Environmental, Social and Corporate Governance Investing

At Hudson Bay we recognize and respect the fact that this is a very important issue and have created the ability of Environmental, Social and Corporate Governance (“ESG”) sensitive organizations to invest with us. Investors that are subject to an ESG or Socially Responsible Investing (“SRI”) mandate are offered the option to acquire bespoke tranches (the “SRI Tranches”) of Hudson Bay Fund LP or Hudson Bay International Fund Ltd. (each, a “Fund”) that enable them to invest in the Fund in a manner that respects their particular ESG mandates. This is accomplished by allocating profits and losses attributable to portfolio investments that would violate their ESG mandate away from their accounts (the “Allocation Away Methodology”). In this regard, SRI Tranches are customizable based on the SRI Investor’s specific ESG mandates. For example, an SRI Investor may desire to avoid all exposure to investments in the securities of fossil fuel-related companies. In this case, profits and losses from fossil fuel investments in our portfolio will not be allocated to the SRI Investor. Details of the Allocation Away Methodology are set forth in the Funds’ Confidential Private Placement Memoranda.

As discussed above, SRI Tranches are customizable based on the SRI Investor’s specific ESG mandate. ESG factors are therefore considered based on the particular SRI Investor’s sensitivities and request. While there is no impact on portfolio design, the investment return of a particular SRI Investor’s may differ from those investors who are not SRI Investors as the applicable SRI Tranche will not be allocated certain profits and losses related to certain portfolio positions which would violate that investor’s ESG mandate. The terms of the SRI Tranches are further discussed in the Funds’ Private Placement Memoranda.

In addition, while at a firm level we do not specifically impose ESG policies on our investment professionals, many of our PMs may take ESG into account when evaluating whether to invest in a particular issuer. Understanding “G” (governance, management and shareholder incentive alignments) is an extremely important and core part of the research process for several of our PM teams. For example, within the event space, we are invested in several discount to NAV, holding company transactions within the Liberty Media complex, and corporate governance and incentive alignment with shareholders is a key factor in our evaluation and analysis of the risks, opportunities, and potential outcomes of the trade.

While “E” and “S” concerns are more situational and case by case depending on the PM, several PMs do take these factors into account when investing both from a philosophical perspective as well as from the perspective of how these factors will affect issuer performance. For example, within the TMT sector, while it’s not often that a media, telco, or Internet company would have any environmental impact, it’s certainly possible to imagine a social platform having an indirect impact, or perhaps an infrastructure or e-commerce player having a gradually increasing impact, which could raise the brow of regulators and impact stock prices. Social is an emerging consideration in the sector, as many digital platforms (social networking, e-commerce, and search) will be increasingly under scrutiny by regulators for consumer protections (pricing and privacy both come to mind). Therefore, our team takes that into account when evaluating companies.

ESG considerations are becoming an increasingly important consideration in the credit space. Issuers have started to issue “Green Bonds” where the use of proceeds is ear marked for ESG purposes. These bonds typically trade better than normal issues because they have scarcity value and because investors need them to fulfill quotas for ESG dedicated funds. As a result, our PM’s have started to incorporate whether an issue is a Green Bond into their investment process.

More broadly we have started to see investors include ESG into their investment mandates and issuer risk evaluations. Companies with poor ESG profiles may have less support from the investment community, which then becomes a headwind to their credit valuation. Therefore, all else being equal, we would rather own a company with a good ESG profile than a poor one from an investment perspective.

ESG is also an important consideration when it comes to credit quality itself – companies with negative environmental impact (i.e. oil and gas), negative social implications (i.e. tobacco), or poor governance (i.e. companies with high executive payout and poor track records) – are potentially companies that have a higher risk profile in general. It therefore becomes an important consideration as part of the broader investment/risk process.

We are very open to accommodating investor specific SRI and ESG concerns and would welcome potential investors to approach us to discuss the various options that we can provide.

Shareholders Rights Directive II (‘SRD II’ - 2017/828) Statement
Article 3g of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as HBC UK LLP to either:


The above engagement policy is limited to the extent that a firm invests on behalf of investors in shares traded on a regulated market (or on third country markets that meet comparable requirements and where the shares dealt in are of a quality comparable to those in a regulated market in the UK).

The firm’s investment strategy is such that whilst the firm may invest in shares traded on a regulated market (or comparable market), the resultant holdings are for investment purposes and the firm does not take explicitly activist positions.

