U.K. Regulatory Disclosures

U.K. Stewardship Code Statement

Pursuant to Rule 2.2.3R of the Financial Conduct Authority’s ("FCA") Conduct of Business Sourcebook, Balyasny Europe Asset Management LLP ("BEAM") is required to disclose whether it commits to the UK Financial Reporting Council's Stewardship Code (the "Code") or explain why it does not, having consideration to its investment approach.

BEAM provides investment advisory services to private investment funds, managing investments across a number of asset classes and markets globally following a number of diversified strategies. It also does not take an activist shareholder approach. As such, while BEAM generally supports the Code and its principles, it is not appropriate to commit to it given the nature of the funds’ investment strategies.

Modern Slavery Act Statement 2021

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) for Balyasny Europe Asset Management LLP, Balyasny International Asset Management Limited and Balyasny International Asset Management II Limited (collectively “Balyasny”) in respect of the financial year ended December 2021.

Organisational Structure and Business

Balyasny is a limited liability partnership incorporated in England and Wales. It is an investment management firm, authorised and regulated by the Financial Conduct Authority.

Balyasny’s Commitment

Balyasny is committed to conducting its business without modern slavery in either its business or its supply chains. Modern slavery as referred to in the Act includes slavery, servitude and forced or compulsory labour, and human trafficking.

Balyasny’s Supply Chain

As an investment management firm, Balyasny’s limited supply chain is predominantly made up of business and professional service organisations or providers. Having reviewed the requirements of the Act with regard to its business, Balyasny believes that its business and supply chain are at low risk of containing instances of modern slavery.

Policies and Procedure

Balyasny has various policies and procedures in place to ensure adherence to applicable laws and regulations, including in relation to bribery and corruption, money laundering, recruitment and employment, whistle blowing, discrimination and harassment, and escalation of issues. Appropriate due diligence is also undertaken when on-boarding vendors or suppliers with an expectation that all providers adhere to relevant laws.

These policies and procedures are periodically reviewed to ensure they remain effective, and training is periodically provided to staff ensuring awareness.

This statement has been approved by Dina Guirguis and Peter McConnon, Directors of the Board of Balyasny International Asset Management, member of Balyasny Europe Asset Management LLP, on 20 June 2021.

Balyasny Europe Asset Management LLP

Pillar 3 Disclosure and Policy

Introduction

Regulatory Context

The Pillar 3 disclosure of Balyasny Europe Asset Management LLP ("the Firm") is set out below as required by the FCA's "Prudential Sourcebook for Banks, Building Societies and Investment Firms" (BIPRU) specifically BIPRU 11.3.3 R. This is a requirement which stems from the Capital Requirements Directive ("CRD") which represents the European Union's application of the Basel Capital Accord. The regulatory aim of the disclosures is to improve market discipline.

Frequency

The Firm will be making Pillar 3 disclosures annually. The disclosures will be as at the Accounting Reference Date ("ARD").

Media and Location

The disclosure will be published on our website.

Verification

The information contained in this document has not been audited by the Firm's external auditors, as this is not a requirement, and does not constitute any form of financial statement and must not be relied upon in making any judgement on the Firm.

Materiality

The Firm regards information as material in disclosures if its omission or misstatement could change or influence the assessment or decision of a user relying on that information for the purpose of making economic decisions. If the Firm deems a certain disclosure to be immaterial, it may be omitted from this Statement.

Confidentiality

The Firm regards information as proprietary if sharing that information with the public would undermine its competitive position. Proprietary information may include information on products or systems which, if shared with competitors, would render the Firm's investments therein less valuable. Further, the Firm must regard information as confidential if there are obligations to customers or other counterparty relationships binding the Firm to confidentiality. In the event that any such information is omitted, we shall disclose such and explain the grounds why it has not been disclosed.

Summary

The CRD requirements have three pillars. Pillar 1 deals with minimum capital requirements; Pillar 2 deals with Internal Capital Adequacy Assessment Process ("ICAAP") undertaken by a firm and the Supervisory Review and Evaluation Process through which the Firm and Regulator satisfy themselves on the adequacy of capital held by the Firm in relation to the risks it faces and; Pillar 3 which deals with public disclosure of risk management policies, capital resources and capital requirements.

The regulatory aim of the disclosure is to improve market discipline.

The Firm is a MiFID Investment Management Firm. It acts solely as agent, so the main protection to our customers is provided through client money arrangements. The Firm's greatest risks have been identified as business and operational risk. The Firm is required to disclose its risk management objectives and policies for each separate category of risk which include the strategies and processes to manage those risks; the structure and organisation of the relevant risk management function or other appropriate arrangement; the scope and nature of risk reporting and measurement systems; and the policies for hedging and mitigating risk, and the strategies and processes for monitoring the continuing effectiveness of hedges and mitigants.

The Firm has assessed business and operational risks in its ICAAP and set out appropriate actions to manage them.

Credit risk is the risk of loss if another party fails to make due on its obligations to the Firm.

The Firm's main credit risk is the exposure to receivables from the U.S. affiliate, Balyasny Asset Management, LP ("BAM"), and/or other counterparties. This credit risk is considered low. The Firm's balances are separate from its affiliates and are placed with banks assigned high credit ratings.

Market risk is the risk of loss that arises from adverse movements in financial markets. The Firm does not engage in proprietary trading and therefore, the Firm has determined its market risk is limited to the Firm's exposure to any assets held on the Firm's Balance Sheet denominated in a foreign currency. The Firms Reporting Currency is GBP and all foreign currency assets are converted into GBP where possible on a regular basis.

Background to the Firm

The Firm is incorporated in the UK and is authorised and regulated by the FCA as a MiFID Investment Management Firm. The Firm's activities give it the BIPRU categorisation of a "Limited Licence" and a "BIPRU £50K" Base Capital firm.

The Firm is the sole entity regulated by the UK Financial Conduct Authority ("FCA").

Shareholder Rights Directive

Balyasny Europe Asset Management LLP is currently considering whether it will adopt an engagement policy pursuant to Article 3g of the amended EU Shareholder Rights Directive (Directive 2007/36/EC).  When that decision has been made, this webpage will be updated accordingly.

BEAM Annual Best Execution Disclosure

The BEAM Annual Best Execution Disclosure for 2019 is available here.

The BEAM Annual Best Execution Disclosure for 2020 is available here.