Effective from 1 January 2026, the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”) introduces a streamlined structure for reporting and is divided into two parts: Policy and Context Disclosure and Activities and Outcomes Report.
In the 2026 version, the Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries”.
There are six Principles of the Code that apply to asset owners and asset managers. These are:
1. Integrating stewardship and investment
2. Promoting well-functioning markets
3. Engagement
4. Exercising rights and responsibilities
5. Selection and oversight of managers
6. Monitoring service providers
The FRC requires that firms aiming to be signatories to the Code must produce an annual Stewardship Report explaining how they have applied the Code in the previous 12 months. The FRC will evaluate Reports against an assessment framework and those meeting the reporting expectations will be listed as signatories to the Code.
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 FRC’s UK Stewardship Code or, where it does not commit to the code, its alternative investment strategy.
The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.
Adherence to the Code is voluntary. MIML is a privately owned investment management firm focused on real estate and real estate related investment opportunities. While MIML supports the objectives that underlie the Code, the provisions of the Code are not considered to be wholly relevant to the activities currently undertaken by the Firm. Therefore, MIML has chosen an alternative approach to stewardship consistent with its overall approach to Responsible Investment/ESG/Sustainable Finance.
If MIML’s activities changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.
For further details on any of the above information, please contact Steve Hall.