UK Stewardship Code

Alpha Portfolio Management (Alpha) is a supporter of the principles of good stewardship. These were set out in the Stewardship Code published by the Financial Reporting Council in July 2010, and updated in September 2012.

We believe that supporting these principles serves to enhance the long-term value of our clients’ investments and to protect their interests, when necessary.

UK Stewardship Code – Declaration of Support

Please find below a summary of Alpha’s policies in relation to the seven main principles of the UK Stewardship Code.

Principle 1

Disclosure of responsibility

Alpha provides a discretionary investment management service and is mindful of the responsibilities arising from this role in the investment chain. Where practicable we seek to have a regular dialogue with our investee companies and are willing to engage with companies where we believe it will protect and enhance shareholder value. This includes such matters as strategy, performance, risk, capital structure and corporate governance including management culture and remuneration. We do not seek to run the company but encourage the board to execute strategy effectively on behalf of our clients. Alpha does not outsource its stewardship responsibilities.

Principle 2

Conflicts of interest

Alpha undertakes to manage conflicts of interest between different client groups and those of the company in accordance with the recommendations of the Code. We have no commercial interest in any of our investee companies. We can accommodate different strategies in respect of the same investee company for different clients, depending on the mandate they have given us.

Principle 3


All investee companies are monitored on a regular basis. This includes the study of financial statements by the company concerned and published research material. It may also include attendance at company meetings, conference calls with management and any one-to-one meetings that Alpha can reasonably undertake. We seek to satisfy ourselves that the company’s board, management structures and governance procedures are operating effectively and in accordance with any expectations created by the company’s public statements. We expect investee companies to adhere to the spirit of the UK Corporate Governance Code and will challenge any divergence from it. Consideration is also given to the social and environmental practices adopted by the company, to ensure that these are also in line with expectations.

Principle 4

Engagement and Escalation of activities

Alpha will escalate its involvement with investee companies where we have significant concerns about their strategy, performance or risk management, or where executives’ management of the companies is felt to be impacting negatively on shareholder value. We would endeavour to initiate this at an early stage and will regularly assess the outcomes of our intervention.

Engagement would be through contact with the relevant members of the board or senior management: executive management if the issue is primarily one of performance, and non-executive if it is one of governance. Calling for resolutions, collaborative action with other investors, and open letters to management will also be considered. We are prepared to be made ‘inside’ by a company, its brokers or advisers provided our consent is obtained beforehand. We try to minimise any period during which we are prohibited from dealing in the shares of the company concerned.

It should be noted that given the small size of Alpha’s holdings the ability to influence company management may be limited and it may be more effective to sell our holding rather than undertake any other action.

Principle 5

Collective action with other investors

Alpha is willing to be approached by other investors and will consider collective engagement where we feel it is more likely to influence the outcome and protect our clients’ interests.

Principle 6


Alpha considers all resolutions where our clients’ mandate allows us to do so. As the size of our holdings means our vote is unlikely to affect the outcome we may support management by voting in favour or not voting at all. However we always vote against a resolution or register an abstention where we feel strongly on an issue, or where we disagree with management on a particular matter and have not been able to come to a resolution. Where possible and appropriate, we will inform the company in advance of our actions and the reasons for them. Our voting record is available on request.

We do not use proxy voting services but monitor and consider public guidance from the mainstream ethical advisory bodies. We do not engage in stock lending.

Principle 7

Reporting of voting activity

Alpha reports periodically on its stewardship and voting activities to any clients who require it.

Full version