UK Stewardship Code

Principle 1

Disclosure of responsibility

Alpha provides a discretionary investment management service and is mindful of the responsibilities arising from this role in the investment chain. Where practicable we seek to have a regular dialogue with our investee companies and are willing to engage with companies where we believe it will protect and enhance shareholder value. This includes such matters as strategy, performance, risk, capital structure and corporate governance including management culture and remuneration. We do not seek to run the company but encourage the board to execute strategy effectively on behalf of our clients. Alpha does not outsource its stewardship responsibilities.

Principle 2

Conflicts of interest

Alpha undertakes to manage conflicts of interest between different client groups and those of the company in accordance with the recommendations of the Code. We have no commercial interest in any of our investee companies. We can accommodate different strategies in respect of the same investee company for different clients, depending on the mandate they have given us.

Principle 3

Monitoring

All investee companies are monitored on a regular basis. This includes the study of financial statements by the company concerned and published research material. It may also include attendance at company meetings, conference calls with management and any one-to-one meetings that Alpha can reasonably undertake. We seek to satisfy ourselves that the company’s board, management structures and governance procedures are operating effectively and in accordance with any expectations created by the company’s public statements. We expect investee companies to adhere to the spirit of the UK Corporate Governance Code and will challenge any divergence from it. Consideration is also given to the social and environmental practices adopted by the company, to ensure that these are also in line with expectations.

Principle 4

Engagement and Escalation of activities

Alpha will escalate its involvement with investee companies where we have significant concerns about their strategy, performance or risk management, or where executives’ management of the companies is felt to be impacting negatively on shareholder value. We would endeavour to initiate this at an early stage and will regularly assess the outcomes of our intervention.

Engagement would be through contact with the relevant members of the board or senior management: executive management if the issue is primarily one of performance, and non-executive if it is one of governance. Calling for resolutions, collaborative action with other investors, and open letters to management will also be considered. We are prepared to be made ‘inside’ by a company, its brokers or advisers provided our consent is obtained beforehand. We try to minimise any period during which we are prohibited from dealing in the shares of the company concerned.

It should be noted that given the small size of Alpha’s holdings the ability to influence company management may be limited and it may be more effective to sell our holding rather than undertake any other action.