UK Stewardship Code

The UK Stewardship Code 2026 (the “Code”), published by the Financial Reporting Council, is a voluntary code that sets standards for stewardship and reporting by asset owners, asset managers and the service providers that support them.

Under rule COBS 2.2.3R of the Financial Conduct Authority’s Conduct of Business Sourcebook, a firm managing investments for professional clients that are not natural persons must disclose the nature of its commitment to the Code or, where it does not commit to the Code, its alternative investment strategy.

CIBRA’s approach

CIBRA Capital Ltd (“CIBRA”) supports the objectives that underlie the Code but has chosen not to commit to the Code at this time.

CIBRA manages a global event-driven investment strategy, including merger arbitrage and opportunities arising from significant corporate events. Its investment approach focuses on individual transactions and events across a range of jurisdictions and instruments, rather than a programme of long-term engagement with all investee companies. Exposure may be held through physical shares or derivatives; a swap position does not itself confer shareholder voting rights.

This does not prevent CIBRA from engaging with company management or exercising voting rights where it has the authority to do so and considers this to be in its investors’ best interests.

CIBRA will keep its position under review and update this statement if its approach changes.