• This information is available from the Management Company Waystone Fund Management (IE) Ltd
    23 St Stephen's Green
    Dublin 2, Ireland
    T: +353 1 533 7020  

  • The UK Stewardship Code 2020 (the "2020 Code") took effect from 1 January 2020, replacing the UK Stewardship Code 2012 (the "2012 Code"). Organisations wanting to become signatories to the 2020 Code are required to produce an annual disclosure explaining how they have applied the 2020 Code in the previous 12 months. Please note that this disclosure is made against the 2012 Code and therefore the information contained within it relates solely to the application of the 2012 Code. For the avoidance of doubt, it does not reflect Trinity Street's position with respect to the 2020 Code and should not be read as a disclosure against the 2020 Code.

    Trinity Street Asset Management LLP (“Trinity Street” or the “Firm”) is a London-based investment manager that is authorised and regulated by the UK Financial Conduct Authority (“FCA”) and a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Trinity Street is an independently-owned investment boutique founded in 2002 and focuses solely on managing Global and International Equity portfolios.

    This document describes how Trinity Street has applied the seven principles of the UK Stewardship Code (the “Code”), which is overseen and published by the Financial Reporting Council. Below we disclose the nature of our commitment to the Code and where, if at all, we do not commit to the Code we state clearly our alternative investment strategy – the Code is applied on a “comply or explain” basis.

    The Code aims to enhance the quality of engagement between institutional investors and companies with the aim of improving long-term shareholder returns and encouraging enhanced corporate governance at portfolio investment companies.

    Code Disclosure 2020
    The following sets forth the seven principles of the Code and outlines how Trinity Street believes it fulfils each of those principles:

    Principle 1: Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
    At the heart of Trinity Street’s investment processes are activities that are at the core of and consistent with stewardship; with our experienced Portfolio Managers engaging with investee companies and potential investee companies on strategy, performance, risk, capital structure and corporate governance.

    In particular Trinity Street considers it to be of paramount importance when assessing proxy voting responsibilities on behalf of its funds and segregated accounts to recognise the fiduciary responsibility it assumes in acting as an investment manager. Trinity Street also recognises the need to exercise its proxy voting obligations with a view to enhancing our clients' long-term investment values.

    Trinity Street has a documented Proxy Voting Policy in compliance with Rule 206(4)-6 of the Investment Advisers Act of 1940.

    Principle 2: Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.
    Trinity Street maintains a robust conflicts of interest policy to seek to identify and manage conflicts of interest that ensures our decisions are taken wholly in the interest of our clients. In compliance with both the FCA and SEC rules, Trinity Street takes a risk-based approach to identify areas of potential conflict of interest, to manage and avoid conflicts of interest in an appropriate manner, and to consider all conflicts when designing and implementing policies and procedures. A summary copy of Trinity Street’s Conflict of Interest Policy is available upon request from the Chief Compliance Officer.

    Principle 3: Institutional investors should monitor their investee companies.
    Comprehensive and continuous proprietary research and monitoring of investee companies is essential to and at the core of Trinity Street’s investment process. Trinity Street utilises various research and support tools to meet this principle.

    Trinity Street may from time to time choose to become insiders. In such a case procedures are in place to restrict information and trading.

    Principle 4: Institutional investors should establish clear guidelines on when and how they will escalate their stewardship.
    Trinity Street takes an active approach to communicating its views to companies where it believes there are issues that will impact shareholder value. Trinity Street prefers to build effective relationships with the management and boards of these companies in private discussions. Should this approach not be successful Trinity Street would consider, in appropriate circumstances, other strategies (for example but not limited to expressing concerns through the company’s advisers, or meeting with the chairman or other board members).

    Principle 5: Institutional investors should be willing to act collectively with other investors where appropriate.
    Should occasion arise, Trinity Street may find it preferable to work with other shareholders of an investee company to effect change. Before entering into collaborative engagement initiatives, Trinity Street will take into account potential conflicts of interest and the regulatory implications of its actions.

    Principle 6: Institutional investors should have a clear policy on voting and disclosure of voting activity.
    As a registered investment adviser with the SEC, Trinity Street has a documented Proxy Voting Policy in compliance with Rule 206(4)-6 of the Investment Advisers Act of 1940. Trinity Street’s clients can request a copy of the Firm’s Proxy Voting Policy from the Chief Compliance Officer. Trinity Street does not disclose this information to non-clients.

