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The Shareholder Rights Directive II (SRD II) is a European Union (EU) directive and aims to encourage effective stewardship and long-term decision making, involving transparency on engagement policies and investment strategies between traded companies and investors. SRD II applies to asset managers including full scope Alternative Investment Fund Managers that invest in shares traded on a regulated market in the EEA as well as ‘comparable’ markets situated outside of the EEA. Firms in scope must on a comply or explain basis develop and publicly disclose an engagement policy, and annually disclose how the engagement policy has been implemented including a general description of voting behaviour.

Vor Capital LLP provides investment management services to various funds (“the Funds”) that pursue investment strategies focusing on concentrated long-biased equity investments into internet businesses. Whilst the nature of the investment strategy the Funds pursue provide the option for proxy voting and shareholder engagement, Vor Capital LLP does not intend to engage in proxy voting and take an ‘activist’ approach to shareholding therefore feels an engagement policy is not appropriate.

For further information on the Firm’s approach, contact:

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