While HBC UK LLP generally supports the objectives that underlie SRD II, for the above reason the firm has chosen not to produce an engagement policy at this time. The Firm will keep its approach to the Code under periodic review and if its investment strategies change in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.
Hudson Bay Capital UK LLP (“HBC UK LLP” or “Firm”) Stewardship Code Disclosure
Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2A.5, HBC UK LLP is required to make a public disclosure on its website in relation to the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code.

The Code was first published by the FRC in July 2010 and it was updated in September 2012. Subsequently, the FRC published the new UK Stewardship Code 2020 (“2020 Code”), which took effect from 1 January 2020, and consists of 12 Principles for asset managers and asset owners, and six Principles for service providers.

The Code applies on a ‘comply or explain’ basis and is voluntary, aiming at enhancing the quality of engagement between institutional investors and companies, to help improve long-term returns to shareholders and provide for the efficient exercise of governance responsibilities by setting out good practice on engagement with investee companies that institutional investors should aspire to.

The FRC defines ‘stewardship’ as ‘the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.’

The 2020 Code Principles are:

  1. Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
  2. Signatories’ governance, resources and incentives support stewardship.
  3. Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first.
  4. Signatories identify and respond to market-wide and systemic risks to promote a well-functioning financial system.
  5. Signatories review their policies, assure their processes and assess the effectiveness of their activities.
  6. Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.
  7. Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.
  8. Signatories monitor and hold to account managers and/or service providers.
  9. Signatories engage with issuers to maintain or enhance the value of assets.
  10. Signatories, where necessary, participate in collaborative engagement to influence issuers.
  11. Signatories, where necessary, escalate stewardship activities to influence issuers.
  12. Signatories actively exercise their rights and responsibilities.

Whilst supporting the objectives underlying the Code and adhering to the highest standards of corporate governance and due diligence in respect of its investments the Firm, having considered the 2020 Code, believes that the Principles are not applicable to its investment activities at this time. Should that change in the future, the Firm will review its commitment to the Code and update this disclosure accordingly. This disclosure will be reviewed at least annually. For any questions regarding this disclosure email jkhan@hudsonbaycapital.com.

Disclosure last updated: 13/09/2024
Terms of Use
Hudson Bay’s operations are speculative and involve a high degree of risk. In reviewing the content of this website (the “Website”) you must keep in mind the speculative and unpredictable nature of the markets in which Hudson Bay trades and that its performance and experience to date may not be indicative, or even representative, of its future operations.

Past results are not necessarily indicative of future performance. Hudson Bay investors could lose all or substantially all of their investment at any given time and from time to time, with a corresponding materially adverse effect on Hudson Bay itself. The Website does not constitute an offer to sell or the solicitation of an offer to buy any of Hudson Bay’s advisory services or products. Any such offer or solicitation would be subject to material legal restrictions and requirements; the Website neither complies nor attempts to comply with any of these. The information contained in the Website does not purport to be complete or accurate and is qualified in its entirety by reference to the information set forth in the applicable operative documents for Hudson Bay advisory services and products, which contain descriptions of the material terms (including, but not limited to, risk factors, conflicts of interest and tax implications) relating to any such investment. No one may rely on any information in the Website for purposes of making any form of investment decision or commitment.

To the extent permitted by applicable law, neither Hudson Bay Capital Management LP, Hudson Bay Capital Associates LLC, nor their respective affiliates, officers, directors, employees, principals or agents (collectively, "Hudson Bay") will be liable to you or any other person for any errors or omissions in the production or content of the Website nor will they under any circumstances be liable to you or any other person for any loss or damage (whether direct, indirect, special, incidental, economic, or consequential, exemplary or punitive) arising from, connected with, or relating to the use of, or inability to use, the Website, or any action or decision made by you or any other person in reliance on the Website (which you agree not to take on the basis of any of the information set forth herein), any material misstatements or omissions in the information presented, or any unauthorized use or reproduction of the Website.

The Website may be updated at any time without notice to you, and any changes will be binding upon you if you continue to use the Website. By entering this Website, you acknowledge that all of the information contained herein shall be held in strict confidence by you.

The information, software and services published on this website may include inaccuracies or typographical errors. Due to various factors, including the inherent possibility of human and mechanical error, the accuracy, completeness, timeliness and correct sequencing of such information, software and services and the results obtained from their use are in no respects guaranteed by Hudson Bay or any persons creating or transmitting such information, software and services and none of the foregoing should be relied upon.
User Agreement

By accessing or using this Hudson Bay Capital Management LP and its affiliates (collectively, "Hudson Bay") website (the "Site"), you hereby accept and agree to comply with the terms and conditions set forth in this User Agreement. This User Agreement is a binding agreement between you and Hudson Bay, and governs your access and use of the Site, which includes any text, graphics, user interfaces, information, data, tools, products, services and other content (together, "Content") available on or through the Site. You may contact Hudson Bay by e-mail at IR@hudsonbaycapital.com with questions about the terms and conditions of this User Agreement.