    For a number of accounts managed by Trinity Street, third party vendor electronic voting services are used (such as Broadridge Proxy Edge). Trinity Street does not carry out stock lending on the accounts it manages.

    Principle 7: Institutional investors should report periodically on their stewardship and voting activities.
    Due to underlying client confidentiality and investment or engagement strategy reasons, it may not always be appropriate to disclose voting actions at a detailed level.

    Trinity Street’s clients can request information about proxies voted and issues raised at meetings of investee companies. Trinity Street does not disclose this information to non-clients.

    General statements:
    For further information on Trinity Street’s application of the Code please contact our Chief Compliance Officer, Steve Hicks, at

    This statement of compliance with the Code was last reviewed in February 2021, and will be reviewed no less frequently than annually.

    18 February 2021

  • Trinity Street Asset Management LLP (the “Firm”) is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is a UK domiciled discretionary investment manager to professional clients and both regulated and unregulated collective investment schemes. The Firm is a full scope BIPRU investment firm, a full scope Alternative Investment Fund Manager ("AIFM") and is categorised as a collective portfolio management investment firm by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s Pillar 3 disclosure fulfils the Firm’s obligation to disclose to market participants’ key pieces of information on a firm’s capital, risk exposures and risk assessment processes.  

    We are permitted to omit required disclosures if we believe that the information is immaterial such that omission would be likely to change or influence the decision of a reader relying on that information. In addition, we may omit required disclosures where we believe that the information is regarded as proprietary or confidential. In our view, proprietary information is that which, if it were shared, would undermine our competitive position. Information is considered to be confidential where there are obligations binding us to confidentiality with our customers, suppliers and counterparties.
    We have made no omissions on the grounds that it is immaterial, proprietary or confidential.

    Risk Management

    The Firm's Management Board determine its business strategy and the level of risk acceptable to the Firm. In conjunction with the Risk Officer, they have designed and implemented a risk management framework that recognises the risks that the business faces and how those risks may be monitored and mitigated and assess on an ongoing basis. The Firm has in place controls and procedures necessary to manage those risks. The Risk Officer will convey information on risks and risk management to the Compliance Officer. 

    The Firm considers the following as key risks to its business:

    Operational risk – This risk covers a range of exposures including security breaches, risk of clerical errors, a breach of a fund’s investment objectives, and the loss of key personnel. Operational risks and how they can be mitigated are assessed as part of the Internal Capital Adequacy Assessment Process (”ICAAP”).

    Business Risk – This risk includes a fall in assets under management due to market movements or internal factors such as poor investment decisions and a loss of reputation, resulting in a reduction in fee income earned by the Firm and hindering its ability to finance its operations and reimburse its expenses. Business risks are assessed and mitigated as part of the ICAAP.

    Market risk - The risk is the exposure to foreign exchange fluctuations due to investment management and performance fees being denominated in currencies other than sterling. The Firm operates currency bank accounts permitting it to receive/pay currency directly.

    Credit risk – This risk relates to the exposure to the Funds for non-payment of management and performance fees and counterparty exposure relating to the Firm’s bank balances and any other debtors. This is monitored by the Firm’s Chief Financial Officer.

    Regulatory Capital

    The Firm is a Limited Liability Partnership, and its capital arrangements are established in its Partnership deed. Its capital contains only members’ capital contributions.

    The Firm has a simple operational infrastructure. Its market risk is limited to foreign exchange risk on its accounts receivable in foreign currency, and credit risk from management and performance fees receivable from the funds under its management. 

    Pillar 1 capital is the higher of:
    1. the base capital requirement of €125,000;   
    2. the sum of market and credit risk requirements; and
    3. the Fixed Overhead Requirement 

    In addition, the Firm, on account of its classification as a full-scope AIFM, is subject to a parallel "own funds" requirement as follows:
    The higher of:
    1. the funds under management requirement, subject to a minimum of €125,000; and
    2. the own funds based on fixed overheads requirement;  
    Plus whichever is applicable of:
        a. the professional negligence capital requirement; or
        b. the PII capital requirement. 

