Quarterlytics / Financial Services / Asset Management / Menhaden PLC

Menhaden PLC

mhn · LSE Financial Services
Claim this profile
Ticker mhn
Exchange LSE
Sector Financial Services
Industry Asset Management
Employees 11-50
← All annual reports
FY2021 Annual Report · Menhaden PLC
Sign in to download
Loading PDF…
Menhaden Resource 

Efficiency 

Menhaden Resource Efficiency PLC
Annual Report for the year ended 31 December 2021

Menhaden Resource Efficiency PLC – Annual Report

Company Summary

Menhaden Resource Efficiency PLC (formerly Menhaden PLC) (the “Company”) is an investment trust. Its shares are 
listed on the premium segment of the Official List and traded on the main market of the London Stock Exchange. The 
Company is a member of the Association of Investment Companies (“AIC”).

Menhaden Capital PLC
Annual Report for the period from incorporation on
30 September 2014 to 31 December 2015

Investment Objective

The Company aims to generate long-term shareholder returns, predominantly in the form of capital growth, by investing 
in businesses and opportunities that  are demonstrably delivering or benefiting significantly from the efficient use of 
energy and resources irrespective of their size, location or stage of development.

Management

The Company employs Frostrow Capital LLP (“Frostrow”) as its Alternative Investment Fund Manager (“AIFM”) to provide 
company management, company secretarial, administrative and marketing services. Frostrow and the Company have 
jointly appointed Menhaden Capital Management LLP as the Portfolio Manager. Further details of these appointments 
are provided on pages 23 and 24.

Capital Structure

The Company’s capital is composed solely of ordinary shares. Details are given on page 36 and in note 13 to the 
financial statements on page 74.

ISA Status

The Company’s shares are eligible for Stocks and Shares ISAs.

Retail Investors advised by IFAs

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

Menhaden

Menhaden are forage fish that occur in great abundance in the West Atlantic Ocean. The name, Menhaden, is derived 
from the Native American expression “he fertilises” referring to the widespread use of the fish as a fertiliser. Menhaden 
filter vast quantities of water and play a key role in the food chain. It has been argued that the environmental movement 
and fisheries ecology rose from the first collapse in the population of Menhaden in the 1860s as this was used as a 
prominent example of mankind’s impact on the oceans and the importance of using resources sustainably.

1

Strategic Report 
2
4
5
8
10
11
12
14
18
22

Company Performance 
Portfolio Profile 
Chairman’s Statement 
Investment Objective and Policy 
Investment Committee  
Investment Process 
Portfolio 
Portfolio Manager’s Review 
Environmental Impact Statement 
Business Review 

3

Financial Statements 
62
63
64
65
66

Income Statement 
Statement of Changes in Equity 
Statement of Financial Position 
Statement of Cash Flows 
Notes to the Financial Statements

2

Governance 
34
36
40

Board of Directors 
Directors’ Report 
Statement of Directors’ 
Responsibilities 
Corporate Governance Statement 
Audit Committee Report 
Directors’ Remuneration Report 
Directors’ Remuneration Policy 
Independent Auditor’s Report

41
47
51
53
54

4

Further Information 
81
82
84
86
91

Shareholder Information 
Glossary 
How to Invest 
Notice of Annual General Meeting 
Explanatory Notes to the 
Resolutions 
Company Information 

93

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

01

1

Strategic Report

Company Performance 

As at 
31 December 2021

For the year ended  
31 December 2021

155.7p 

17.3% 

NAV per share 

NAV per share 
(total return)* 

2020: 132.7p

2020: 13.2%

112.0p 

13.1% 

Share price 

Share price 
(total return)* 

2020: 99.0p

2020: 3.0%

28.1% 

1.8% 

Share price discount 
to NAV per share* 

Total ongoing charges* 

2020: 25.4%

2020: 2.0%

This report contains terminology that may be unfamiliar to some readers. The Glossary on pages 82 and 83 gives 
definitions for frequently used terms. 

*Alternative performance measures (“APMs”)

02 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Total Return Performance – One Year

%
130.0

120.0

110.0

100.0

90.0

80.0

Dec 20

Mar 21

June 21

Sep 21

Dec 21

RPI+3%

Company Share Price Total Return

Company NAV Total Return

Source: Frostrow Capital LLP, Office for National Statistics  
Rebased to 100 as at 31 December 2020 

Total Return Performance – Three Years

%

200.0

180.0

160.0

140.0

120.0

100.0

80.0

Dec 18

Jun 19

Dec 19

Jun 20

Dec 20

Jun 21

Dec 21

RPI+3%

Company Share Price Total Return

Company NAV Total Return

Source: Frostrow Capital LLP, Office for National Statistics  
Rebased to 100 as at 31 December 2018

Total Return Performance – Five Years

%

200.0

180.0

160.0

140.0

120.0

100.0

80.0

Dec 16

Jun 17

Dec 17

Jun 18

Dec 18

Jun 19

Dec 19

Jun 20

Dec 20

Jun 21

Dec 21

RPI+3%

Company Share Price Total Return

Company NAV Total Return

Source: Frostrow Capital LLP, Office for National Statistics  
Rebased to 100 as at 31 December 2016

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

03

1

Strategic Report

Portfolio Profile

Portfolio Distribution

By Asset Allocation

0.7%

12.5%

By Geography

3.2%

2.9%

21.3%

86.8%

Public Equities 

Liquidity

Private Investments

72.6%

Europe

Asia & Emerging Markets

North America

UK

By Theme

6.5% 0.9%

8.1%

42.4%

42.1%

Sustainable Infrastructure
and Transportation
Digitisation

Clean Energy

Industrial Emissions Reduction

Water and Waste Management

Investment Themes 
Theme

Clean energy

Industrial emissions reduction

Sustainable infrastructure and 
transportation
Water and waste management

Digitisation
Reporting

Description 

Companies  involved  in  the  production  and  transmission  of  power  from  clean 
sources such as solar or wind. 
Companies  focused  on  improving  energy  efficiency  (e.g.  in  buildings  or 
manufacturing processes) or creating emissions reduction products or services. 
Companies  in  the  infrastructure  and  transport  sectors  helping  to  reduce 
harmful emissions. 
Companies with products or services that enable reductions in usage/volumes 
and/or smarter ways to manage water and waste. 
Companies that facilitate reduced resource consumption through digital technology. 
Companies providing the means for environmental reporting and evaluation. 

04 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Chairman’s Statement 
Sir Ian Cheshire

I am pleased to present our seventh annual report since the 
launch of the Company in July 2015. This report covers the 
year ended 31 December 2021. 

ownership levels in each company) almost double to over 
58,000 tonnes. The amount of clean electricity generated by 
the portfolio almost tripled to over 94,000 megawatt hours. 

Performance 
The  Company’s  net  asset  value  (“NAV”)  per  share  total 
return*  for  the  year  was  17.3%  (2020:  13.2%),  which 
compares favourably with the 10.5% (2020: 4.2%) increase 
of  our  RPI+3%  primary  performance  comparator  and 
reflects good portfolio performance over the period. Indeed, 
this brings the compound NAV performance over the last 
five years to approximately 13% per annum. 

However, it is disappointing that this did not translate into 
stronger market demand for the shares and, consequently, 
the price at which they trade. The price lagged the NAV, 
resulting in a less impressive, though still respectable, share 
price total return* of 13.1% (2020: 3.0%). 

Albeit with some bouts of volatility along the way, equity 
markets made positive progress through 2021 and this was 
reflected  in  the  Company’s  performance.  The  leading 
contributors to performance in the year were the holdings in 
the  digitisation  space,  notably  Alphabet  and  Microsoft 
because of the holding sizes, but all of the holdings within 
that 
the  accelerated  digital 
from 
transformation  being  driven  along  by  the  evolution  of 
working  practices  and  consumer  behaviour  during 
the pandemic.  

theme  benefited 

The Board is reassured by the positive performance of the 
portfolio  and  the  disciplined  approach  of  our  Portfolio 
Manager in pursuit of their investment strategy: selecting 
competitively advantaged businesses that are demonstrably 
delivering or benefiting significantly from the efficient use 
of resources. 

Our Portfolio Manager has provided a full description of the 
development and performance of the portfolio over the year 
in the Portfolio Manager’s Review on pages 14 to 17.  

Environmental Impact 
As  in  past  years,  we  have  integrated  the  Company’s 
Environmental Impact Report within the annual report. It can 
be found on pages 18 to 21. This year saw the total tonnes 
of  greenhouse  gas  (“GHG”)  emissions  avoided  by  our 
investments  (as  a  proportion  based  on  the  portfolio’s 

*Alternative Performance Measure (see Glossary beginning on page 82)

During 2021 the commitments of the portfolio’s listed equity 
holdings were assessed against the Paris Agreement. While 
most are working towards the target 2°C limit by 2050, we 
have  reservations  about  two  investee  companies.  Our 
Portfolio Manager will increase engagement with them in 
2022 in pursuit of a lowering of their future climate impact. 

