Regulatory Disclosures


University of Cambridge Investment Management Limited (“UCIM”) is authorised and regulated by the Financial Conduct Authority in the UK with reference number 515843. UCIM is a private limited company incorporated in England and Wales with company number 06907395. Its registered address is The Old Schools, Trinity Lane, Cambridge CB2 1TN, UK.

UCIM is the investment manager of the Cambridge University Endowment Fund (the “Fund”) which is an unregulated collective investment scheme as defined in section 235 of FSMA. The Fund is not available to the general public for investment. The purpose of this website is to inform visitors about UCIM’s business and activities. The information on this website, including all opinions or other content, is not intended to and does not constitute financial, accounting, tax, legal, investment, consulting or other professional advice or services but is for information purposes only.

To the extent that this website contains information regarding past performance, you should be aware that past performance is not indicative of future results.

UCIM and the Fund are not authorised or regulated in any country outside the UK and it may be unlawful to access the content of this website from outside the UK. If you choose to access information on this site, you do so at your own risk and it is your responsibility to comply with the applicable laws and regulations in countries outside the UK, including in particular, the United States of America.

Shareholder Rights Directive II

The Shareholder Rights Directive II (SRD II) is a European Union (EU) directive which aims to encourage better shareholder engagement and improve transparency in the ownership of companies. SRD II applies to asset managers including full scope Alternative Investment Fund Managers such as University of Cambridge Investment Management Limited ("UCIM") that invest in shares which are traded on a regulated market in the EEA as well as ‘comparable’ markets situated outside of the EEA. Rule 2.2B.5.R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook requires an authorised firm to publicly disclose an engagement policy, and annually disclose how the engagement policy has been implemented including a general description of voting behaviour; or explain why an engagement policy does not apply.

UCIM is committed to using the University’s influence to engage with investment managers across the entire Cambridge University Endowment Fund ("Fund") to promote better shareholder engagement. The specific application of SRD II to UCIM’s activities relates to the portion of the Fund's assets that is managed by third-party managers in a segregated account structure, who in turn invest in shares that fall within the scope of the SRD II. UCIM has made the decision to delegate engagement with company management to its third-party investment managers, and therefore requires these managers to produce engagement policies and make disclosures. While UCIM supports the general objectives that underlie the rationale for the development of an engagement policy, UCIM acts in an oversight capacity to assess the engagement policies and disclosures of third-party investment managers to ensure that policies are fit for purpose and are being adhered to.

Disclosure of commitment to the Financial Reporting Council’s Stewardship Code

UCIM is not a signatory to the UK Stewardship Code due to the nature of our investment strategy and types of investments we make. However, we support the objectives that underlie the Code, and welcome the expansion of the 2020 Code to cover a broader range of asset classes and geographies. Cambridge University has established a Statement of Investment Responsibility which we align to. The policy outlines our commitment to incorporating sustainable investment factors into our investment decision making where such factors are relevant, while also acting in a manner that is consistent with our duties to CUEF.