    Pillar 2 capital is calculated by the Firm as representing any additional capital to be maintained against any risks not adequately covered under the requirement in Pillar 1 as part of its ICAAP. When making this calculation, the Firm also takes into account the own funds requirement detailed above, in particular where the own funds exceeds Pillar 1 capital (and the extent to which the Firm is able to use capital instruments to fulfil both requirements).
    It is the Firm’s experience that its Pillar 1 capital requirement normally consists of the Fixed Overhead Requirement, although market and credit risks are reviewed monthly. The Firm applies a standardised approach to credit risk, applying 8% to the Firm risk-weighted exposure amounts, consisting mainly of investment management and performance fees due but not paid, and bank balances. Having performed the ICAAP, the Firm has concluded that no additional capital is required in excess of its Pillar 1 capital requirement.

    As at the 31st March 2021 the Firm’s regulatory capital position was: 

    Capital Item
    Tier 1 capital: £5,984,000
    Total capital resources, net of deductions: £3,835,000

    The Firm’s ICAAP assesses the adequacy of its internal capital to support current and future activities. This process includes an assessment of the specific risks to the Firm, the internal controls in place to mitigate those risks and an assessment of whether additional capital mitigates those risks. The Firm also considers a wind down scenario to assess the capital required to cease regulated activities.

    We have not identified credit risk exposure classes or the minimum capital requirements for market risk as we believe that they are immaterial. Concerning Pillar 1, it is the Firm’s experience that the Fixed Overhead Requirement establishes its capital requirements and hence market and credit risks are considered not to be material. Furthermore, the market and credit risks component excludes such risks related to the management of alternative investment funds.

    Our capital requirements are currently £1,304,000 (the higher of the minimum capital calculated in accordance with either ‘Pillar 1’ or ‘own funds’) which is well within the level of regulatory capital held.

    We consider this amount to be sufficient regulatory capital to support the business and have not identified any areas that give rise to a requirement to hold additional risk-based capital.

    The Firm’s ICAAP is formally reviewed by the Management Committee annually, but will be revised should there be any material changes to the Firm’s business or risk profile. 


    Given the nature and small number of staff, remuneration is set by the Management Board. There is a formal review process of staff performance and based thereon determines each staff members overall level of remuneration and the split of that between base salary and bonus for employees and profit share for members in compliance with the FCA Rules on remuneration.

    Given that the Firm has only one business area, investment management, all remuneration disclosed in our audited financial statements is from this business area.

    The Firm has defined “Code Staff” to be the Portfolio managers, Risk officer and Compliance officer. The aggregate level of remuneration earned by “code staff” for the financial year ended 31st March 2021 was approximately £18,647,000.

    As the Firm currently has no Alternative Investment Fund which is either domiciled in the European Economic Area ("EEA") or marketed in the EEA there is no requirement for a remuneration statement to form part of the annual report of any Alternative Investment Fund.

    There is also a requirement for a remuneration statement to form part of the annual report of any Alternative Investment Fund ("AIF") to which the Firm acts as AIFM and which is either domiciled in the European Economic Area ("EEA") or marketed in the EEA.  

    The Firm is subject to the AIFMD Remuneration Code ("the Code"), has applied proportionality and, pursuant to this application and where relevant, has disapplied various provisions of the Code. 

  • Background

    RTS 28 supplements MiFID Directive 2014/65/EU with regulatory technical standards for the annual publication by investment firms of information on the identity of execution venues.

    RTS 28 - Summary

    Summary of the analysis and conclusions Trinity Street Asset Management LLP (“TSAM”) has drawn from the detailed monitoring of the quality of execution obtained on the execution venues where TSAM has executed all client orders in the calendar year 2020 (“the Report Period”).  

    As part of the MiFID II best execution requirements, investment firms must publish, on an annual basis, reports summarising specific information on the quality of execution obtained for each financial instrument traded during the preceding year. MiFID II provides 22 sub-classes of financial instruments and investment firms are required to disclose their trading volumes with different counterparties expressed as a percentage of the firm’s total execution volume and a percentage of the number of executed orders, in that particular sub-class of financial instrument. In addition, investment firms must also provide a qualitative report summarising the conclusions drawn from its monitoring of the quality of execution.
    This report provides qualitative information summarising the quality of indirect execution (placing orders with, or transmitting orders to, another entity for execution) undertaken by TSAM in 2020, in the sub-classes of instruments detailed below. This report should be read with the accompanying quantitative disclosure report, which summarises, where applicable, the top 5 execution brokers used during 2020 for the sub-class of financial instruments in question. TSAM only acts on behalf of Professional Clients.
    This report covers: Equities (shares and depositary receipts); Other Instruments (unclassified by ESMA).

    Explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution.

