Governance

Notwithstanding the broad powers of investment available to the Company as a closed-ended fund, the Board has adopted the following investment restrictions:

• no single holding shall constitute more than 10% of the Company’s total assets (calculated at the time of investment). The Board will pay particular attention to holdings which grow to represent more than 10% of total assets;
• the Company will not invest in unlisted securities;
• the Company will not invest in derivative instruments, whether for efficient portfolio management, gearing or investment purposes;
• the Company will not invest in other listed closed-ended investment funds.
• the Company shall not take legal or management control over any investments in its portfolio; and
• not more than 50% of the Company’s investments may be in securities which are not qualifying securities or government securities for the purposes of the UK ISA Regulations.

The Investment Adviser adopts a stock picking approach in the belief that a thorough analysis and understanding of a company is the best way to identify long-term superior growth prospects. This understanding begins with identifying those companies where the ownership structure and incumbent management are conducive to the realisation of the aim of achieving superior long-term earnings growth.

The Investment Adviser will seek to identify companies which enjoy certain key business characteristics including some or all of the following:

• a strong management record and team, and the confidence that the Investment Adviser has in that management’s ability to explain and account for its actions;
• proprietary technology and other factors which indicate a sustainable competitive advantage;
• a reasonable expectation that demand for their products or services will enjoy long-term growth; and
• an understanding that structural changes are likely to benefit rather than negatively impact that company’s prospects.

In analysing potential investments, the Investment Adviser will employ differing valuation techniques depending on their relevance to the business characteristics of a particular company. However, the underlying feature will be the sustainability and growth of free cashflow in the long-term.

Portfolio risk is mitigated by investment in a diversified spread of investments. The Investment Adviser is not constrained by benchmark weightings, sector, geographical location within Europe or market capitalisation or size of investee companies.

Any material change in the investment policy of the Company described above may only be made with the approval of shareholders by an ordinary resolution.

European Opportunities Trust PLC is a member of the Association of Investment Companies. It implements the principles and recommendations of the AIC’s Code of Corporate Governance.