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Puma Investments

Shareholder Rights Directive

Puma Investment Management Limited (“Puma” or the “Firm”) is authorised and regulated by the Financial Conduct Authority (“FCA”).

The EU Shareholder Rights Directive (EU) 2017/828 (“SRD II”) has been implemented in the UK through amendments to the FCA Handbook, principally within the Conduct of Business Sourcebook (“COBS”). SRD II is intended to encourage long‑term shareholder engagement and transparency by certain asset managers and institutional investors in relation to investments in shares traded on regulated markets.

Under COBS 2.2B, UK MiFID investment firms providing portfolio management services and UK alternative investment fund managers are required, on a comply‑or‑explain basis, either to:

  • develop and publicly disclose a shareholder engagement policy and make annual disclosures on its implementation; or
  • publish a clear and reasoned explanation as to why such a policy has not been adopted.

The SRD II requirements apply only to the extent that a firm invests on behalf of investors in shares traded on a regulated market.

Puma’s listed equity investment activity is limited to shares admitted to trading on the Alternative Investment Market (“AIM”), including through the management of Puma AIM VCT plc and the provision of its Puma AIM IHT Service. AIM is classified as a multilateral trading facility (“MTF”) and is not a regulated market for the purposes of the FCA Handbook.

Accordingly, Puma considers that, based on the nature of its current investment activities, the SRD II requirements set out in COBS 2.2B do not apply to the Firm at this time.

This disclosure is reviewed periodically and will be updated if there is a material change to Puma’s investment activities or to the applicable regulatory framework.