    Execution factors taken into consideration by TSAM in executing orders may include:
    -Costs of execution
    -Speed of execution
    -Likelihood of achieving execution and settlement
    -Size and nature of the order
    -Any other consideration relevant to the execution of the specific order
    The relative importance given to the execution factors was in line with TSAM’s best execution policy and consistent with TSAM’s processes in respect of these sub-classes of financial instruments.

    Equities (Shares and Depositary Receipts):
    The equity securities acquired / sold on behalf of clients were generally liquid, medium and large cap stocks in developed markets, with standard fees agreed across brokers. Price and liquidity were generally the most important of the execution factors during the review period, although all execution factors were considered for each proposed trade as part of TSAM’s operations.

    Other Instruments:
    TSAM places orders in a number of equities and depositary receipts that are not traded in the EU. Where the tick-size regime adopted for EU equities is not available for these non-EU securities, they have been classified as Other Securities for this report.

    Description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.

    TSAM has no close links, conflicts of interest or common ownership with respect to the execution venues that it used to execute orders.

    Description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

    TSAM has no specific arrangements to report.

    Explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurs.

    Execution venues are reviewed periodically. During the Report Period a small number of additional brokers/execution venues were added.   These additions were made to enhance liquidity capabilities.

    Explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements.

    There has been no differentiation across client categories during the Report Period. All of TSAM’s clients are professional clients. TSAM is not authorised to conduct investment business with retail investors.

    Explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client.

    Not relevant to TSAM’s operations; TSAM does not have retail clients.

    Explanation of how the investment firm has used the information acquired under Delegated Regulation (EU) 2017/575 (RTS 27).

    Execution quality and overall achievement of best execution are monitored through a number of tools and processes. This includes an independent Transaction Cost Analysis ("TCA") provider.

    Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of MiFID II.

    TSAM has not used output from consolidated tape providers in respect of the Review Period.

    RTS 28 - Analysis of Execution 2018, 2019, 2020

  • TSAM Privacy Policy

    Trinity Street Asset Management LLP ("TSAM"), takes the privacy of customers (“you”) seriously and aims to protect that privacy as far as possible. TSAM is a “data controller” in respect of any personal information we hold about you as our customer.

    TSAM will amend this privacy notice from time to time. This privacy notice was last updated in May 2021.

    Contact Us

    If you have any questions about this privacy notice or our privacy related practices, you can contact us:

    • at the following address: Trinity Street Asset Management LLP, 1 Cavendish Place, London, W1G 0QF, UK.
    • by email at:
    • by phone at: +44 (0) 207 495 9110.

    How we obtain your information:

    In the course of providing services to you, or receiving services from you, we collect information that personally identifies you.  The information we collect about you (or your staff) comes from:

    • application forms or other materials you submit to us during the course of your relationship with us;
    • your interactions with us, transactions and use of our products and services;
    • your business dealings with us, including via email, telephone or as stated in our contracts with you;
    • depending on the products or services you require, third parties (including for money laundering checks, among other things); and
    • recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).

    The information we collect

    If you are our customer, we collect information that helps us to identify you and to manage your accounts. We also collect financial information about you, information about your transactions with us and information required for us to carry out money laundering and other checks and to comply with our legal obligations.

    Where you are our customer, information that we collect can include:

    • your name, title and contact details;
    • your professional title and occupation;
    • your age and marital status;
    • financial information;
    • personal identifiers such as your social security number, national insurance number, tax file number, IP address or our internal electronic identifiers;
    • information which we might need to conduct ‘know your client’ checks such as details relating to your passport and credit history; and
    • other information you provide to us in the course of your dealings with us or which we require to provide you with TSAM’s services.

    In limited cases, we also collect what is known as “special categories” of information. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes result in us obtaining information about actual or alleged criminal convictions and offences.

    You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.

    Our use of your information

    Where you are our customer, we collect, use, share and store information about you to process transactions and to improve the quality of the service that we provide to you.

    When processing your information, we do so in our legitimate interests (as set out in the bullet points below), because of legal obligations that we are subject to or because the information is required either in order to provide our products or services to you or to receive products and services from you in accordance with a contract.

    Where we process “special categories” of information about you, we do so either because you have given us your explicit consent, we are required by law to do so or the processing is necessary for the establishment, exercise or defence of a legal claim.

