Stewardship Code Disclosure Policy.

January 2021

This Stewardship Policy (the “Policy”) is for Abri Advisors (UK) Ltd. (“Abri”). While not subject to FCA regulations, Abri has chosen to voluntarily disclose the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook “COBS”, and to disclose where it does not commit to the Code. The Code sets out a number of principles relating to institutional investors who may invest in UK companies:

The seven principles of the Code are that institutional investors should:  

•Publicly disclose their policy on how they will discharge their stewardship responsibilities.  

•Have, and publicly disclose, a robust policy on managing conflicts of interest in relation to stewardship. 

•Monitor their investee companies. 

•Establish clear guidelines on when and how they will escalate their activities. 

•Be willing to act collectively with other investors where appropriate.  

•Have a clear policy on voting and disclosure of voting activity.  

•Report periodically on their stewardship and voting activities.  


Abri pursues an investment strategy to which certain of the aims of the Code are not wholly relevant, and certainly not across the entire portfolio of investments.

Abri’s investment strategy focuses on restructuring and distressed investments of SME’s mainly based in Europe and North America, and primarily in non-equity securities of non-UK companies to which the aims of the Code are not relevant.

Consequently, while Abri fully supports and endorses the general principles and objectives of the Code, the provisions of the Code are not wholly relevant to the type of investments currently undertaken by Abri. If Abri's investment strategy changes in such a manner that the provisions of the Code become relevant, Abri will promptly amend this disclosure accordingly.


For further information on Abri’s approach contact: 

Jeffrey Tirman, CEO 

jtirman@abriadv.com 

+44.7377.216.166