Statement on the UK Stewardship Code

Eighteen48 Partners Limited’s (the “Company”) approach in relation to engagement with issuers and their management, is determined on a global basis.A consistent global approach is taken to engagement with issuers and their management in all of the jurisdictions in which the Company invests and, consequently, the Company does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction and feels that the Code is not appropriate to the Company’s business model.

However, whilst the Company has not made a formal commitment of compliance with the Code, its alternative investment strategy, is generally supportive of the spirit and aims of good stewardship as contained within the Code. As such, in practice, the Company would take into consideration the principles as set out in the Code.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice.Should the Company’s position change we will review our commitment to the Code and make appropriate disclosure at that time.For further details on any of the above information please contact the Company’s Compliance Officer.

Statement in Relation to the Shareholder Rights Directive II

The Second Shareholder Rights Directive (“SRD”), which took effect in the UK on 10 June 2019, aims to improve shareholder engagement and increase transparency around stewardship. The Company invests in listed equities and as such we are required to disclose and make publicly available our policies on how we engage with other shareholders and the companies that we invest in, and how our strategies create long-term value.

The Company invests for the long term across all asset classes, both through funds and directly in public and private markets. We serve professional investors, sophisticated families, and institutions.

As a multi-strategy investment manager, the Company does not deal in listed equities as an integral part of its core investment strategy.  However, when holding listed equities generally the Company’s approach is to proxy vote in line with management recommendations except in exceptional circumstances. The Company considers this sufficient considering the low volume of business involving listed equities and does not otherwise consider shareholder engagement in its investment strategy.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Company’s position change we will review our commitment to SRD and make appropriate disclosure at that time.

Statement on the Sustainable Finance Disclosure Regulation (“SFDR”)

Eighteen48 Partners does not consider adverse impacts of investment decisions on sustainability factors. As such we do not currently host a section on our website dedicated to SFDR at this time. However, we have ensured/confirm that the appropriate disclosures with regards to PAI and sustainability risk have been included within the Funds Supplements taking into consideration the investment strategy and composition of the Fund.

MiFIDPRU Remuneration Disclosure


TheFinancial Conduct Authority (“FCA” or “regulator”) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Eighteen48. In particular, Chapter 8 of MIFIDPRU (“MIFIDPRU 8” or the “public disclosures requirements”) sets out public disclosure obligations with which the Firm must comply, further to those prudential obligations.

Eighteen48 is classified under MIFIDPRU as a small and non-interconnected investment firm (“SNI MIFIDPRU investment firm”). As such, MIFIDPRU 8 requires Eighteen48 to disclose information regarding the Firm’s remuneration policy and practices.

The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture, and to assist stakeholders in making more informed decisions about their relationship with the Firm.

This document has been prepared by Eighteen48 in accordance with the requirements ofMIFPRU 8 and is verified by Eighteen48. Unless otherwise stated, all figures are as at the 31 December 2021 financial year-end.


As an SNI MIFIDPRU investment firm, Eighteen48 is subject to the basic requirements of the MIFIDPRU Remuneration code. Eighteen48, as an alternatives investment fund manager, is also subject to the AIFM Remuneration Code. The purpose of the requirements on remuneration are to:

  • Promote effective risk management in the long-term interests of the Firm and its clients;
  • Ensure alignment between risk and individual reward;
  • Support positive behaviours and healthy firm cultures; and
  • Discourage behaviours that can lead to misconduct and poor customer outcomes.

The objective of Eighteen48’s remuneration policies and practices are to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.

In addition, Eighteen48 recognises that remuneration is a key component in how the Firm attracts, motivates and retains quality staff and sustains consistently high levels of performance, productivity and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and greatest competitive advantage.

Eighteen48 is committed to excellence, teamwork, ethical behaviour and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude and results.


The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance as well as the financial performance of each business unit, and the financial and non-financial performance of the individual in contributing to the Firm’s success.

All staff members are eligible to receive variable remuneration.  Variable compensation is based on an individual’s performance against their objectives.  An individual’s performance is assessed by annual, and mid-year performance reviews.  

The Firm’s variable remuneration is based on the assessment of the individual’s performance and competence in his/her role within the business during a defined period. Examples of factors used by an individual’s supervisor to measure individual performance include job knowledge and work quality, teamwork, relationships and client focus, communications, adherence to Group policies, behaviour alignment to sustainability risks, contributions to ESG factors, as applicable, and innovation.  The Firm primarily assesses an employee’s individual performance on non-financial criteria, which would include, among other things, how the employee personally exhibits and contributes to the promotion of the Firm’s core values listed below:

Putting the client first

  • Always act in our clients’ best interests and safeguard their assets as if they were our own.
  • Build long-term relationships based on trust and underpinned by our alignment with clients.
  • Preserve client confidences and confidentiality.
  • Manage client and firm resources cost-effectively.
  • Act with integrity at all times, regardless of our own interests.

Demanding excellence

  • Embrace high expectations and celebrate the quality of work done.
  • Be intellectually rigorous, curious and creative.
  • Encourage debate in a spirit of constructive engagement.
  • Sustain an ‘idea meritocracy’ anchored in thorough research, rational scepticism, humility and self-awareness
  • Always look for ways to improve what we do and to expand our knowledge.

Acting as a partner

  • Cultivate an environment that is non-hierarchical, inclusive and collaborative.
  • Show leadership, initiative and ownership in all projects and tasks.
  • Support and help our colleagues to the best of our ability.
  • Act with respect, transparency and intellectual honesty towards clients and colleagues.
  • Take collective responsibility for decisions made.
  • Hold each other accountable for upholding our values on a daily basis.

The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration.

The performance period runs from January to December, in accordance with the Firm’s year end.  This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.


The Remuneration Committee is responsible for setting and overseeing the implementation of Eighteen48’s remuneration policy and practices. The Remuneration Committee:

  • Is appropriately staffed (the Remuneration Committee currently includes the Co-founders/CEO, CFO, and COO) to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital and liquidity;
  • To avoid any conflicts of interest, awards to the members of the Remuneration Committee are specifically reviewed and approved by the co-founders;
  • Prepares decisions regarding remuneration, including decisions which have implications for the risk and risk management of the Firm;
  • Ensures that the remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors and other stakeholders in the Firm; and
  • Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of the Firm and of its clients.

Eighteen48’s remuneration policy and practices are reviewed annually by the RemunerationCommittee.


For the financial year 1 January 2022 to 31 December 2022, the total amount of remuneration awarded to all staff was £4,239k, of which £3,014k comprised the fixed component of remuneration, and £1,224k comprised the variable component. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the Firm itself, directors, employees of other entities in the group, employees of joint service companies, and secondees.