We are pleased that a third of the portfolio’s equity holdings 
have now set targets that have been independently validated 
by the Science Based Targets initiative. This means they 
have  a  clearly  defined  pathway  to  reduce  their  GHG 
emissions in line with the goals of the Paris Agreement.   

We are aware that the sectors represented in the portfolio, 
including transport, infrastructure and waste management, 
intersect closely with natural environments, so we are keen 
to see the companies we invest in actively reporting on the 
impacts of their activities upon local flora and fauna, soil 
quality and natural environments. Therefore, a focus for 2022 
is to encourage more investee companies to take action on 
protecting nature and biodiversity.  

The report is also made available as a separate document, 
which includes the methodological detail, on our website 
www.menhaden.com. 

Investment Policy 
When the Company was launched in 2015 the investment 
policy,  as  set  out  in  the  IPO  prospectus,  reflected  the 
intention that the portfolio would be comprised of three main 
allocations: listed equity; yield assets; and special situations 
(the last being private equity investments). Since then, the 
Company  has  consistently  disclosed 
the  portfolio 
composition according to those three categories. However, 
in the current economic environment it has proven to be very 
difficult  to  find  investments  suitable  for  the  portfolio  with 
attributes that would cause them to be identified as yield 
assets. Additionally, those that were identified have tended 
to also fall into the special situations (private equity) category. 
Accordingly,  we  have  concluded  that  the  yield  assets 
description is superfluous and, therefore, have made a minor 
change to the Company’s investment policy to remove the 
reference to a yield assets allocation. The investment policy, 
which  is  set  out  on  page  8,  now  says:  “The  Company 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

05

1

Strategic Report

Chairman’s Statement 
continued

invests, either directly or through external funds, in a portfolio 
that is comprised predominantly of a combination of listed 
equities and private equity investments”. There is no change 
to the way investments are selected for the portfolio.   

Investment Themes 
We  also  reviewed  the  investment  themes  by  which  the 
Company’s investments are categorised and concluded that 
it  would  be  helpful  to  redefine  these  in  order  to  provide 
investors with a more meaningful profile of the portfolio. In 
particular, we noted that most of the investments tended to 
fall  into  the  “resource  and  energy  efficiency”  theme  and 
considered  that  it  would  be  helpful  to  break  this  down 
further. The revised themes, together with their definitions, 
are set out on page 4.   

The Board 
The  Board  announced  in  January  the  appointment  of 
Barbara Donoghue as a non-executive Director, with effect 
from 1 February 2022. She has a wealth of entrepreneurial 
and corporate experience and I am confident she will be an 
asset to the Board. In making this appointment the Board 
took due consideration of its balance of skills, experience, 
knowledge  and  diversity  and  we  recommend  that 
shareholders support her election at the forthcoming Annual 
General Meeting (“AGM”). 

The Board also announced in January that Emma Howard 
Boyd  will  be  stepping  down  from  the  Board  at  the 
conclusion  of  this  year’s  AGM.  I  would  like  to  take  this 
opportunity to thank her for her contribution to the Board 
since the Company’s launch.  

We will continue to explore Board refreshment opportunities 
to ensure an orderly Board succession in line with corporate 
governance  guidelines  and  the  Company’s  policy  on 
Directors’ tenure, and also with an eye on diversity.   

Share Price Discount 
The  Company’s  share  price  discount  continues  to  be  a 
matter that the Board monitors closely. At the year-end, the 
discount* to the NAV per share at which the Company’s 
shares trade had widened to 28.1% (2020: 25.4%) and the 
discount currently remains around this level. 

asking shareholders to renew the Directors’ share issuance 
authorities at this year’s AGM. Enlarging the capital base will 
reduce  the  annual  ongoing  charges  and  enhance  the 
secondary market liquidity of the Company’s shares, which 
the Board believes is in the interests of all shareholders. 
However, the Company can only issue new shares at a price 
representing a premium to the NAV per share and therefore 
the Board remains focused on improving the Company’s 
share  rating  through  investment  performance  and  an 
effective marketing strategy. 

Reiterating  previous  statements  on  share  buybacks,  the 
Board continues to be of the opinion that buybacks are not 
always  in  the  interests  of  shareholders,  since  this  would 
reduce the size of the Company and increase the ongoing 
charges ratio. Instead, as mentioned above, in addition to 
monitoring the Portfolio Manager’s performance, the Board 
and the AIFM have focused on the Company’s marketing 
and  distribution  strategy.  However,  the  Board  keeps  the 
possibility  of  share  buybacks  under  continuous  review. 
Accordingly, the Board is asking shareholders to renew the 
authority to repurchase existing shares in the market at the 
forthcoming AGM. 

Annual General Meeting 
The Company’s seventh AGM will be held at the offices of 
Frostrow Capital LLP, 25 Southampton Buildings, London 
WC2A 1AL on Wednesday, 22 June 2022 at 12 noon. The 
Notice convening the AGM together with explanations of the 
proposed resolutions can be found on pages 86 to 92. 

It is hoped that this year it will be possible to hold the AGM 
in its normal format at the venue set out above. However, in 
case Government guidance once again restricts attendance 
the Board strongly encourages shareholders to register their 
votes online in advance by visiting www.signalshares.com 
and following the instructions on the site. Appointing a proxy 
online  will  not  restrict  shareholders  from  attending  the 
meeting in person should they wish to do so, subject to any 
Government guidance to the contrary. The Board will keep 
the situation under review and should it be necessary to 
restrict  attendance  this  will  be  communicated  via  the 
Company’s  website.  Shareholders  are  encouraged  to 
consult the Company’s website at www.menhaden.com for 
any late changes to the arrangements. 

As  was  expressed  last  year,  the  Board’s  aim  is  for  the 
Company to eventually be in a position to grow through the 
issuance  of  new  shares  and  the  Board  is,  accordingly, 

Should it not be possible to hold the AGM in the normal 
format,  the  Board  currently  expects  to  adopt  the  same 
approach  as  last  year,  combining  a  closed  AGM  with  a 

06 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

webinar  to  enable  the  Portfolio  Manager  to  give  a 
presentation  online.  Shareholders  should  send  any 
questions  they  may  have  to  the  Company  Secretary  by 
email to info@frostrow.com ahead of the meeting. Details on 
registering for the webinar will be made available nearer the 
time if this alternative becomes necessary. 

Dividend 
The Company’s dividend policy is that the Company will only 
pay dividends sufficient for it to maintain investment trust 
status.  The  revenue  return  for  the  year  to  31  December 
2021  means  that  a  dividend  must  be  paid  to  meet  this 
requirement. Consequently, the Board is recommending to 
shareholders  that  a  final  dividend  of  0.2p  (amounting  to 
£160,000 in total) be declared in respect of the year ended 
31  December  2021  and  a  corresponding  resolution  has 
been included in the Notice of Meeting for the AGM. If this 
resolution is passed the dividend will be payable on 29 June 
2022 to shareholders on the register on 6 June 2022. The 
shares will be marked ex-dividend on 1 June 2022. 

Outlook 
It is apparent from our primary performance comparator that 
inflation  increased  significantly  in  the  year  to  December 
2021. This is principally a consequence of the increased 
money supply from Government and central bank policy 
responses  to  Covid-19.  It  has  manifested  particularly  in 
energy  prices  and  where  supply  chain  shortages  have 
arisen, but it can be expected to continue more broadly. It is 
unlikely that this is a short-term transitory effect. On the plus 
side,  equities  kept  ahead  of  inflation  in  the  year  and 
historically  have  been  proven  to  be  a  good  place  to  be 
invested during inflationary times.  

Our portfolio is well placed, with pricing power being a key 
attribute that our Portfolio Manager looks for in investment 
propositions. 

Following  COP26  in  November  2021  progress  on  the 
transition to net zero appears to be an increasing investor 
priority as well as being a political focus, which corresponds 
well  with  the  Company’s  resource  efficiency  investment 
thesis.  

Whilst the Board shares global concern about the Russian 
aggression in Ukraine, to the best of our current knowledge 
the situation should have no direct impact on the Company 
and while one portfolio company is affected by the Russian 
sanctions,  Safran,  its  share  price  has  recovered  to 
December levels after initial volatility. As far as we are aware 
there are no Russian shareholders and services provided to 
the Company are not affected by any sanctions.  

The  Board  remains  confident  about  the  resilience  and 
long-term prospects of the portfolio as well as the prospects 
of the environmental and resource-efficiency sectors. 

Sir Ian Cheshire 
Chairman 
20 April 2022 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

07

 
1

Strategic Report

Investment Objective and Policy

Investment Objective 
The Company’s investment objective is to generate long-
term  shareholder  returns,  predominantly  in  the  form  of 
capital  growth,  by 
in  businesses  and 
investing 
opportunities 
that  are  demonstrably  delivering  or 
benefitting significantly from the efficient use of energy and 
resources  irrespective  of  their  size,  location  or  stage  of 
development. 

