Key disclosure documents published by Devon Equity Management Limited:

Investment Philosophy

Our investment philosophy is consistently applied and coherent. There are no surprises in what we do.

Engagement Policy

Designed to increase asset manager transparency, boost stewardship and long-term decision making.

ESG Policy

ESG is integrated into the investment process at Devon.

Our Funds

We invest in European equities on behalf of European Opportunities Trust PLC
(a FTSE 250 investment trust), a Luxembourg UCITS SICAV (Devon Equity Funds) and institutional investors.

How to Invest

There are a number of ways to invest in our Funds. Please see listed below a full list of options:

Invest through a financial adviser, stockbroker or bank

We recommend that you discuss any financial decisions with a financial adviser, particularly if you are unsure whether an investment is suitable, as Devon is unable to provide investment advice. A financial adviser can provide advice on and facilitate investment into the company. Consider using or to find a financial adviser near to you.

Invest through an execution-only platform

An investment in an investment trust can also be executed through an execution-only platform. A transaction charge and other charges are payable to the platform for the provision of this service. A selection of platforms are shown below:

Alliance Trust Savings
AJBell Youinvest
Bestinvest / Tilney
Charles Stanley Direct
Hargreaves Lansdown
Halifax Share Dealing
Interactive Investor
Share Centre

Non-mainstream pooled investment products

The Company currently conducts its affairs, and intends to continue to conduct its affairs, so that the Company’s ordinary shares can be recommended by Independent Financial Advisers to ordinary retail investors in accordance with the FCA’s rules in relation to non-mainstream pooled investment products (NMPI).The Company’s ordinary shares are excluded from the FCA’s restrictions which apply to non-mainstream pooled investment products because they are shares in an investment trust.

Investment Policy

The Company Devon Equity Management will, at all times, invest and manage its assets, with the objective of spreading risk and in accordance with the following policies:

Investment Restrictions

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.

Borrowing limits

The Company will, at all times, invest and manage its assets, with the objective of spreading risk and in accordance with the following policies:

Investment Approach

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

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.

Benchmark Index

MSCI Europe Index – EUR Total Return (MXEU)

Compliance with UCITS investment restrictions : While Devon Equity Funds is structured as a UCITS in Luxembourg.


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.


Important Information