Legal Notice

Silk Invest Limited is authorised and Regulated by the Financial Conduct Authority in the UK.

Silk Invest Limited is a registered investment adviser with the U.S. Securities and Exchange Commission.

We take our legal and fiduciary responsibilities very seriously. Before entering this site you should read and agree to the warnings and disclaimers below and accept to comply with the terms and conditions set forth therein.

Silk Invest Limited is incorporated in England and Wales under number 6603042.

The UK Financial Conduct Authority has granted Silk Invest Limited Part IV permission under the Financial Services and Markets Act 2000 at 17 September 2008.

Access to Silk Invest’s site is restricted to Non-U.S. Persons outside the United States within the meaning of Regulation S under the U.S. Securities Act of 1933, as amended (the “Securities Act”). As defined in the Securities Act, the term “U.S Person” means: (1) any natural person resident in the United States; (2) any partnership or corporation organised or incorporated under the laws of the United States; (3) any estate of which any executor or administrator is a U.S. person; (4) any trust of which any trustee is a U.S. person; (5) any agency or branch of a foreign entity located in the United States; (6) any non-discretionary account or similar account (other than an estate or trust) held by a dealer or other fiduciary for the benefit or account of a U.S. person; (7) any discretionary account or similar account (other than an estate or trust) held by a dealer or other fiduciary organised, incorporated, or (if an individual) resident in the United States; and (8) any partnership or corporation if: (A) organised or incorporated under the laws of any foreign jurisdiction; and (B) formed by a U.S. person principally for the purpose of investing in securities not registered under the Securities Act, unless it is organised or incorporated, and owned, by accredited investors (as defined in Rule 501(a)) who are not natural persons, estates or trusts.

Each person accessing, by so doing, acknowledges that: (1) it is not a U.S. person (within the meaning of Regulation S under the Securities Act) and is located outside the U.S. (within the meaning of Regulation S under the Securities Act); and (2) any securities described herein (A) have not been and will not be registered under the Securities Act or with any securities regulatory authority of any state or other jurisdiction and (B) may not be offered, sold, pledged or otherwise transferred except to persons outside the U.S. in accordance with Regulation S under the Securities Act pursuant to the terms of such securities.

Each person accessing this site, by so doing, acknowledges that in relation to persons in the United Kingdom, the information herein is directed only at persons who (i) fall within the classification or “professional investor” or “eligible counterparty” as outlined in the Financial Conduct Authority’s implementation of the MiFID Client Classification requirements, (ii) fall within the definition of “eligible investor” as defined in the various fund offering memorandums, prospectuses and subscription documentation, or (iii) are persons to whom this communication may otherwise lawfully be made (all of the persons in (i) to (iii) being together referred to as “relevant persons”). This communication must not be acted on or relied on by persons in the United Kingdom who are not relevant persons. Any investment or investment activity to which this communication relates is available in the United Kingdom only to relevant persons and will be engaged in only with relevant persons.

The information on this site is not and should not be construed as an offer, or a solicitation of an offer, to buy or sell any securities, Silk Invest funds or other financial instruments. Such offers and sales will be made only pursuant to the current prospectus for those securities, funds or other financial instruments, together with current financial statements (if available), a relevant subscription application and any other required documents, all of which must be read in their entirety. No action has been taken to permit a public offering in any jurisdiction where action would be required for that purpose. Each person accessing this site, by so doing, acknowledges that investment in any of the securities, funds or other financial instruments described herein may be restricted to qualified or experienced investors as defined in their relevant jurisdiction. This communication or the information herein must not be acted on or relied on by persons who are not such qualified or experienced investors as defined in their relevant jurisdiction. The information on this site is for information purposes only. Descriptions of any company or fund or their securities or the markets or developments mentioned herein are not intended to be complete. This document and/or information should not be regarded by recipients as a substitute for the exercise of their own judgment and has no regard to the specific investment objectives, financial situation or particular needs of any specific recipient. All information and opinions on this site are subject to change without notice, and Silk Invest Limited and its subsidiaries or affiliated companies, as appropriate (“Silk Invest”) are under no obligation to update or keep current the information contained on this site and accept no liability in respect of the accuracy or completeness of any information herein. In considering the prior performance information contained herein, prospective investors should bear in mind that past performance is not necessarily indicative of future results, and that there can be no assurance that the comparable results will be achieved. Not all securities, services or products mentioned on this site can be available in any jurisdiction.

The information contained on this site may not be reproduced, distributed or published, in whole or in part, for any purpose without the written permission of Silk Invest and Silk Invest accepts no liability whatsoever for the actions of third parties in this respect.

You agree that your use of this website and any dispute arising in relation to this website is subject to English law and you submit to the jurisdiction of the English courts in connection with any such dispute.