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Privacy Notice

(April 2023)

This notice (this “Privacy Notice”) is provided by Hudson Bay Capital Management LP and its affiliates (collectively, “we”, “us”, or “HBC”), and sets forth the policies of HBC for the collection, recording, storage, use, retrieval, altering, erasing and disclosing (collectively, “processing”) and protection of personal information relating to current, prospective and former investors (collectively, “Investors”) in the investment funds and other vehicles (each, a “Fund”) advised by HBC. This Privacy Notice may be changed at any time, provided a notice of such change is given to you.

References to "you" or an "Investor" in this Privacy Notice mean any Investor who is an individual, or any individual connected with an Investor who is a legal person (each such individual, a “data subject”), as applicable.

Capitalized terms used herein but not defined herein shall have the meanings assigned to them in the Confidential Private Placement Memorandum relating to the relevant Fund, as may be supplemented, updated or modified from time to time (the “Memorandum”).

The types of personal data we may collect and use

The categories of personal data we may collect include names, residential addresses or other contact details, signature, nationality, tax identification number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds details or other sensitive information, such as certain special categories of data contained in the relevant materials or documents.

How we collect personal data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; and (ii) information that we obtain in relation to any transactions between you and us.

We may also receive your personal information from third parties or other sources, such as our affiliates, the administrator of the Funds (the “Administrator”), publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

Using your personal data: the legal basis and purposes

We may process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), including where this is necessary for the performance of a contract we have entered into with you, direct marketing of our products and services, monitoring and analyzing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction over our business). Your personal data will be processed in accordance with the applicable law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in your subscription in the applicable Fund being rejected, or compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How we may share your personal data

We may disclose information about you to our affiliates or third parties, including the Administrator, prime brokers, custodians and executing brokers, and other trading counterparties, as applicable, for our everyday business purposes, such as to facilitate transactions by the Funds, maintain your account(s), or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information about an Investor in order to accept subscriptions from them or to facilitate the establishment of trading relationships with executing brokers or other trading counterparties. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at +1 212-571-1244. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.

We do not share your information with non-affiliates for them to market their own services to you.

Retention periods and security measures

Personal data will be retained for the duration of your investment and for a minimum period of five to seven years after a redemption or withdrawal, as applicable. We may retain personal data for a longer period, for example for the purposes of marketing our products and services or compliance with applicable law. From time to time, we may review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with the applicable law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of the applicable law.

Who to contact about this Privacy Notice

Please contact Investor Relations at +1 212-571-1244 for any questions about this Privacy Notice or requests with regards to the personal data we hold.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. US state laws may give you additional rights to limit sharing.

For more specific information or requests in relation to the processing of personal data by the Administrator, prime brokers, custodians or any other service provider to the Funds, you may also contact the relevant service provider directly by visiting their websites.

Additional Information for Residents of the United Kingdom:

Personal Data Processed in Third Countries. Your personal information will be processed in the United States, and other countries outside the UK (“Third Countries”), that may not offer the same level of data protection as that afforded by the UK’s data protection laws, including the UK General Data Protection Regulation (“GDPR”). We will process personal data (or ensure that it is processed) in such Third Countries subject to appropriate safeguards and in accordance with the requirements of applicable law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries.

Your rights. You may have certain rights under the GDPR (or the DPA as defined below) in respect of the personal data we hold and which you may exercise. These rights are:

Please note that the right to be forgotten that applies in certain circumstances is not likely to be available in respect of the personal data we collect to satisfy our legal or regulatory obligations, as described above.

Complaining to the ICO

You have the right to complain to the Information Commissioner’s Office (“ICO”). Further information is available from the ICO’s website.

Additional Information for investors into funds organized under the laws of the Cayman Islands

For the purposes of the Cayman Islands Data Protection Act (as amended) (the “DPA”) a Cayman Islands Fund is a data controller. The rights applicable to data subjects under the DPA are similar to those of the GDPR. Where personal data related to Cayman Islands fund investors is transferred outside of the Cayman Islands this must only be transferred to another country or territory that provides an adequate level of protection, and if necessary, arrangements similar to those applicable under GDPR or as provided for by the relevant competent authority in the Cayman Islands shall also be required.

Use of cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

You can also click on “Cookie Preferences” on our website and change your preferences as to how we use cookies.

Recording and monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of:

Copies of recordings may be stored for a period of five years, or such other longer period as we may determine from time to time.