Shinfalls Commodities LLP

Shareholders Rights Directive II (‘SRD II’) Disclosure

Introduction

Shinfalls Commodities LLP is regulated by the Financial Conduct Authority (“FCA”) as a Full-Scope Alternative Investment Fund Manager with MiFID top up permissions. 

Shinfalls Commodities LLP is a commodity-focused alternative investment manager, specialising in the global metals markets. The firm provides bespoke investment management services, working in close partnership with its clients to deliver tailored solutions across commodity and metals strategies. This includes providing targeted exposure to specific metals-based investment opportunities. Shinfalls’ partners bring extensive experience and a strong track record in allocating capital to sophisticated commodity and alternative investment strategies.

SRD II

Article 3g of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as the Firm to either:

  • develop and disclose an engagement policy describing how the firm integrates shareholder engagement in its investment strategy; or
  • disclose why the firm has chosen not to comply with those requirements.
Such an engagement policy requires a firm to describe how it:
  • integrates shareholder engagement in its investment strategy:
  • monitors investee companies on relevant matters, including:
    • strategy
    • financial and non-financial performance and risk
    • capital structure
    • social and environmental impact and corporate governance
  • conducts dialogues with investee companies;
  • exercises voting rights and other rights attached to shares;
  • cooperates with other shareholders;
  • communicates with relevant stakeholders of the investee companies; and
  • manages actual and potential conflicts of interests in relation to the firm’s engagement.

The above engagement policy is limited to the extent that a firm invests on behalf of investors in shares traded on a regulated market (or on third country markets that meet comparable requirements and where the shares dealt in are of a quality comparable to those in a regulated market in the UK).

The Firm’s approach to engagement

The Firm runs a fundamentally driven investment strategy that focuses on base and precious metals. As such the firm does not invest in shares traded on a regulated market (or comparable market).

While the Firm generally supports the objectives that underlie SRD II, for the above reason/reasons the Firm has chosen not to produce an engagement policy at this time.