FCA Rules (COBS 2.2B) impose the requirements of the Shareholder Rights Directive (“SRD”) on full-scope UK AIFMs and UK MiFID investment firms that provides portfolio management services to the extent the firm invests on behalf of investors in shares traded on a regulated market.
Gravis Capital Management Ltd (“GCM”)
GCM manages two infrastructure debt funds. GCP Infrastructure Investments Ltd is focused on investment in UK infrastructure debt secured against projects generating long-dated, predictable, public sector cash flows. GCP Asset Backed Income Fund Ltd is focused on investment predominantly in debt secured against physical assets and/or contracted cash flows which are predominantly UK based.
The investment strategies of the funds managed by GCM do not currently involve investing in shares traded on a regulated market and GCM will not therefore be publishing an engagement policy as defined in the SRD for these funds. Should the investment strategies change, GCM will review its obligations under the SRD and amend this disclosure as necessary.
Gravis Advisory Limited (“GAL”)
GAL is the investment manager to four open ended funds, the TM Gravis UK Infrastructure Income Fund, the TM Gravis Clean Energy Income Fund, the TM Gravis UK Listed Property (PAIF) Fund and the TM Gravis Digital Infrastructure Income Fund.
GAL believes in a long-term approach to investment and seeks to deliver stable, predictable returns by investing in companies with sustainable business models and long dated dependable cashflows.
The detailed Voting and Engagement Policy explains GAL’s approach to active ownership, including engagement and voting and can be viewed here.
Voting forms an important part of GAL’s investment strategy and the latest annual Voting and Engagement report can be viewed here.
December 2025
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