Under The FCA Conduct of Business Sourcebook (COBS) 2.2.3 R any firm other than a venture capital firm, which is managing investments for a professional client that is not a natural person must disclose clearly the following listed information on its website or another accessible form:
i. the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code; or
ii. where it does not commit to the Stewardship Code, its alternative investment strategy.
Firms that wish to do so may notify the FRC by email via that they have published a statement; details of each signatory, along with a link to its statement will be listed on the FRC’s website, according to the categories of asset managers, asset owners and service provider here:
The FRC’s Stewardship code guidance expects application on a “comply or explain” basis, although it’s not a rigid set of rules. Where a principle is not being complied with, a meaningful explanation should be delivered enabling the reader to understand the firm’s approach to stewardship. Firms may determine that some, but not all, of the provisions of the Stewardship Code are disproportionate in its case and set out as part of its disclosure why this is the case.
Silk Invest Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) as a MiFID investment management firm. Under COBS 2.2.3R of the FCA Handbook Silk Invest is required to make a public disclosure in relation to the nature of her commitment to the UK Financial Reporting Council’s Stewardship Code initially published in July 2010, and updated in September 2012. To this extent, Silk Invest is deemed to be “managing investments for professional clients that are not natural persons”, so this statement shall apply.
The Code was published by the Financial Reporting Council, UK independent regulator responsible for promoting high quality corporate governance and reporting with the sole aim of fostering investment. The Stewardship Code is directed at asset owners and asset managers with equity holdings in UK-listed companies and aims to enhance the quality of engagement between institutional investors and companies they invest in. Silk Invest supports the principle’s underlying the Code and also believe in the importance of corporate governance driven by efficient company’s management, senior leadership and strong boards members all of which ultimately protect and enhance shareholder value. Silk Invest also seek to engage with the managements of firms we own, co-owned or invest in to understand better the risks and returns and to achieve optimum value for our investors and we have also set out below the approach taken to the Code principles and explained this aforesaid approach to our business and partners. Although, our holdings in investee companies may not be significant, hence many of the Code principles will not be applied on grounds that they are not proportionate to our size of firm. Regardless, we will seek to review this statement on an annual basis and update accordingly and we will inform the FRC appropriately. Silk Invest can be contacted via should you require further information on our approach to the Stewardship Code.
Principle 1: Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
At Silk Invest, we strive to do our best in providing quality investment management service and advise to all our clients. We hereby state that we seek to comply with the Code to the best of our expertise and professional ability.
Principle 2: Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.
As we are regulated by the FCA, as a firm we are duty bound to identify and mitigate any conflicts of interest between ourselves, our clients, investors and among all parties that could result in a loss (s) to them. Silk Invest maintain a conflicts of interest policy and register to fulfil this requirement and we do not undertake any other business activities that may give rise to a conflict of interest as we do have fiduciary responsibility to act in the best interest of our clients and investors.
Principle 3: Institutional investors should monitor their investee companies.
Silk Invest Ltd’s investment objective is to deliver superior risk-adjusted investment returns by constructing a risk/reward-efficient portfolio across our focused market for the optimum benefit of our clientele and investors. By so doing, we review, assess, monitor and analyse each investee company’s governance, strategy and performance to ensure it continues to ensure our investment objectives and criteria are met.
Principle 4: Institutional investors should establish clear guidelines on when and how they will escalate their stewardship activities.
Silk Invest and her management are committed to and will take all reasonable action to preserve, protect and enhance the interests of our clients and investors via risk management review, feedbacks, engagement, proxy and meetings among other various effective medium we have in place at the firm.

Principle 5: Institutional investors should be willing to act collectively with other investors where appropriate
As a firm focused in the frontier market space, Our philosophy is that local presence is critical for making the right investment decisions and as such we believe we have sufficient expertise and knowledge of our market and investee companies alike to be able to deal with any concerns that we might have about their business activities, strategy, regulatory obligations or corporate governance all of which we help us make informed decision in order to decide on whether to exit a market, sector, zone, dispose of or reduce our holding so long such action will not breach legal, regulatory, market conduct or confidentiality obligations applicable.
Principle 6: Institutional investors should have a clear policy on voting and disclosure of voting activity
In line with Silk Invests commitment to provide quality investment management and advisory service to our clients to participate in a voting exercise of an investee company or exercise our vote in such a manner and that our decision will be to the best interest of our clients and investors.

Principle 7: Institutional investors should report periodically on their stewardship and voting activities.
Silk Invest will provide an account of our engagement and voting activities to our clients and investors on request and we will not make disclosure on the nature of that activity or conclusions drawn as they may be a confidential, sensitive or subjective information which are often used to inform our investment decisions as we reserve that right so long they are within the investment guidelines.