Policy updated: April 2021

Stewardship Policy

Positive Pennine is a trading style of Pennine Wealth Solutions LLP, which is authorised and regulated by the Financial Conduct Authority.

This policy statement sets out how Pennine Wealth Solution LLP (PWS) adopts control and procedures to ensure compliance with Article 3g of the Shareholder Rights Directive II and adherence to the EFAMA Stewardship Code.


Asset managers must act within strict statutory and regulatory requirements when managing the assets entrusted to them by clients. In certain investment strategies, asset managers may seek to preserve and/or enhance the value of the companies they invest in. through exercising voting rights and engagement with the management of the issuers. Where appropriate, asset managers should consider stewardship/engagement for all equity investment strategies.

Stewardship aims to promote the long-term success of companies in such a way that companies, investors and the economy benefits.

These requirements apply only to the extent that firms invest in shares traded on a regulated market.

The Pennine Wealth Solutions LLP (PWS) Service

We provide Financial Advisers with investment services that help their clients meet their objectives. Our core offering is a range of risk-profiled discretionary investment model portfolios designed to suit most investment styles. Our service is available through retail investment platforms built around our philosophy of making high-quality investment management accessible and affordable.

How PWS engages with the companies in which our clients have investments

Our underlying investment managers strategy, is one of direct and continuous engagement and contact with the management of the assets that we invest in.

How PWS monitors the companies in which our clients have investments

PWS believes an essential component of stewardship is effective monitoring of the companies we invest in. our monitoring includes research carried out by the underlying investment managers: –

  • Management meetings
  • Reviewing and analysing financial company reports
  • Reviewing company policies and procedures
  • Reviewing corporate culture and business models

Accounting to clients

The clients selected retail investment platform is responsible for sending clients their investment reports in accordance with regulatory requirements. We do not send clients reports on how PWS has discharged its stewardship duties because they mainly comprise ‘behind the scenes’ activities, often on a confidential basis.

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