Regulatory Disclosures

UK Stewardship Code

Financial Reporting Council's Stewardship Code (the "Code") aims to enhance the quality of engagement between institutional investors and UK companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. The Code is voluntary and sets out good practice on engagement with investee companies to which the UK Financial Reporting Council believes institutional investors should aspire and operates on a 'comply or explain' basis.

Culross Global Management Limited manages and advises portfolios of hedge funds and does not invest directly with UK companies. As such, the Code is not applicable to our business.

Culross Global Management Limited supports the broad aims and objectives of the Code and as a regulated firm, subject to the European regulatory regime, has in place a conflicts of interest policy (which is available on request) as well as a code of ethics policy to which all employees are bound. The conflicts of interest policy sets out the circumstances which may constitute actual or potential conflicts of interest in our business, which may entail a material risk of damage to the interests of one or more of our clients. For each area identified, it specifies the policy or procedures to be followed and measures to be adopted to manage such conflicts and ensure with confidence that any material risk of damage to clients is prevented.

Pillar 3 Disclosures

The Basel Committee on Banking Supervision introduced a capital adequacy framework (Basel II) to promote safety and soundness in the financial system and maintain an appropriate level of capital in the system, enhance competitive equality, constitute a more comprehensive approach to addressing risks, and focus on internationally active banks. Basel II is structured around three ‘pillars’: Pillar 1, ‘minimum capital requirements’, Pillar 2, ‘supervisory review’ and Pillar 3, ‘market discipline’.

Pillar 3 complements the minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2). Its aim is to encourage market discipline by developing a set of disclosure requirements which will allow market participants to assess key pieces of information on a company’s capital, risk exposures and risk assessment processes.

Culross Global Management Limited’s Pillar 3 disclosures are available at the registered office or on request, please message:

Remuneration Policy

Culross pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (bonus). Variable remuneration for relevant staff takes into account compliance with all Culross’s policies and procedures, including those relating to all aspects of the sustainability objectives and goals being pursued by the company.