Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook (“COBS”), Orion Resource Partners (UK) LLP (“ORP UK” or the “Firm”), to the extent that it is managing investments for a professional client (as defined by the FCA), is required to include on its 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, explain its considered choice based on the Firm’s investment approach.

The Code is a voluntary code, aimed at enhancing the quality of engagement by asset managers and owners with corporate issuers and sets out 12 principles relating to how investment and stewardship is integrated, including environmental, social and governance issues.

ORP UK provides investment management services to clients which pursue strategies involving a diversified portfolio of investments on a global basis with a variety of timeframes. Although the Code is therefore applicable to some aspects of these strategies, this generally represents a small portion of the invested asset base which is typically across a variety of jurisdictions globally.

Whilst the Firm is supportive of the Code’s objectives and principles, the specific provisions of the Code are not aligned with the type of trading currently undertaken by the ORP UK. The Firm has therefore chosen not to commit to the Code at this time. If the ORP UK’s investment strategy changes, in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.

ORP UK further provides regular and routine reporting to its clients, such that they remain apprised of the stewardship of their investments.