    We use your information for the purposes of the following legitimate interests:

    • to permit, administer and record your investment in any of our funds;
    • to administer, operate, facilitate and manage your account(s) with us and your use of our services and products;
    • to manage any funds that you invest in with us and to communicate with you in connection with your investment in our funds;
    • in connection with TSAM’s internal management and reporting;
    • to facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

    How we share your information

    We share certain information within TSAM with our third party partners, business associates and subcontractors, and with other third parties for the purposes set out in this policy.

    We disclose personal information to third parties, subcontractors, agents and any person (“Third Parties”) who provides professional, legal, accounting advice or other services to TSAM or the TSAM  sponsored funds, who will use such information in the course of providing advice or other services to you and for the purposes that we specify. Such third parties may, for example, process data:

    • to facilitate the opening of your account or investment in a fund, the management and administration of your holdings in your account or in a fund and any related account on an on-going basis which are necessary for the performance of your contract in relation to the account or with the fund, including without limitation the processing of redemption, conversion, transfer and additional subscription requests, and the payment of distributions;
    • in order to carry out anti-money laundering checks and related actions which TSAM considers appropriate to meet any legal obligations imposed on TSAM, or the administrator relating to, or the processing in the public interest, or to pursue the legitimate interests of TSAM or the administrator in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with TSAM’s, and the administrator's anti-money laundering procedures.
    • to report tax related information to tax authorities in order to comply with a legal obligation;
    • to monitor and record calls and electronic communications (i) for processing verification of instructions; (ii) for investigation and fraud prevention purposes; (iii) for crime detection, prevention, investigation and prosecution; (iv) to enforce or defend TSAM, the administrator’s or their affiliates' rights, themselves or through third parties to whom they delegate such responsibilities or rights in order to comply with any legal obligation imposed on TSAM or the administrator;  (v) to pursue the legitimate interests of TSAM or the administrator in relation to such matters; or (vi) where the processing is in the public interest;
    • to disclose information to other third parties such as service providers of a fund, auditors, regulatory authorities and technology providers in order to comply with any legal obligation imposed on TSAM, or the administrator or in order to pursue the legitimate interests of TSAM, or the administrator;
    • to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of TSAM, or the administrator to improve their service delivery;
    • to update and maintain records and carry out fee calculations;
    • to retain anti money laundering and other records of individuals to assist with subsequent screening of them by the administrator including in relation to your investment.

    All such companies are required to maintain the confidentiality of such information to the extent they receive it.

    We also disclose your personal information or any portions thereof (a) as required by, or to comply with, applicable law, regulation, court process or other statutory requirement; and (b) at the request of any regulatory, supervisory or governmental authorities.

    How we transfer your information

    We use cloud-based technologies and do business in a global marketplace. This means that we may share your information outside the European Economic Area (“EEA”). Where we do so, we put in place safeguards to protect it.  Some of these countries may have lower standards of data protection than in your home country, and not all countries outside of the EEA have data protection laws that are similar to those in the EEA, so they may not be regarded by the European Commission as providing an adequate level of data protection. Where we transfer your information outside of the EEA, we will seek to ensure that the transfer is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards.

    Retention of information

    We will hold your personal information on our systems for the longest of the following periods:

    • a minimum of six years; or
    • as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us;
    • the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
    • any retention period that is required by law;
    • the end of the period in which litigation or investigations might arise in respect of the services that we provide to you.

    Your rights

    Data protection laws may provide you with rights to object to marketing.

    They may also provide you with rights including rights to access data, as well as rights for data to be erased, corrected, used for only limited purposes, not used at all, or transferred to you or a third party.  You can seek to exercise any of these rights by contacting us at the details set out in the “Contact Us” section above.  You may have the following rights under data protection laws:

    Right of subject access: The right to make a written request for details of information about you held by TSAM and a copy of that information.

    Right to rectification: The right to have inaccurate information about you rectified.

    Right to erasure ('right to be forgotten'): The right to have certain information about you erased.

    Right to restriction of processing: The right to request that your information is only used for restricted purposes.

    Right to object: The right to object to the use of your information, including the right to object to marketing.

    Right to data portability: The right, in certain circumstances, to ask for information you have made available to us to be transferred to you or a third party in machine-readable formats.

    Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your information. If you withdraw your consent, this will not affect the lawfulness of TSAM’s use of your information prior to the withdrawal of your consent.         

    Please note that these rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.

    If you are unhappy with the way we have handled your information you have a right to complain to the data protection regulator in the EU Member State where you live or work, or where you think a breach of your personal information has taken place.