To  reflect  its  non-benchmarked  total  return  investment 
strategy,  the  Company  uses  RPI+3%  as  its  primary 
long-term financial performance comparator. In addition to 
this absolute return performance measure, the Company 
also uses a range of specialist, sectoral and peer group 
benchmarks to assess its relative performance. 

Investment Policy 
The Company’s investment objective is pursued through 
constructing  a  conviction-driven  portfolio  consisting 
primarily of direct listed and unlisted holdings across asset 
classes and geographies. 

Asset Allocation 
The Company invests, either directly or through external 
funds, in a portfolio that is comprised predominantly of a 
combination  of 
listed  equities  and  private  equity 
investments. 

The  flexibility  to  invest  across  asset  classes  affords  the 
Company two main benefits: 

• it  enables  construction  of  a  portfolio  based  on  an 

assessment of market cycles; and 

• it enables investment in all opportunities which benefit 

from the investment theme. 

It is expected that the portfolio will comprise approximately 
15 to 30 positions. 

Geographic Focus 
Although  the  portfolio  is  predominantly  focused  on 
investments  in  developed  markets,  if  opportunities  that 
present an attractive risk and reward profile are available in 
emerging markets then these may also be pursued. 

While  many  of  the  companies  forming  the  portfolio  are 
headquartered  in  the  UK,  USA  or  Europe,  it  should  be 
noted that many of those companies are global in nature, 
so  their  reporting  currency  may  not  reflect  their  actual 
geographic or currency exposures. 

Investment Restrictions 
Subject to any applicable investment restrictions contained 
in the Listing Rules from time to time, the Portfolio Manager 
will not make an investment if it would cause the Company 
to  breach  any  of  the  following  limits  at  the  point  of 
investment: 

• no more than 20% of the Company’s gross assets may 
be invested, directly or indirectly through external funds, 
in the securities of any single entity; and 

• no more than 20% of the Company’s gross assets may 

be invested in a single external fund. 

Hedging 
The  Company  may  enter  into  any  hedging  or  other 
derivative  arrangements  which  the  Portfolio  Manager 
(within such parameters as are approved by the Board and 
the  AIFM  and  in  accordance  with  the  Company’s 
investment  policy)  may  from  time  to  time  consider 
the  purpose  of  efficient  portfolio 
appropriate 
management,  and  the  Company  may  for  this  purpose 
leverage through the use of options, futures, options on 
futures, swaps and other synthetic or derivative financial 
instruments. 

for 

Cash Management 
There  is  no  restriction  on  the  amount  of  cash  or  cash 
equivalent instruments that the Company may hold and 
there may be times when it is appropriate for the Company 
to have a significant cash position instead of being fully or 
near fully invested. 

08 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

The Listing Rules restrict the Company from investing more 
than 10% of its total assets in other listed closed-ended 
investment funds, save that this restriction does not apply 
to investments in closed-ended investment funds which 
themselves have published investment policies to invest no 
more than 15% of their total assets in other listed closed-
ended investment funds. The Company will comply with 
this investment restriction (or any variant thereof) for so long 
as such restriction remains applicable. 

At the date of this report, the Company was not invested 
in any listed closed-ended investment funds. 

In  the  event  of  any  material  breach  of  the  investment 
restrictions applicable to the Company, shareholders will 
be informed of the actions to be taken by the Alternative 
Investment Fund Manager (“AIFM”) through a Regulatory 
Information Service announcement. 

Borrowing and Leverage Limits 
The Company may incur indebtedness for working capital 
and investment purposes, up to a maximum of 20% of the 
net asset value at the time of incurrence. The decision on 
whether  to  incur  indebtedness  may  be  taken  by  the 
Portfolio Manager within such parameters as are approved 
by the AIFM and the Board from time to time. There will be 
no limitations on indebtedness being incurred at the level 
of the Company’s underlying investments (and measures of 
indebtedness for these purposes accordingly exclude debt 
in place at the underlying investment level). 

At the date of this report, the Company had no borrowings. 

In  addition,  the  Alternative  Investment  Fund  Managers 
Regulations (“UK AIFMD”) require the Company, which is 
an Alternative Investment Fund (“AIF”) under the regulations, 
to  set  maximum  leverage  limits  corresponding  to  the 
UK  AIFMD  leverage  definition.  The  UK  AIFMD  defines 
leverage as any method by which the total exposure of an 
AIF  is  increased  and  provides  two  calculation  methods 
(gross  and  commitment),  as  further  explained  in  the 
Glossary  on  page  82  and  in  the  separate  UK  AIFMD 
periodic disclosures document on the Company’s website. 

Other Investment Restrictions 
The Company will at all times invest and manage its assets 
with the objective of spreading risk and in accordance with 
its published investment policy. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

09

1

Strategic Report

Investment Committee

Menhaden Capital Management LLP has been appointed as the Company’s Portfolio Manager. The Portfolio Manager’s 
Investment Committee, acting under delegated authority, makes all investment and disinvestment decisions in respect 
of the Company. 

Graham Thomas 
Graham is the non-executive chairman of the Investment Committee. Before founding Menhaden 
Capital Management LLP with Ben Goldsmith, Graham chaired the Executive Committee of RIT 
Capital Partners plc. Prior to this, Graham was the head of the Standard Bank Group’s US$3 billion 
Principal Investment Management division, which was established in 2008 under his leadership. He 
joined Standard Bank from MidOcean Partners in London, where he was a founding partner. Before 
MidOcean Partners, he was an Executive Director in the Investment Banking division of Goldman 
Sachs & Co. 

Graham is currently chief executive officer of private equity firm, Stage Capital, and on the investment 
committee of Apis Partners. He is a Rhodes Scholar with degrees from Oxford and the University of 
Cape Town. 

Ben Goldsmith 
Ben  is  the  chief  executive  officer  of  Menhaden  Capital  Management  LLP.  Before  co-founding 
Menhaden, Ben co-founded WHEB Asset Management, one of Europe’s leading sustainability-
focused investment management firms. Ben is a director of Cavamont Holdings, the Goldsmith family 
investment vehicle.  

Ben chairs the UK Conservative Environment Network, and is a Trustee of The Children’s Investment 
Fund Foundation, a globally leading climate and health focused philanthropic foundation. Ben is a 
non-executive director of the UK Government’s Department for Environment, Food and Rural Affairs. 

Luciano Suana 
Luciano  is  the  chief  investment  officer  at  Menhaden  Capital  Management  LLP.  Before  joining 
Menhaden  Capital  Management  LLP,  Luciano  was  a  Director  of  Barclays  Capital  in  the  Capital 
Markets  division  where  he  ran  the  credit  trading  operations  for  Brazil  out  of  São  Paulo.  Before 
Barclays, Luciano was a Director of Dresdner Kleinwort in London. There he focused mainly on 
Infrastructure, Utilities and Real Estate assets as head of the illiquids credit group. 

Luciano holds a Licenciatura in business administration from Universitat Autònoma de Barcelona and 
was granted the Premio Extraordinario de Fin de Carrera for outstanding academic performance. 

10 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
Investment Process 

Investment Process 
The portfolio management team, which has day to day 
responsibility for managing the portfolio, is led by Luciano 
Suana, and comprises himself, Ben Goldsmith and Edward 
Pybus.  

The  portfolio  management  team  presents  investment 
opportunities  to  the  Investment  Committee,  which  is 
chaired by Graham Thomas.  

Thematically, the team seeks to invest in opportunities, 
publicly  traded  or  private,  which  either  demonstrably 
deliver or benefit significantly from the more efficient use 
of energy and resources. All investment opportunities are 
assessed through a value lens, with the aim of acquiring 
investments with low downside risk, backed by identifiable 
assets and cash flows, at attractive valuations. The team 
seeks to invest with a long-term perspective, and with high 
conviction. Consequently, the portfolio comprises around 
20 positions and the team aims for portfolio turnover to 
be low.  

When  identifying  suitable  investment  opportunities,  the 
portfolio  management  team  is  cognisant  of  the  UK 
Stewardship Code and the UN Principles of Responsible 
Investment. 

Investment Committee 
The  Investment  Committee  meets  weekly  in  order  to 
consider the investment opportunities presented by the 
portfolio management team. All investment decisions must 
be made with the unanimous consent of all members of 
the Investment Committee unless one of the members has 
a potential conflict of interest, in which case that member 
will excuse himself from that particular decision. 

