Stewardship & engagement policy

Engagement Policy

Revera Asset Management (‘Revera’) makes a clear distinction between engagement and voting at investee company meetings.  High levels of company engagement are a fundamental part of Revera’s investment process.  However, voting at investee company meetings is only done when exceptional circumstances dictate. 

Revera has concluded that this results in the best outcome for clients based on the following reasons; 

Revera is a fundamental, medium-to-long term investor.  At the time of investment in a company, our expected holding period is normally at least three years.  Some investee companies have been in client portfolios for more than a decade.  To make an investment of this nature requires high levels of engagement with the company prior to making that investment. 

Revera is not an activist investor, nor does it typically look to invest in businesses where a material change in the company’s strategy is required to crystallise profits for client portfolios.  Revera seeks to back businesses where the combination of inherent business strengths and competent management is likely to drive value creation. 

Revera has no concept of an “underweight” investment.  Client portfolios have no exposure to businesses where Revera’s investment managers are not wholly behind the investee company’s stated strategy and objectives.  Similarly, as a manager of focused portfolios, no investments are made on the basis on the size of their presence in a particular investment universe. 

Revera is an investment boutique, and does not manage assets at a scale that is likely to affect the decision making process at the top level of its investee companies through its voting actions.  If Revera’s investment managers disagree with a position taken by an investee company’s management team on any issue, it is unlikely to materially affect any voting decision on that issue. 

Moreover, Revera typically believes that its energies are better spent working with investee companies where it agrees with its management teams, rather than working against those where it does not.  The first response in these situations is to sell the investment where we have issues. 

However, this should be set against the contextual arrangements surrounding the due diligence process prior to investment and the ongoing monitoring of investee companies.  Engagement with potential and actual investee companies is a crucial part of this process. 

As a fundamental investor, Revera believes in the mutual interdependency between financial success and socio-environmental success.  Successful businesses work in harmony with their prevailing environments.  Ethically dubious actions and activities eventually lead to adverse outcomes for the business as a whole. 

Prior to investment, and over the period of investment, investee companies are reviewed for factors that may affect both the long term success of the company and that of its underlying market.  These factors may, inter alia, include the following: 

               Board or management structure that lacks breadth of experience and perspective 

    Aggressive relocation of profits to low tax jurisdictions, or other non-commercial structures to            lower tax liabilities 

   Financial gearing that endangers the company’s survival or creates systemic risks in an industry

   Potentially unfair practices when dealing with customers

   Cavalier approach to regulation and company law 

   Insufficient regard for environmental impact of activities 

Revera engages constructively with potential and actual investee companies, typically through the medium of face to face meetings, video meetings or telephone calls.  Follow-up information requests and feedback may be submitted via email, or in some cases through the relevant company’s corporate broker. 

Portfolio turnover, and the costs of such turnover are disclosed to clients on a regular basis, and are disclosed in the periodic statutory reports of all regulated collective investment schemes. 

Revera does not use proxy advisors for making decisions on its stewardship responsibilities. 

Revera does not undertake securities lending activities on behalf of its clients. 

Exceptions to the General Policy

Where appropriate, Revera will deviate from its stated policy of non-voting at investee company meetings.  This will typically happen when one of the risk factors referred to above becomes an issue in the company, and it is unlikely that Revera will be able to realise the value of its clients’ investments before the risk materialises, or if it cannot be achieved without significant diminution of the investment’s value.  In these circumstances, Revera will use all statutory options, including working with other investors to vote against the proposals or the management team, to reverse the decision. 

Voting Record in 2020

In line with its general policy, Revera did not instruct votes on behalf of its clients in any meeting during this period. 

Conflicts of Interest

The Board of Revera regularly reviews conflicts of interest across its business.  Possible conflicts of interest could emerge between Revera and its clients when investing in businesses that may also act for clients who can invest in Revera’s suite of regulated funds.  In the year under review, Revera’s client funds invested in the ordinary shares of Hargreaves Lansdown plc.  Clients of Hargreaves Lansdown also invested in the shares of S&W Revera UK Dynamic Fund, a client of Revera.  At the end of 2019, the value of investments attributable to Hargreaves Lansdown’s clients was less than 0.1% of all of Revera’s funds under management.  Revera clients’ ownership of Hargreaves Lansdown equity equated to less than 0.1% of that company’s outstanding issued share capital.  As a result, there was no perceived, effective conflict of interest between the two parties. 

Stewardship Code and other Stewardship Models

Revera is not currently a signatory to the Financial Reporting Council’s Stewardship Code.  The Board of Revera fully support the aims of, and principles behind, the Stewardship Code.  At the current time, the company is undertaking a restructuring of its engagement framework to ensure that it meets not only the obligations of the Stewardship Code, but also certain international models such as the UN’s Principles for Responsible Investing and evolving regulatory and client demands to incorporate ESG considerations formally into the investment process. 

This Engagement Policy will be updated once these changes are complete. 


This statement was last reviewed on 29th March 2021.