    In the UK, your local regulator is the Information Commissioner. The website is available at

    TSAM takes the protection of your personal information seriously, and has security measures and policies in place to address this. All TSAM staff are made aware of their information security responsibilities.

    Privacy policy download

Shareholder Rights Directive (Directive (EU) 2017/828) ("SRD II")
  • Trinity Street Asset Management LLP: Engagement Policy

    This document summarises the policy of Trinity Street Asset Management LLP and its affiliated companies (“Trinity”) and our approach to investee engagement and how it meets the requirements of the Shareholders Rights Directive (SRDII).   The policy covers all client funds and accounts for which Trinity serves as investment manager or adviser, and outlines how Trinity monitors and engages with investee companies, as well as how the nature of these engagement activities are disclosed.
    As a longstanding investor Trinity recognises the importance of ongoing investee engagement in its investment strategy.  In our experience effective stewardship promotes high standards of corporate governance and has been proven to add value and to the success of companies. Through effective stewardship Trinity aims to deliver long-term performance for clients.

    UK Stewardship Code
    Trinity has supported the principles of the 2012 Stewardship Code, the standards of best practice that it represents and, where possible, looks for similar standards across its investable universe.  For more information on Trinity’s position on the 2012 Stewardship Code, please refer to the statement on the Trinity website (  As of the date of this policy, Trinity is reviewing the content of the 2020 UK Stewardship Code.

    Integrating investee engagement
    As an active manager, Trinity believes that stewardship helps to safeguard and enhance the risk-adjusted returns of clients’ investments.  Furthermore, good corporate governance supports the alignment of the interests of company management with those of its investors.  Where possible Trinity seeks to maintain constructive dialogue with company management.  Stewardship activities are undertaken by the investment team as part of the ongoing engagement with companies.
    Initially, as part of the investment decision making process, Trinity’s investment team will review company documents and third-party research and undertake meetings with management.  These reviews are documented and discussed by Trinity’s portfolio managers and wider investment team.  The outcome of these discussions will have a direct impact on investment decisions and portfolio construction, and will inform the nature of ongoing dialogue and engagement with a company.  This initial process sets out the foundations of Trinity’s approach to stewardship and the basis of its relationship post-investment.

    Monitoring investee companies on relevant matters
    Trinity has established policies and procedures on when and how it will manage its activities in order to protect and enhance the shareholder value of investee companies.
    Trinity’s investment team will correspond directly on relevant, material topics.  These include both financial and non-financial performance and risks.  As part of the ongoing monitoring of companies, discussions with companies will focus on governance, strategy, capital structure and allocation, in the areas listed below as appropriate:

    Corporate strategy
    Capital allocation
    Management structures
    Balance sheet efficiency
    Cash generation
    Sustainability of returns
    Competitive advantage / risks
    Regulatory risks

    Corporate Governance
    Transparency and disclosure
    Governance structures
    Minority interests fair representation
    Public reporting
    Management accessibility
    Long-term incentive schemes
    While historically corporate governance has been the focus of non-financial performance and risk dialogue, environmental and social factors and their improvement are increasing areas of focus of investee engagement , see examples below.

    Global impact and emissions
    Local impact and water and waste management
    Incidents of environmental pollution
    Energy management
    Use of green energy
    Polices and innovations to limit negative impact
    Customer welfare
    Human rights and community relations
    Labour practices and health and safety
    Supply chain management
    Materiality of philanthropy spend
    Product quality and safety

    Trinity’s monitoring typically includes:

    • Meetings with company management and directors
    • On -site company visits
    • Monitoring company announcements
    • Reviewing company interim and annual results
    • Attending capital market meetings
    • Attending meetings with external research providers to validate investment recommendations
    • Reviewing external research

    Trinity expects companies to comply with local regulations and governance codes.  Company boards should seek to satisfy the reasonable expectations of customers, investors and employees, as well as acting in a way that demonstrates their responsibility to wider society, to ensure long term prosperity for all.

    Conducting dialogue with investee companies
    Trinity’s dialogue with investee companies takes place during the life of the investment and can cover any issue that may affect a company’s ability to deliver long term performance and to create shareholder value.
    Dialogue with companies is undertaken by the investment team, through but not limited to the following methods:

    • Email exchanges with company management
    • Meetings with senior management
    • Company site visits
    • Participation in roadshows

    The Trinity investment team seeks to engage positively with companies to address any issues through discussions and agreement.
    Trinity expects investee companies to respond to requests in a timely manner.  Where companies fail to respond or to appropriately engage in dialogue on the issues raised, the investment team may review its investment decision in consideration of the materiality of he issue and its impact on the long-term success of the company. 
    Where appropriate, Trinity logs and records the detail of engagement activities, including the final outcome.   