Investment Network 
The  portfolio  management  team  has  access  to  a 
proprietary investment network, which includes a group of 
investment managers of external funds and, from time to 
time,  external  experts  and  advisers.  The  portfolio 
management  team  believe  that  this  is  of  benefit  to  the 
investment process and helps to source opportunities that 
they  believe  would  not  otherwise  be  available  to  the 
Company. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

11

  
1

Strategic Report

Portfolio

Investments held as at 31 December 2021 

Investment

Alphabet

Country/region

United States

Fair
Value
£’000

34,757

% of  

Total Net                                    

Assets 

27.9                                   

Charter Communications

United States

21,974

17.6                                   

United States 

15,390

12.4                                   

Spain

10,174

8.2                                   

Microsoft

X-ELIO*1

Canadian Pacific Railway

Safran

VINCI

Canadian National Railway

John Laing*2

Ocean Wilsons

Top Ten Investments

TCI Real Estate*

ASML

Canada

France

France

Canada 

UK

Bermuda

United States

Netherlands 

9,273

8,117

6,502

6,258

4,000

3,650

7.5                                   

6.5                                   

5.2                                   

5.0                                   

3.2                                   

2.9                                   

120,095

1,602

96.4 

1.3                                   

1,187

1,109

826

796

125,615

(1,084)

124,531

1.0                                   

0.9                                   

0.7                                   

0.6                                   

100.9 

(0.9) 

100.0 

Waste Management

United States

KLA

LAM Research

Total Investments

Other Liabilities

Total Net Assets

United States 

United States

1 Investment made through Helios Co-Invest L.P.      2  Investment made through KKR Aqueduct Co-Invest L.P.     *  Unquoted

12 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
 
      Business Description                                                                                                             Theme 

Delivers a range of internet based products and services for users and advertisers, 
which are powered by renewable energy with the group being the largest corporate 
buyer of renewable power worldwide

  Digitisation 

Owns and operates telecommunications infrastructure across the USA, which will 
underpin the Internet of Things

Sustainable infrastructure and 
transportation

Provides cloud infrastructure and software services which deliver energy efficiency 
savings for customers versus legacy solutions 

Digitisation

      Develops and operates solar energy assets                                                                      Clean energy 

Owns and operates (fuel-efficient) freight railways in Canada and the USA

Designs, manufactures and services next generation aircraft engines which offer 
significant fuel efficiency savings 

Builds and operates energy efficient critical infrastructure assets

Sustainable infrastructure and 
transportation

Industrial emissions reduction

Sustainable infrastructure and 
transportation

Operates rail freight services across North America, which represent the most 
environmentally friendly way to transport freight over land

Sustainable infrastructure and 
transportation

Portfolio of mostly renewable, rail and social infrastructure assets

Operates ports and provides (lower climate impact) maritime services in Brazil 

Invests in energy-efficient real estate projects 

Sustainable infrastructure and 
transportation

Sustainable infrastructure and 
transportation

Sustainable infrastructure and 
transportation

Develops, manufactures & services advanced lithography systems used to produce 
more energy efficient semiconductor chips 

Digitisation

      Provides waste management and environmental services in North America                    Water & waste management  

Develops, manufactures & services inspection and metrology equipment used to 
increase the efficiency of semiconductor manufacturing 

Digitisation

Develops, manufactures & services etching & deposition equipment used to produce 
more energy efficient semiconductor chips

Digitisation

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

13

      
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
      
  
 
1

Strategic Report

Portfolio Manager’s Review 

Performance 
During  2021,  the  Company’s  NAV  per  share  increased 
from 132.7p to 155.7p. This represents a total return of 
17.3% and compares to the RPI+3% total return of 10.5%. 
The price at which the Company’s shares traded was at a 
28.1%  discount  to  NAV  at  31  December  2021,  having 
widened from 25.4% at the end of 2020. The contributions 
to the 17.3% NAV per share total return over the period 
are summarised below: 

However, we were pleased to announce the completion of 
a  new  private  investment  in  infrastructure  operator  and 
developer, John Laing, in December 2021. This is our third 
co-investment with KKR.  

Quoted Equities 
Our portfolio of quoted equities represented 88.2% of net 
assets at 31 December 2021, and delivered a total return of 
24.9% over the period, adding 20.6% to our NAV. 

31 December

2021 Contribution 
% 

NAV %

Asset Category

Public Equities

Private Investments

Cash

Foreign Exchange Forwards

Performance Fee & Other Accruals

Expenses

Net Assets

Net Return

88.2

12.7

0.7

(0.1)

(1.5)

100.0

Financial  conditions  remained  benign  during  2021  but 
central  banks,  led  by  the  US  Federal  Reserve,  latterly 
signalled their intention to gradually tighten monetary policy, 
given inflation concerns. Equity markets stayed buoyant, 
albeit  with  significant  dispersion  between  sectors  and 
individual companies.  

Given the successful exits of private investments over the 
last few years, our portfolio is overweight public equities. 
Alphabet  and  Microsoft  both  performed  exceptionally 
well,  accounting  for  the  majority  of  our  investment 
performance.  Waste  Management 
our 
semiconductor  capital  equipment  companies  were  also 
notable contributors. Charter Communications ended 
the year approximately flat, whilst Safran was the single 
largest detractor. Key investment decisions included exits 
from both Airbus and Union Pacific, the material increase 
of  our  position  in  Microsoft  and  the  initiation  of  a  new 
position in French infrastructure group, VINCI.  

and 

Our private investment activity was limited, with X-ELIO and 
TCI  Real  Estate  Partners  III each making a return of 
capital payment and the completion of the sale of Calisen. 

14 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Investment

Alphabet

Microsoft

Waste Management

Canadian National

Ocean Wilsons

ASML

Canadian Pacific

KLA

20.6 

1.3 

– 

(1.1) 

(1.7) 

(1.8) 

17.3 

LAM Research

Airbus

Charter Communications

Union Pacific

VINCI

Safran

Increase/ Contribution  
to NAV % 

(Decrease) %

65.3

51.2

41.5

11.8

10.4

77.8

3.8

66.1

52.3

11.4

(1.4)

1.7

3.1

(7.1)

13.1 

4.4 

0.8 

0.7 

0.6 

0.6 

0.4 

0.4 

0.4 

0.3 

– 

– 

(0.1) 

(1.0) 

Note: Percentage increase/decrease for individual holdings is calculated 
on their local currency and based over the holding period if bought or 
sold during the year. 

Alphabet was the standout contributor to our performance 
and  was  our  largest  holding  at  31  December  2021, 
representing 27.9% of NAV. In our view the shares continue 
to offer one of the most attractive risk-rewards in the market. 
We believe Alphabet has a formidable business model and 
market position and yet it traded on a similar multiple to the 
S&P 500 market at 31 December 2021. Whilst we continue 
to carefully monitor the various antitrust cases against the 
company, we remain confident about Alphabet’s prospects 
and believe that the secular growth of digital advertising, 
successful  scaling  of  the  Google  Cloud  business  and 
improving capital allocation will continue to drive significant 
earnings growth in the years ahead. Importantly, Alphabet 

 
 
 
continues to set new sustainability targets. Building on its 
pledge to operate on carbon-free energy everywhere, at all 
times, by 2030, we were also pleased to see, in September 
2021, that the company aims to replenish 120% of the water 
it consumes across its datacentres and offices.  

Microsoft was also a very strong contributor, validating our 
decision to materially increase our position in late April and 
early May. Following these additional purchases, the shares 
rose more than 30% over the remainder of the calendar year. 
The holding represented 12.4% of NAV at 31 December 
2021. We expect the group to continue benefiting from the 
secular digitisation theme for many years. CEO Satya Nadella 
expects IT spending to increase from 5% to 10% of GDP by 
the end of the decade. The company is the key technology 
partner  for  all  enterprises  and  its  software  products  are 
ubiquitous. Following Alphabet’s lead, Microsoft now also 
aims to operate on carbon-free energy everywhere, at all 
times,  by  2030.  Furthermore,  the  company  wants  to  be 
carbon negative in the same timeframe and to have removed 
all carbon it has emitted since its founding by 2050. During 
the calendar year, Microsoft announced a 15% blended 
average price increase for Office 365, the largest since its 
launch a decade ago. We do not expect the move to have 
any  material  impact  on  customer  retention  and  believe  it 
clearly demonstrates the group’s pricing power. In our mind 
this is emblematic of the type of company we want to hold 
in the portfolio.  

Following a period of moving sideways in the prior year, 
Waste Management shares delivered robust performance 
in 2021. The company benefited from both the recovery in 
economic activity and its successful integration of Advanced 
Disposal  Services,  which  included  upgraded  synergy 
targets. With the share price multiple at an all-time high, we 
opted to realise some profits in December and sold a portion 
of our holding. We continue to expect the shares to deliver 
steady performance over time, with the company offering 
an  appealing  combination  of  predictable  free  cash  flow 
generation,  solid  competitive  position  and  a  shareholder 
friendly management team. We are also pleased with the 
company’s  progress  on  its  environmental  goals.  Whilst 
Waste Management’s services currently avoid three times 
more  emissions  than  are  generated  by  its  operations, 
management is aiming to increase this figure to four times 
by  2038.  The  company  is  increasingly  harnessing  the 
methane gas emitted from its landfill facilities by transforming 
it into renewable natural gas and is currently using it to power 
approximately one quarter of its vehicle fleet.  

