Stewardship Code Disclosures

Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2A.5, North Wall is required to make a public disclosure on its website in relation to the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code.

The Code was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in 2012, 2020 and 2026.

The Code is a voluntary framework that promotes the responsible allocation, management and oversight of capital to create long term sustainable value for clients and beneficiaries. It aims to enhance the quality of engagement between investors and the entities in which they invest. The Code encourages investors to consider long-term risks and opportunities, including impacts on the economy, environment, and society on which beneficiaries’ interests depend. It is applied on an “apply and explain” basis and it outlines how asset owners and asset managers can protect and enhance the value of the investments entrusted to them.

The FRC defines ‘stewardship’ as “the responsible allocation management, and oversight of capital to create long-term sustainable value for clients and beneficiaries.”

The Code comprises six Principles that can be summarized as follows:

  1. Signatories integrate stewardship and investment to deliver long-term sustainable value for their clients and beneficiaries;
  2. Signatories identify and respond to market-wide and systemic risks to promote well-functioning financial markets;
  3. Signatories engage to maintain or enhance the value of assets;
  4. Signatories actively exercise their rights and responsibilities;
  5. Signatories integrate stewardship considerations into their selection and oversight of external managers; and
  6. Signatories monitor and hold to account stewardship service providers.

Whilst supporting the objectives underlying the Code and adhering to the highest standards of corporate governance and due diligence, the Firm having considered the 2026 Code, believes that the Principles are not applicable to its investment activities at this time. Should that change in the future, the Firm will review its commitment to the Code and update this disclosure accordingly. This disclosure will be reviewed at least annually. For any questions regarding this disclosure email michael.daniell@northwallcap.com.

Disclosure last updated: January 2026