    Exercising voting rights and other rights attached to shares
    Trinity’s investment team aim to vote on all proxies presented to them.  Where concerns arise the investment team seeks to address these through engagement with company management and other key stakeholders.
    Subject to mandate restrictions, Trinity is generally responsible for voting proxies and taking decisions in connection with proxy voting with respect to equity shares held by or on behalf of clients where it serves as investment manager or adviser. 
    Where Trinity is given responsibility for proxy voting, it will take reasonable steps under the circumstances to ensure that proxies are voted in the best interests of its clients.
    Trinity considers its prior experience with similar proxy proposal, its perception of the motivation behind a proxy proposal, the manner in which the proxy proposal is structured, and other facts and circumstances related to the proposal. 
    Cooperating with other investors
    Trinity is willing to engage and act collaboratively with other investors, where appropriate and in the interests of clients, and permitted by regulations. In deciding whether to not to engage or act collectively with other investors, Trinity will consider a range of factors, including:

    • the sensitivity of the issue being discussed
    • if, by acting collaboratively, the engagement is likely to be more effective
    • the alignment of other investors with Trinity’s objectives
    • the impact of the collective engagement on the ongoing relationship with the investee company

    Communicating with relevant stakeholders of the investee companies
    In addition to collaborating with other investors, in appropriate circumstances Trinity will communicate and cooperate with relevant stakeholders who bring together companies to engage and discuss focussed issues.
    Managing actual and potential conflicts of interest in relation to the firm’s engagement
    Trinity has in place a policy to identify and manage conflicts of interest that may arise between it and its clients and between different clients.  All Trinity staff are required to have an understanding of conflicts of interest, and to raise actual or potential conflicts of interest with the Trinity Compliance Officer. 

    DATE of Policy: 10 November  2020


ESG (Environmental and Social Governance)
  • Trinity Street's approach to Environmental and Social Governance ("ESG") – website disclosure under and in accordance with the Sustainable Finance Disclosure Regulation ("SFDR")

    This document explains how Trinity Street Asset Management LLP ("Trinity Street") (a) factors sustainability risks into the investment decision making process and (b) how this assessment may impact on the returns of the clients whose assets it manages.

    Trinity Street has incorporated and integrated ESG considerations into its investment process and approach.

    A key aspect of Trinity Street's methodology is to seek to ensure that it appropriately understands ESG issues relating to investee companies and potential investee companies; for example in relation to controversial issues, putting them into context and providing advice on voting at annual general meetings.

    Integration of ESG in Trinity Street's investment process means that the person making the investment decision is in possession of appropriate information, can determine how they impact the investment case, including valuation, and is in a position to engage with the managers of the investee company representing the interests of asset owners.

    The Trinity Street investment team considers ESG as part of its assessment of the companies we invest in to seek to positively impact investment returns. It is important to note that ESG does not drive the investment process at Trinity Street, but rather is an important factor that is considered when investing, holding, and divesting, for example when considering valuation.

    Environmental and Social Governance

    Research Integration - Integration begins with Trinity Street's portfolio managers and analysts considering ESG factors as part of their bottom-up, fundamental research. Trinity Street believes that by embedding ESG considerations in the different stages of the work of our investment teams - rather than a separate ESG research function – provides the most effective integration strategy. Currently Trinity Street uses the in-depth resources provided by Sustainalytics, which supports the investment team's analysis by providing additional ESG-related data, analysis, and training, and enhancements to processes and documentation.

    Portfolio Construction & Maintenance – Analysts monitor and update any material ESG considerations relevant to a particular security on an ongoing basis as a part of their standard research activities. The investment team determines the extent to which various research inputs are incorporated and weighted in their investment decisions.

    Risk Management - ESG risk considerations are integrated into our risk management framework and is part of the mainstream investment risk conversation held on a quarterly basis. Trinity Street's performance and risk team uses industry-recognised tools to provide a top-down, portfolio level perspective on ESG factors. This ensures ESG analytics are integrated into regular portfolio performance and risk analysis, as well as discussions with and between portfolio managers.