Consolidation  surged  back  onto  the  North  American 
railroad industry agenda, with both Canadian National 
and Canadian Pacific making bids to buy Kansas City 
Southern.  The  well  reported  tussle  between  the  two 
companies  ended  with  Canadian  Pacific  as  the  only 
viable  acquirer,  after  regulatory  uncertainty  effectively 
stymied  Canadian  National’s  bid.  Canadian  Pacific 
announced the completion of its acquisition in December 
2021, but it remains subject to the merger being approved 
by  the  United  States  Surface  Transportation  Board. 
Canadian Pacific expects to be able to start integrating 
Kansas City Southern in late 2022. However, if the Surface 
Transportation Board does not approve the transaction, 
Canadian Pacific will have to sell the business, possibly 
at a loss. We think this is unlikely due to the transaction’s 
procompetitive characteristics and the regulator’s positive 
reception so far, in contrast to its opposition to Canadian 
National’s bid. 

Our thesis for both companies is unchanged, with rail as the 
most environmentally friendly way of transporting freight over 
land. Current locomotives are four times more fuel efficient 
than trucking on a per unit basis. Both businesses possess 
very strong competitive positions, which we believe provides 
them with real pricing power. We are also optimistic on the 
Canadian  Pacific-Kansas  City  Southern  combination, 
which will create a unique network spanning three North 
American countries. There will be a significant opportunity 
to  grow  volumes  by  converting  road  freight  to  new  rail 
services between Mexico, Texas and the Upper Midwest.  

Separately, we opted to exit our position in the Canadian 
railroads’ peer, Union Pacific, in March and reallocate the 
proceeds  within  the  portfolio  to  opportunities  offering  a 
better balance between risk and reward. 

The global semiconductor shortage seems to be persisting 
due to rapid demand growth driven by cloud computing, 
artificial  intelligence,  5G,  the  Internet  of  Things  and  the 
digitisation  of  the  automotive  industry.  Significant  capital 
investments by the industry to expand capacity have proven 
a  boon 
for  our  semiconductor  capital  equipment 
companies, ASML, Lam Research and KLA. Since our 
initial purchases in October 2020, each company’s share 
price had more than doubled at the year end. They each 
dominate their respective niche and play a critical role in 
helping the wider industry both maximise semiconductor 
production from finite resources and develop and produce 
more  advanced  and  energy  efficient  chips.  Whilst 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

15

1

Strategic Report

Portfolio Manager’s Review 
continued

semiconductors  remain  a  secular  growth  story,  we  are 
aware  that  the  path  forward  is  likely  to  include  ups  and 
downs. We opted to trim each position towards the end of 
the year.  

During the year Ocean Wilsons subsidiary, Wilson Sons, 
announced a corporate restructuring which transferred its 
listing to the Brazilian market. This process was completed 
in October and should enable Wilson Sons' shares to be 
included  in  Brazilian  and  Latin  American  stock  market 
indices. Whilst investors initially reacted favourably to the 
news, the shares gave up some of the gains towards the 
year end. Operationally, container and towage volumes are 
recovering at the ports in Brazil and longer term we believe 
a  growing  Brazilian  market  will  drive  a  significant 
improvement 
financial  performance. 
Furthermore, we believe that there is significant value in the 
shares, with the current price implying a value for the ports 
business of only 3.5 times normalised EBITDA. 

the  group’s 

in 

Charter Communications remains our second largest 
holding, representing 17.6% of NAV. The shares reversed 
their strong performance in the first eight months of the year 
to end it approximately flat. This was driven by investors' 
concerns around future broadband subscriber growth, with 
the rate of quarterly net additions slowing. We believe this 
only natural following a Covid-19 induced pull forward of 
demand. Charter Communications offers consumers an 
attractive  value  proposition  through  the  bundling  of 
broadband  and  mobile  services,  which  we  believe  other 
providers will struggle to match. Our thesis remains that 
Charter Communications’ hybrid fibre coax network will 
serve as a key piece of infrastructure in the ongoing digital 
transformation,  with  the  company’s  moves  to  secure 
valuable wireless spectrum in recent auctions set to further 
increase its importance. Whilst we are aware of growing 
competition from new fibre buildouts and fixed wireless, we 
currently  believe  the  company  can  continue  to  raise 
penetration  across  its  footprint  in  both  broadband  and 
mobile, supporting growing free cash flow and higher capital 
returns.  

We initiated a new position in French infrastructure group 
VINCI in April 2021. The company has a strong track record 
of building and operating critical infrastructure assets around 
the world and is currently transforming its business, with the 
aim of achieving a 40% reduction in carbon emissions by 
2030. Last year the group successfully raised its inaugural 
green bond of €500 million, and the recently announced deal 

16 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

to acquire the ACS Energy business provides it with a best 
in class renewable energy development platform. We believe 
the  company  is  extremely  well  placed  for  an  inflationary 
environment,  with  its  infrastructure  concessions  being 
government  authorised  monopolies  that  benefit  from 
inflation-linked pricing power. The position represented 5.2% 
of NAV at 31 December 2021.  

Airbus  and  Safran  continue  to  work  diligently  to  help 
aviation transition to a more sustainable footing, with the 
industry targeting a 50% reduction in carbon emissions by 
2050 under the Carbon Offsetting and Reduction Scheme 
for  International  Aviation.  Both  Airbus  and  Safran  are 
working  to  realise  the  goal  of  presenting  the  first  zero-
emission commercial aircraft by 2035 as part of the French 
government’s  plan.  Commercial  air  travel  continued  to 
rebound  over  the  year.  There  are  significant  disparities 
between different regions and countries but people are flying 
again when and where permitted. There is still uncertainty 
as to when international travel will fully recover, especially 
with China’s borders remaining effectively closed. With both 
companies’ share prices having recovered significantly from 
their lows, we opted to take some profits in April 2021. We 
chose  to  fully  exit  our  position  in  Airbus  and  to  trim  our 
position  in  Safran,  which  represented  6.5%  of  NAV  at 
31 December 2021. Since our original investment in Airbus 
in May 2016, we have generated an IRR of 28%. 

Private Investments 
Our portfolio of private investments represented 12.7% of 
our total NAV at 31 December 2021, and delivered total 
returns of 8.9% during the period, adding 1.3% to our NAV. 

Investment

X-ELIO

TCI Real Estate

Calvin Capital

John Laing

Increase/ Contribution 
to NAV % 

(Decrease) %

9.8

21.9

–

–

1.0 

0.2 

0.1 

– 

Note: Percentage increase/decrease for individual holdings is calculated 
on their local currency and based over the holding period if bought or 
sold during the year. 

X-ELIO,  the  Spanish  solar  operator  and  developer, 
continues  to  execute  well.  In  Spain,  the  company  was 
recently successful in bidding for 315 megawatts of new 
development and announced a partnership with integrated 

to 

jointly  develop  a 

energy  company  ENI 
further 
140 megawatts of capacity. The value of our holding was 
marked up according to the co-investment manager’s latest 
valuation in May and we subsequently received a £2 million 
cash distribution from the company, in relation to proceeds 
from the sale of assets. This reduced the value of our holding 
and  left  X-ELIO  representing  8.2%  of  our  NAV  at  the 
period end. 

Our  original  investment  in  TCI  Real  Estate  Partners 
Fund  III  in  2018  incorporated  a  commitment  to  invest 
additional  follow-on  amounts  to  support  further  fund 
investments. Whilst we had hoped they would draw down 
additional capital from our commitment over the year under 
review,  the  opposite  occurred  with  our  receipt  of  a 
US$2.2 million distribution in June. This reflected the return 
of capital and income proceeds realised after David Lloyd 
Leisure repaid the fund following a successful refinancing.  

Following the completion of the sale of Calisen we received 
cash proceeds of £6.1 million. We were pleased with this 
result,  with  the  transaction  representing  a  return  on 
investment  of  approximately  1.8  times  over  four  years, 
equivalent to a net IRR of approximately 15%. 

We were also pleased to complete a new co-investment 
with  KKR  in  John  Laing  in  December  2021.  Our  initial 
£4  million  investment  equated  to  3.2%  of  our  NAV  at 
31 December 2021 and was funded from cash on hand and 
partial  sales  of  existing  quoted  equity  positions.  The 
company  is  an  originator,  developer  and  owner  of  core 
mid-market infrastructure assets primarily across Europe, 
North  America  and  Australia.  The  company  works  to 
mitigate the environmental impact of its operations on an 
asset by asset basis and has committed itself to the net zero 
transition for its business, with an aim to complete this for 
direct operations ahead of the collective 2050 target. We 
expect the development pipeline of infrastructure assets to 
provide us with opportunities to commit additional capital 
over time. 

