Bluegem Capital Partners LLP
FCA Regulatory Disclosure on the Stewardship Code
April 2026
Rule 2.2.3R of the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (“COBS”) requires an FCA-authorised firm to disclose the nature of its commitment to the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.
Effective from 1 January 2026, the Code has been substantially updated to support long-term, sustainable value creation while significantly reducing the reporting burden for signatories.
The purpose of the Code is to establish the core principles of effective stewardship and to set a high standard of transparency for asset owners, asset managers, and the service providers that support them.
The 2026 Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term, sustainable value for clients and beneficiaries”.
Adherence to the Code is voluntary.
Bluegem Capital Partners LLP (“Bluegem”, the “Firm”) has chosen not to commit to the Code for the following reasons:
Bluegem has chosen an alternative approach to stewardship consistent with its overall approach to responsible investing and environmental, social and governance issues, and considers that the principles behind this approach are aligned with those of the Code. Further details on Bluegem’s approach to responsible investing can be found at https://www.bluegemcp.com/responsible-investing.
The Firm determines its approach to stewardship on a case-by-case basis, taking into account the best approach to optimising portfolio company performance and outcomes.
Consequently, while Bluegem generally supports the objectives underlying the Code, the provisions of the Code are not considered to be relevant to the activities currently undertaken by the Firm. If Bluegem’s activities and approach change in such a manner that the provisions of the Code become relevant, the Firm will review its position and will amend this disclosure accordingly.
For further details on any of the above information, please contact enquiries@bluegemcp.com.