Under COBS 2.2B.5R of the FCA Handbook, the Firm is required to develop and publicly disclose an Engagement   Policy   (per   COBS   2.2B.6R)   and   make   subsequent   annual   disclosures   of   the implementation of that Engagement Policy, OR publicly disclose a clear and reasoned explanation of why the Firm has chosen not to do so.

GCW pursues a number of investment strategies, which in general aim to help individuals preserve and grow their wealth, depending on their risk profiles. In the case of direct investments in companies, GCW may engage with the management of those companies, including voting on matters which we consider material to the interests of our clients. In such cases, our diligence and analysis enable us to form views on the activities, strategy and performance of those companies, and to use our voting rights and access to  management  to  express  these  views.  We  may  also  engage  with  other  shareholders  and stakeholders, where it is appropriate and consistent with our strategy and the interests of our clients. However, many of our investments are in fund vehicles and not direct investments in companies.

We may also engage with other shareholders and stakeholders, where it is appropriate AND consistent with our strategy and the interests of our client(s).  

The Firm is considering its position on an ongoing basis with respect to its obligations above, however, at this point, the Firm does not consider that it is appropriate for it to have a formal Engagement Policy, due to its investment approach and size.