FX Hedges 
Our currency hedges are in place to lower the volatility of our 
sterling reporting currency returns by reducing non-sterling 
exposure related to investments that are denominated in 
other  currencies.  We  have  been  using  currency  forward 
contracts to hedge between half and two thirds of our EUR 
and  USD  denominated  exposures.  The  depreciation  of 
sterling during the period meant that we incurred a small loss 
on these currency forward contracts on a standalone basis, 
equivalent to 1.1% of the NAV. 

Outlook 
Forecasting the future is fraught with difficulty and so we 
focus  on  investments  which  require  us  to  make  as  few 
predictions as possible. We believe our criteria of resource 
efficiency, quality and value should leave our portfolio well 
placed to generate superior returns over time relative to the 
risk taken, in most market conditions. Whilst the prospect 
of tightening monetary policy has had a significant impact 
on valuations in certain pockets of the market, our quoted 
equities have been less affected. If current rates of inflation 
remain high, and real interest rates negative, we believe our 
focus on companies with pricing power will keep us in good 
stead. The presence of better opportunities within public 
markets has limited our private investment activity after a 
series  of  successful  realisations.  We  continue  to  search 
diligently  for  suitable  private  investments  that  offer  an 
attractive balance between risk and reward, but intend to 
make  sure  we  only  make  investments  that  improve  the 
quality of the portfolio. We are pleased to report that the 
Company’s  net  asset  value  has  now  successfully 
compounded at circa 13% annually, after fees, for over five 
years.  

31 December 2016

31 December 2021

Annualised Net Return

Net Asset
Value
£’000

68,283

124,531

NAV  
  per  share 
pence 

 85.4  

 155.7 

12.9% 

Menhaden Capital Management LLP 
Portfolio Manager 
20 April 2022

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

17

 
1

Strategic Report

Environmental Impact Statement

Foreword  
2021 was a landmark year for climate conscious investors. The latest IPCC assessment report demonstrated without a 
shadow of a doubt the connection between human activity and emerging climate chaos. At the COP26 climate conference 
world leaders made ambitious pledges to accelerate the transition to a net zero global economy by 2050. It is becoming 
increasingly  obvious  that  climate  and  other  environmental  risks  and  opportunities  are  having  a  material  effect  on 
investment returns. 

Menhaden Resource Efficiency PLC’s (the “Company’s”) objective is to generate long-term returns for shareholders by 
investing in businesses and opportunities that demonstrably deliver, or benefit significantly from, the efficient use of energy 
and other resources. 

The companies held in the portfolio are leading their respective fields in embedding resource efficiency into their operations, 
not least through the implementation of circular economy initiatives which emphasise reuse and recycling.  

In this Impact Statement we report how the Company’s holdings helped to reduce their environmental footprint, including 
their CO2e emissions, in 2021 through measures such as energy saving initiatives and use of resource efficient technologies. 
By way of illustration, renewable power giant X-ELIO delivered over 94,000 megawatt hours of clean electricity in 2021.   

In 2021 we also received positive responses to our direct engagements with portfolio companies on these matters, 
encouraging several to step up their environmental reporting and targets. Canadian Pacific and Safran both improved 
their climate reporting scores on the CDP global disclosure system during the period, while others committed to science-
based targets for emissions reductions.  

Our investment performance has been good during the year. The Company’s net asset value rose by 17.3% in 2021, 
signalling that there is financial opportunity in applying an environmental mindset to investment decision-making.  

Ben Goldsmith 
CEO, Menhaden Capital Management LLP 

Impact Data1 

1 All impact data in this report refers to the Company’s listed portfolio and the biggest private holding, X-ELIO, and is based on the proportion of each 
entity held at 31 December 2021. Analysis is calculated on best estimates using publicly disclosed data and full details of our methodology can be 
found in the Impact Report Appendix on our website.

18 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
Our approach and developments in 2021 
Menhaden Capital Management LLP (“MCM”) continued to 
apply 
research-oriented  approach 
throughout 2021 aiming to find the innovation, products and 
services that show corporate best practice when it comes 
to energy and resource efficiency.  

fundamental, 

its 

technology 

There was relatively little turnover in the portfolio during the 
year,  but  we  made  some  changes  to  our  investment 
themes,  which 
to 
included  broadening 
digitisation, opening up themes on ‘environmental reporting’ 
and  ‘industrial  emissions  reduction’  and  expanding  our 
transport theme to encompass sustainable transport and 
infrastructure. The latter saw the Company complete a new 
co-investment with KKR in John Laing Group. The group 
is  committed  to  responsible  investment  and  decreased 
direct emissions by 48% and Scope 3 emissions by 89% in 
their last year reported. We also invested in VINCI who are 
transforming  their  business  around  achieving  a  40% 
reduction in emissions by 2030 (compared to 2018).  

Total tonnes of greenhouse gas (“GHG”) emissions avoided 
by the Company’s investments (as a proportion based on 
the portfolio’s ownership levels in each company) almost 
doubled this year to over 58,000 tonnes. The amount of 
clean electricity generated by the portfolio almost tripled to 
over 94,000 MWh, with X-ELIO being the main generator. 

We  accept  that  high-emitting  sectors  like  aviation  and 
construction contribute greatly to climate change but rather 
than  avoid  the  sector  entirely  we  want  to  reward  those 
players  leading  the  way  in  efficient  and  environmentally-
friendly practices. For example, VINCI’s construction arm 
launched its Exegy low carbon concrete range in September 
2020,  which  reduces  C02  emissions  by  up  to  70% 
compared with traditional concretes.  

We take a similar future-focused approach to the transport 
sector,  which  is  responsible  for  24%  of  direct  CO2 
emissions.  The  transport  industry  has  been  slow  to 
decarbonise, so we look to support companies such as 
Safran which launched a new project in partnership with 
GE Aviation in June 2021 called the CFM Rise (Revolutionary 
Innovation for Sustainable Engines), a low-carbon aircraft 
technology that targets a 20% reduction in fuel consumption 
and CO2 emissions in comparison to current jet engines. In 
2021  we  divested  from  Airbus,  which  despite  offering  a 
more energy efficient option than peers, was one of the most 
carbon-intensive  stocks  in  the  portfolio.  We  took  an 
opportunity to sell following the significant recovery of its 
share price after the Covid-19 pandemic. 

Railways  represent  the  most  energy  efficient  method  of 
moving freight over land. Investee companies Canadian 
Pacific and Canadian National have both implemented 
robust climate actions plans to minimise emissions released 
from rail freight. Canadian Pacific has committed to reduce 
Scope 1, 2 and 3 GHG emissions intensity of its locomotives 
in excess of 38% by 2030. The company also installed solar 
capacity at its Calgary headquarters, and announced its 
Hydrogen Locomotive Programme to create north America’s 
first line-haul hydrogen locomotive prototype. 

Finally, perhaps one of our most impressive environmental 
performers in 2021 was Waste Management, a US waste 
and environmental services company. Services the company 
provides, such as turning gas from its landfills into energy, 
help it avoid three times the GHG emissions it generates 
from  its  operations,  and  it  is  aiming  to  increase  this  to 
four times by 2038. 

Active ownership: Leveraging our voice 
on climate 
As responsible stewards of shareholders’ capital, we are 
committed to using our voice to foster best practice, both 
by engaging directly with companies in the portfolio and 
working in collaboration with other investors and initiatives. 

In 2021 we began an organised programme of engagement 
to move the portfolio’s holdings forward on environmental 
reporting and target setting. We believe that the setting of 
emissions reduction plans in line with what climate science 
says  is  required  for  a  net  zero  economy  and  regular 
disclosure on performance against these targets is a vital 
first step to driving energy and resource efficiency. 

Thus, it was encouraging to see Safran improve their CDP 
environmental reporting platform score from a ‘C’ to a ‘B’ 
last year, and for Canadian Pacific to improve from a ‘B’ to 
an ‘A-‘ following our engagements on this issue. We are 
pleased to note that a third of the portfolio’s equity holdings 
have established clearly-defined pathways to reduce their 
GHG emissions in line with the goals of the Paris Agreement, 
with targets that have been independently validated by the 
Science Based Targets initiative. 

We will continue to engage with portfolio companies this 
year  in  our  quest  to  raise  standards  of  environmental 
disclosure and action.  

As  long-term  investors,  we  also  believe  that  mitigating 
environmental  risks  involves  an  active  approach  to  the 
preservation of biodiversity and are proud to be signatories 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

19

1

Strategic Report

Environmental Impact Statement 
continued   

of the Financial Sector Commitment Letter on Eliminating 
Commodity Driven Deforestation. We are cognisant that the 
sectors  represented  in  the  portfolio,  including  transport, 
infrastructure and waste management, intersect closely with 
natural  environments,  and  keenly  interested  to  see  the 

companies we invest in actively reporting on the impacts of 
their activities upon local flora and fauna, soil quality and 
natural  environments.  Therefore,  a  focus  for  2022  is  to 
encourage  more  investee  companies  to  take  action  on 
protecting nature and biodiversity.  

