Statement of Commitment to the UK Stewardship Code

Oakglen Wealth Limited (“Oakglen”, “we”, “us”, “our”) is required under Financial Conduct Authority rules to disclose the nature of its commitment to the Financial Reporting Council’s UK Stewardship Code 2026 (the “Code”) or, where it does not commit to the Code, to explain its alternative investment approach. Becoming a signatory to the Code is voluntary. This statement explains Oakglen’s proportionate approach to stewardship, reflecting the nature, scale and complexity of our business and investment activities.

The UK Stewardship Code 2026 establishes core Principles of effective stewardship and a high standard of transparency for asset owners, asset managers and relevant service providers. It defines stewardship as the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries. It therefore permits organisations to explain their approach in a manner aligned with their own strategy and circumstances.

The Code recognises that organisations differ in size, business model, investment approach, asset classes, rights and influence. Oakglen therefore applies stewardship proportionately by focusing on matters that are financially material to client outcomes and on activities where we have a realistic ability to influence or hold another party to account. Where a Principle is not applicable, or applies only to part of our business, we explain the reason, the relevant limitation and any alternative oversight undertaken. Oakglen is not currently a signatory to the Code and does not represent that it complies with every reporting requirement applicable to signatories. Nevertheless, we support the Code’s purpose and apply stewardship practices where these are relevant to our investment activities and proportionate to the nature, scale and complexity of our business. Our approach focuses on integrating stewardship into investment decisions, identifying material market-wide and systemic risks, engaging where we have a realistic ability to influence outcomes, exercising rights where appropriate, and overseeing relevant third-party providers.

Oakglen’s proportionate approach is set out below under the five Policy and Context Disclosures and the six Activities and Outcomes Principles relevant to asset managers. As Oakglen is not a signatory, this statement is not an FRC submission. It is reviewed at least annually and updated where changes to our business model, investment approach, governance, resources or stewardship practices make this necessary.

Policy and Context Disclosures

Disclosure A – Organisation, investment beliefs and stewardship approach

Oakglen provides discretionary investment management services to its clients. Our stewardship approach is informed by our client base, investment mandates, time horizons, asset allocation, use of direct investments and collective investment vehicles, and the rights and influence available to us. We prioritise stewardship activity where an issue is financially material, relevant to client objectives and capable of being influenced through our investment process.

Disclosure B – Governance and resources

The Board has ultimate oversight of Oakglen’s stewardship approach. The Investment Committee oversees its practical integration into investment decision-making, supported by relevant investment, risk and compliance personnel. Stewardship responsibilities are embedded within existing roles rather than maintained as a separate dedicated function, which is proportionate to our size and operating model. We support these responsibilities through investment research, portfolio monitoring, risk and compliance systems, committee reporting and relevant professional development. External research and specialist providers may be used where they add expertise or coverage that would not be efficient to maintain internally.

Disclosure C – Policies, processes and review

Oakglen maintains policies, procedures, systems and controls relevant to stewardship, including its portfolio management, responsible investment, conflicts of interest, risk management, compliance and third-party oversight arrangements. These are reviewed in accordance with the firm’s policy review cycle and sooner where regulatory, business or operational developments require. Material changes are considered through the relevant governance forum and approved at the appropriate level, including by the Governance, Risk Management & Compliance Committee or the Board. Independent assurance may be obtained from external audit or compliance specialists where proportionate to the risk and scope of the review.

Disclosure D – Conflicts of interest

Oakglen maintains a conflicts of interest policy and arrangements to identify, record, prevent or manage conflicts between the firm, its clients and different clients. Stewardship-related conflicts may arise, for example, where Oakglen or a connected party has a business relationship with an issuer, where different client mandates imply different voting or engagement preferences, or where personal or corporate relationships could affect an investment or voting decision. Relevant conflicts are escalated through the firm’s established governance arrangements and managed in the best interests of clients, including through disclosure, information barriers, independent review, abstention or other appropriate controls. The policy is kept under periodic review and is available on request.

Disclosure E – Dialogue with clients

Oakglen seeks to understand each client’s investment objectives, risk profile, time horizon and relevant preferences, including any clearly defined investment restrictions that can be implemented effectively. We communicate through regular client reviews, portfolio reporting and investment commentary prepared by our investment specialists. Feedback obtained through these channels is considered by the investment and governance teams and may inform investment restrictions, communications, stewardship priorities or the review of relevant policies and processes. Where feedback does not result in a change, we retain discretion to explain the reasons, including mandate, operational or fiduciary constraints.

Activities and Outcomes Principles

Principle 1 – Integrating stewardship and investment

Oakglen integrates stewardship considerations into investment research, security selection, portfolio construction and ongoing monitoring where they are financially material and relevant to client objectives. Priority themes are determined through the investment process and may include governance, strategy, financial resilience, environmental and social factors, and climate-related risks and opportunities. The depth and method of stewardship activity differ according to asset class, geography, investment structure, materiality and the rights and influence available to us.

Principle 2 – Promoting well-functioning markets

Oakglen identifies market-wide and systemic risks that may materially affect long-term client outcomes through investment research, portfolio monitoring, risk oversight and Investment Committee review. Relevant risks may include market liquidity, concentration, valuation, geopolitical developments, climate change, cyber risk and disruption to financial-market infrastructure. Our response is proportionate to our size and influence and may include adjusting investment assumptions or portfolio exposures, engaging with issuers or service providers, participating selectively in industry or regulatory initiatives, and escalating concerns where this is likely to be effective.

Principle 3 – Engagement

Oakglen engages selectively where an issue is material to an investment case, engagement has a reasonable prospect of protecting or enhancing value, and the expected benefit is proportionate to the resources required. Engagement may be conducted directly, through meetings or correspondence with issuers, through fund managers or other intermediaries, or collaboratively where this is lawful and likely to be more effective. For each material engagement, we seek to record the issue, objective, method, progress, outcome and any next step. If progress is insufficient, escalation may include further dialogue, engagement with senior representatives, collaboration, voting action, reducing exposure or divestment.

Principle 4 – Exercising rights and responsibilities

Oakglen considers the rights and responsibilities available for each asset class and investment structure. For listed equities, the Investment Committee determines when and how voting rights are exercised in clients’ best interests, taking account of the subject matter, materiality of the holding, realistic influence, relevant mandate terms, geography and any conflict of interest.

Principle 5 – Selection and oversight of external managers

Where Oakglen invests through external managers, stewardship considerations are incorporated proportionately into initial due diligence, selection, appointment and ongoing monitoring. Relevant considerations may include the manager’s stewardship policies, governance, resources, engagement and voting approach, conflicts management, reporting quality and alignment with Oakglen’s expectations and client mandates. Material concerns are raised with the manager and tracked through the oversight process. Escalation may include enhanced monitoring, requesting remedial action, restricting further investment or replacing the manager where this is proportionate and in clients’ best interests.

Principle 6 – Monitoring stewardship service providers

Oakglen identifies any third parties that directly support its stewardship activities, such as proxy advisers, investment consultants, external engagement providers, research providers or voting platforms. Before appointment, and periodically thereafter, we assess whether their services support our stewardship objectives, including the quality, accuracy, timeliness and relevance of their work and their management of conflicts. Material service issues are documented, challenged and escalated through the relevant oversight arrangements.

Last updated in October 2026