Compliance Documents

“Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Pragma Wealth Management Limited (“Pragma” or the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code, first published in 2010 and subsequently subjected to updates in 2012 and 2020.  The most recently published UK Stewardship Code 2020, sets high standards by way of Principles which should be applied by asset owners and service providers (in some cases), as well as asset managers, such as Pragma.

 Pragma is a small fund of fund manager pursuing two investment strategies.  As a consequence, the 2020 Code, as presented, is not considered to be appropriate to Pragma’s investment approach, and therefore, the Firm has chosen not to commit to the Code at this time.  We agree with the aspirations of the latest Code and that its application has a role to play in creating long-term value for client and the ultimate beneficiaries of the assets managed, with the potential to lead to sustainable benefits for stakeholders in the issuers we indirectly invest in.  We consider Stewardship issues on a case-by-case basis and where relevant, make decisions in the best interests of our clients.  Should our resources position and investment strategy change in such a manner that the provisions of the Code become more relevant, Pragma will reconsider its position under the Code.”