Portfolio Company Alignment with Paris Agreement Goals 
The figure below shows our assessment of the commitments of the portfolio’s listed equity holdings against the Paris 
Agreement. It indicates that most are working towards the target 2°C limit by 2050, but we have concerns about LAM 
Research and ASML. We will increase our engagement with these in 2022 with a view to encouraging improvements in 
their future climate impact. 

INVESTING IN BIG TECH SOLUTIONS FOR NATURE 
There is growing awareness about the interlinked crises of climate change and biodiversity and this is creating opportunity 
for several firms, including portfolio constituents Microsoft and Alphabet, to explore how they can help restore and 
preserve the natural environment.    

Microsoft recently committed to building a Planetary Computer to help protect the earth’s ecosystems. The platform 
will provide scientists, sustainability practitioners and conservation stakeholders with global environmental data to help 
them identify the impacts climate change is having on biodiversity, and enable them to work with the data to support 
environmental monitoring, forecasting, planning, and attribution.  

At Alphabet, a new initiative using Google Earth technology has been designed to promote ecosystem restoration 
across the world. Restor, a science-based open data platform developed by Google Creative Lab, launched in November 
2021 and shows data on local biodiversity, current and potential soil carbon and other variables like annual rainfall, soil 
PH and land cover.  

Last year, Google also announced it would make AI-powered improvements to its Maps application to direct drivers along 
more environmentally friendly routes, focusing on reducing emissions by avoiding traffic and limiting fuel consumption.  

20 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Alignment with SDGs 
MCM and the Company’s Board support the UN Sustainable Development Goals (“SDGs”) and many of the portfolio’s 
holdings contribute to the challenge of achieving them. We mapped our investment themes against the SDGs and 
concluded that our contributions focus on six of the goals:  

2021 saw record levels of extreme weather events and the IPCC warned temperature increases 
will likely impact the global water cycle. The state of California, home to Alphabet, headquarters, 
recorded a severe drought and the company has committed to replenish 20% more water than 
it uses by 2030 to help return regions with high or extremely high-water scarcity to a normal level. 

Our portfolio companies have a significant role to play in both supply and creating demand for 
renewable energy. X-ELIO is a global leader in the development of photovoltaics while Microsoft 
has set a goal to be carbon negative by 2030 and to remove from the environment all the carbon 
the company emitted since its founding by 2050. Encouragingly semi-conductor company ASML 
has already reached its goal to use 100% renewable electricity across all of its operations. 

We invest in companies helping build the infrastructure needed to transition to a low-carbon future. 
Electric Vehicles (EVs) will help reduce transport emissions by 31% compared to petrol cars and 
to support their roll out VINCI Autoroutes is aiming for all its service areas to have electric charging 
stations by 2023. Charter Communications is also investing in innovative technologies to 
support the transition, including 10G connectivity for the Internet of Things and smart cities. 

Building a more circular economy is an important opportunity for sustainable investors and in the 
US more than 75 billion pounds of food is wasted each year. Waste Management has invested 
in technology to recycle food waste from residential, commercial and industrial sources and turn 
it into energy or compost. Semiconductor supplier ASML also has a range of waste management 
initiatives such as the Return4Reuse programme. From 2019 to 2020, the company’s total waste 
generated per €1 million reduced from 417 kg to 360 kg. 

This is a key theme across our portfolio. In the transport sector, for example, Safran is focusing 
its research on breakthrough aircraft, to reach low carbon aviation by 2030-35 and move towards 
carbon neutrality around 2050. Canadian National has set a target in line with achieving net zero 
carbon emissions by 2050. By doing so, it is the first North American railroad to formally commit 
to join the Business Ambition for 1.5°C and the United Nations’ Race to Zero campaign. 

Since  2002,  Oceans  Wilson  maritime  services  company,  Wilson  Sons,  has  been  donating 
deactivated tugboats to the award-winning Pernambuco Artificial Reefs Project, which works to 
help the recovery of damaged marine ecosystems and serves as a living laboratory for studies on 
marine biology. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

21

 
1

Strategic Report

Business Review

The Strategic Report on pages 2 to 33 has been prepared 
to provide information to enable shareholders to assess 
how the Directors have performed their duty to promote 
the success of the Company. 

The  Strategic  Report  contains  certain  forward-looking 
statements. These statements are made by the Directors 
in good faith based on the information available to them up 
to the date of this report and such statements should be 
treated  with  caution  due  to  the  inherent  uncertainties, 
including  both  economic  and  business  risk  factors, 
underlying any such forward-looking information. 

Business Model 
The Company is an externally managed investment trust 
and its shares are listed on the premium segment of the 
Official List and traded on the main market of the London 
Stock Exchange. 

The purpose of the Company is to provide a vehicle for 
investors to gain exposure to a portfolio of companies that 
are demonstrably delivering or benefiting significantly from 
the efficient use of energy or resources irrespective of their 
size, location or stage of development, through a single 
investment. 

The  Company  is  an  Alternative  Investment  Fund  (“AIF”) 
under  the  UK’s  Alternative  Investment  Fund  Managers 
Regulations (“UK AIFMD”) and Frostrow Capital LLP is the 
appointed Alternative Investment Fund Manager. 

As  an  externally  managed  investment  trust,  all  of  the 
Company’s day-to-day management and administrative 
functions are outsourced to service providers. As a result, 
the Company has no executive directors, employees or 
internal operations. 

The Board is responsible for all aspects of the Company’s 
affairs, including setting the parameters for asset allocation, 
monitoring  the  investment  strategy  and  the  review  of 
investment  performance  and  policy. 
It  also  has 
responsibility for all strategic policy issues, including share 
and 
issuance 
discount/premium  monitoring,  corporate  governance 
matters, investor relations, dividends and gearing. 

and  buy  backs, 

share  price 

Further information on the Board’s role and the topics it 
discusses  with  the  AIFM  and  the  Portfolio  Manager  is 
provided 
in  the  Corporate  Governance  Statement 
beginning on page 41. 

22 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Investment Strategy 
The implementation of the Company’s investment objective 
has been delegated to Frostrow Capital LLP (“Frostrow” or 
the “AIFM”) by the Board. Frostrow has, in turn and jointly 
with 
the  Company,  appointed  Menhaden  Capital 
Management LLP as the Portfolio Manager. 

Details of the Portfolio Manager’s approach are set out in 
the Investment Process section on page 11 and in their 
review beginning on page 14. 

While the Board’s strategy is to allow flexibility in managing 
the investments, in order to manage investment risk it has 
imposed  various  investment,  gearing  and  derivative 
guidelines  and  limits,  within  which  Frostrow  and  the 
Portfolio Manager are required to manage the investments, 
as set out on pages 8 and 9. 

Any material changes to the investment objective or policy 
require approval from shareholders. 

Dividend Policy 
The  Company  complies  with  the  United  Kingdom’s 
investment trust rules regarding distributable income which 
require investment trusts to retain no more than 15% of 
their income from shares and securities each year. The 
Company’s dividend policy is that the Company will only 
pay dividends sufficient for it to maintain investment trust 
status.  

The Board 
The Board is currently constituted of three male Directors 
(60%) and two female Directors (40%). The Company has 
no employees. 

Biographical  details  of  the  Directors  are  set  out  on 
pages 34 and 35 and information on the workings of the 
Board  and  its  Committees  is  set  out  in  the  Corporate 
Governance Statement on pages 41 to 46. 

Emma Howard Boyd will step down from the Board and 
all other Directors will seek re-election by shareholders at 
the Annual General Meeting to be held on 22 June 2022. 

Principal Service Providers 
The  principal  service  providers  to  the  Company  are 
Frostrow  Capital  LLP 
the  “AIFM”), 
Menhaden  Capital  Management  LLP  (“MCM”  or  the 
“Portfolio Manager”) and J.P. Morgan Europe Limited (the 

(“Frostrow”  or 

 
“Depositary”). Details of their key responsibilities and their 
contractual arrangements with the Company follow. 

Management  Agreement,  MCM  provides, inter  alia,  the 
following services: 

the  Company  and  Frostrow 

AIFM 
The Board has appointed Frostrow as the designated AIFM 
of the Company on the terms and subject to the conditions 
of the alternative investment fund management agreement 
between 
(the  “AIFM 
Agreement”). The AIFM Agreement assigns to Frostrow 
overall responsibility to manage the Company, subject to 
the  supervision,  review  and  control  of  the  Board,  and 
ensures that the relationship between the Company and 
Frostrow is compliant with the requirements of UK AIFMD. 
Frostrow,  under  the  terms  of  the  AIFM  Agreement 
provides, inter alia, the following services: 

• risk management services; 

• marketing and shareholder services; 

• administrative and secretarial services; 

• advice  and  guidance 

in 

respect  of  corporate 

governance requirements; 

• maintenance of the Company’s accounting records; 

• preparation and dispatch of the annual and half yearly 

reports and monthly factsheets; and 

• ensuring  compliance  with  applicable  tax,  legal  and 

regulatory requirements. 

