Act 1934 (the “Exchange Act”), “institutional investment managers” that are required to file reports under Section 13(f) of the Exchange Act, are also required to report their proxy voting record with respect to certain shareholder advisory votes on executive compensation (say-on-pay votes) effective as of 1 June 2024. A link to the Firm’s proxy voting records can be found here. Proxy Voting records can also be made available on request to compliance@dlpartners.com.
Law and Jurisdiction
These Terms and any and all disputes or claims arising out of or in connection with them (whether contractual or non-contractual) shall be governed by and shall be construed in accordance with English law. All disputes arising out of or in connection with these Terms (whether contractual or non-contractual) shall be subject to the exclusive jurisdiction of the English courts. A condition of using this Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.
Modern Slavery Act Transparency Statement
This statement is made by Davide Leone & Partners Investment Company Limited (“Davide Leone & Partners”) pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes Davide Leone & Partners’ Modern Slavery Act Transparency Statement for the financial year ended 28th February 2026.
Davide Leone & Partners is a London-based global long/short equity investment Firm, authorised and regulated by the Financial Conduct Authority.
As a financial services firm, we do not manufacture goods or operate complex physical supply chains. Our business involves the management of investment portfolios, and our supply chains principally consist of professional and financial services providers such as fund administrators, prime brokers, legal advisers, auditors, technology advisors and research and data providers.
We assess our supply chain to carry a relatively low inherent risk of modern slavery given the professional and regulated nature of our principal suppliers. Nonetheless, we recognise our ongoing responsibility to remain vigilant and to take proportionate steps to identify and mitigate risk.
Davide Leone & Partners takes a zero-tolerance approach to slavery in any form and is committed to ensure that modern slavery and human trafficking are not taking place within its business. We further expect those within our supply chain to comply with all applicable laws and regulations including with respect to the Act.
Our personnel policies set out the standards of behaviour expected by staff and all employees are required to act in accordance with such policies.
Our whistleblowing policy enables staff to raise concerns confidentially, including identifying any concerns in relation to modern slavery, without fear of retaliation.
Davide Leone & Partners has considered its principal supplier relationships and its business operations assessing their nature, geography and potential exposure to modern slavery risks.
We shall continue to review our approach to the risks of modern slavery and human trafficking in line with the statutory guidance published by the UK Government and shall review and update this statement accordingly.
Patrick McGuinness
Chair
Davide Leone & Partners Investment Company Limited