Under Rule 2.2.3R of the FSA's Conduct of Business Sourcebook, PGR Capital LLP ("the Firm") is required to disclose the nature of its commitment to the UK Financial Reporting Council's Stewardship Code ("the Code") or, where it does not commit to the code, its alternative investment strategy.
The Firm acts only as an investment manager and does not trade in UK listed securities on behalf of its clients; as such, the provisions of the Code do not apply to it.