Blue Planet Investment Management Ltd ("Blue Planet”)
Disclosure of our commitment to the Code
Under COBS 2.2.3R of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the Financial Reporting Council's UK Stewardship Code (the "Code"), which was published by the Financial Reporting Council ('FRC')
It sets out good practice on engagement with investee companies and is to be applied by firms on a "comply or explain" basis.
The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases, firms are required to explain why it is not appropriate to comply with a particular principle.
The 12 principles of the Code consist of the following:
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Purpose, strategy and culture;
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Governance, resources and incentives;
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Conflicts of interest;
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Promoting well-functioning markets;
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Review and assurance;
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Client and beneficiary needs;
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Stewardship, investment and ESG integration;
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Monitoring managers and service providers;
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Engagement;
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Collaboration;
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Escalation; and
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Exercising rights and responsibilities
Blue Planet is a relatively small investment management firm which manages one OEIC with current total funds under management (FUM) of less than £100m.
The OEIC is a global fund with a small proportion of its investments in UK firms. The companies it is invested in are mostly very large capitalised organisations and the fund’s exposure to any one of them would be very small in relation to their total equity capital. The degree of influence we would command would be very small indeed.
Although we are pleased to endorse the principles of the code, in practice we are not able to influence the UK companies in which we might be invested.
We acknowledge that our exposure to UK companies could change and therefore we will monitor that exposure on an annual basis and publish the outcome of the review on this website.
DISCLOSURE OF OUR COMMITMENT TO THE CODE
Stewardship Code Statement

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