AIFM Fee 
Under the terms of the AIFM Agreement, Frostrow receives 
a  periodic  fee  equal  to  0.225%  per  annum  of  the 
Company’s  net  assets  up  to  £100  million,  0.20%  per 
annum of the net assets in excess of £100 million and up 
to £500 million, and 0.175% per annum of the net assets 
in excess of £500 million. 

The AIFM Agreement is terminable on six months’ notice 
given by either party. 

Portfolio Manager 
MCM is responsible for the management of the Company’s 
portfolio  of  investments  under  a  delegation  agreement 
between MCM, the Company and Frostrow (the “Portfolio 
Management Agreement”). Under the terms of the Portfolio 

• seeking out and evaluating investment opportunities; 

• recommending the manner by which cash should be 

invested, divested, retained or realised; 

• advising on how rights conferred by the investments 

should be exercised; 

• analysing the performance of investments made; and 

• advising  the  Company  in  relation  to  trends,  market 
movements  and  other  matters  which  may  affect  the 
investment objective and policy of the Company. 

Portfolio Management Fee 
MCM receives a periodic fee equal to 1.25% per annum 
of the Company’s net assets up to £100 million and 1.00% 
of the Company’s net assets in excess of £100 million. 

The  Portfolio  Management  Agreement  is  terminable  on 
six months’ notice given by any of the three parties. 

Performance Fee 
MCM  is  also  entitled  to  a  performance  fee  which  is 
dependent on the level of the long-term performance of 
the Company.  

The performance fee is calculated for discrete three year 
performance periods. In respect of a given performance 
period, a performance fee may be payable equal to 10% 
of the amount, if any, by which the Company’s adjusted 
NAV at the end of that performance period exceeds the 
higher  of  (a)  a  compounding  hurdle  (an  annualised 
compound  return)*  on  the  gross  proceeds  of  the  IPO 
issues  and 
(adjusted 
repurchases) of 5% per annum; and (b) a high watermark 
(the  highest  net  asset  value  that  the  Company  has 
reached on which a performance fee has been paid)*. The 
performance fee is subject to a cap in each performance 
period of an amount equal to the aggregate of 1.5% of the 
weighted  average  NAV  in  each  year  (or  part  year,  as 
applicable) of that performance period. 

for  any  subsequent  share 

*see Glossary for further details 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

23

1

Strategic Report

Business Review 
continued 

Portfolio Manager in November 2021, following which it 
made a recommendation to the Board. 
The  Board  believes  the  continuing  appointment  of  the 
AIFM  and  the  Portfolio  Manager,  under  the  terms 
described on page 23, is in the interests of shareholders 
as a whole. In coming to this decision, the MEC and the 
Board took into consideration, inter alia, the following: 
• the  terms  of  the  AIFM  Agreement  and  the  Portfolio 
Management Agreement, in particular the level and method 
of remuneration, the notice period and the comparable 
arrangements of a group of the Company’s peers; 

• the quality of the service provided and the quality and 
depth  of  experience  of  the  company  management, 
company secretarial, administrative and marketing teams 
that  the  AIFM  allocates  to  the  management  of  the 
Company; and 

• the quality of service provided by the Portfolio Manager 
in  the  management  of  the  portfolio;  and  the  level  of 
performance of the portfolio in absolute terms and by 
reference to RPI+3% and other relevant indices. 

Position, Performance and Future 
Developments 
The Statement of Financial Position on page 64 shows the 
Company’s financial position at the year end. Performance 
in  the  year  relative  to  the  Company’s  key  performance 
indicators is set out below and further outlined, together 
with investment activity and strategy, market background 
and  the  future  outlook,  in  the  Chairman’s  Statement 
beginning on page 5 and the Portfolio Manager’s Review 
on pages 14 to 17. 

The  Portfolio  Manager  believes  that  companies  which 
supply products and services that help to conserve scarce 
resources,  reduce  negative  environmental  impacts  and 
improve  resource  efficiency  are  likely  to  enjoy  faster 
growing end markets. The Directors continue to believe 
that  environmental  and  resource-efficiency  solutions, 
together with the Portfolio Manager’s investment strategy, 
should provide good returns for the long-term investor. 

It is expected that the Company’s investment strategy in 
the coming year will remain largely unchanged. 

Depositary 
The Company has appointed J.P. Morgan Europe Limited 
as its Depositary in accordance with UK AIFMD on the terms 
and subject to the conditions of an agreement between the 
Company,  Frostrow  and  the  Depositary  (the  “Depositary 
Agreement”). The Depositary provides the following services, 
inter alia, under its agreement with the Company: 

• safekeeping and custody of the Company’s custodial 

investments and cash; 

• processing of transactions; and 

• foreign exchange services. 

The Depositary must take reasonable care to ensure that 
the Company is managed in accordance with the Financial 
Conduct  Authority’s  Investment  Funds  Sourcebook, 
UK AIFMD and the Company’s Articles of Association. 

Under  the  terms  of  the  Depositary  Agreement,  the 
Depositary is entitled to receive an annual fee of the higher 
of £40,000 or 0.0175% of the net assets of the Company 
up to £150 million, 0.015% of the net assets in excess of 
£150  million  and  up  to  £300  million,  0.01%  of  the  net 
assets in excess of £300 million and up to £500 million and 
0.005%  of  the  net  assets  in  excess  of  £500  million.  In 
addition, the Depositary is entitled to a variable custody fee 
which depends on the type and location of the custodial 
assets of the Company. 

The  Depositary  has  delegated 
the  custody  and 
safekeeping of the Company’s assets to JPMorgan Chase 
Bank N.A., London branch (the “Custodian”). 

The notice period on the Depositary Agreement is 90 days 
if terminated by the Company and 120 days if terminated 
by the Depositary. 

Evaluation of the AIFM and the Portfolio 
Manager 
The performance of the AIFM and the Portfolio Manager is 
reviewed continuously by the Board and the Company’s 
Management Engagement Committee (the “MEC”), with a 
formal evaluation process being undertaken each year. As 
part  of  this  process,  the  Board  monitors  the  services 
provided  by  the  AIFM  and  the  Portfolio  Manager  and 
receives regular reports from them. The MEC reviewed the 
appropriateness of the appointment of the AIFM and the 

24 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Key Performance Indicators (“KPIs”) 
The Board of Directors reviews performance against the 
following KPIs. They comprise both specific financial and 
shareholder-related measures. The results for the year are 
summarised in the Chairman’s Statement on page 5.  

The KPIs for the Company are:  

• Net asset value (“NAV”) per share total return; 

• Share price total return; 

• Discount/premium  of 
NAV per share; and 

• Ongoing charges ratio. 

the  share  price 

to 

the 

Please  refer  to  the  Glossary  beginning  on  page  82  for 
definitions of these terms and an explanation of how they 
are calculated. 

NAV per share total return 
The Directors regard the Company’s NAV per share total 
return as being the overall measure of value delivered to 
shareholders over the long term. This reflects both the net 
asset value growth of the Company and any dividends paid 
to  shareholders.  The  Board  monitors  the  Company’s 
NAV total return against its benchmark and peers in the 
AIC Global Sector and the AIC Environmental Sector. The 
Company’s  NAV  per  share  total  return  over  the  year  to 
31 December 2021 was 17.3% (2020: 13.2%). To reflect 
the Company’s non-benchmarked total return investment 
strategy, the Board uses RPI+3% as its primary long-term 
financial performance comparator. RPI+3% over the year 
was 10.5% (2020: 4.2%). 

A full description of the portfolio and performance during 
the  year  under  review  is  contained  in  the  Portfolio 
Manager’s Review commencing on page 14 of this report. 

Share price total return 
The Directors regard the Company’s share price total return 
to  be  a  key  indicator  of  performance  and  monitor  this 
closely. This measure reflects the return to the investor on 
last traded market prices, assuming any dividends paid are 
reinvested. The Company’s share price total return over the 
year to 31 December 2021 was 13.1% (2020: 3.0%). 

Share price discount/premium to NAV per share 
The share price discount/premium to the NAV per share 
is considered a key indicator of performance as it impacts 
the share price total return and can provide an indication 
of how investors view the Company’s performance and its 
investment objective. At 31 December 2021 the discount 
(2020:  25.4%).  The  Chairman’s 
stood  at  28.1% 
Statement, on page 6, addresses the discount and the 
approach of the Board. The discount remained stubbornly 
wide throughout the year, notwithstanding the Company’s 
positive performance.  

Ongoing charges ratio 
Ongoing charges represent the costs that shareholders 
can reasonably expect to pay from one year to the next, 
under normal circumstances. The Board continues to be 
conscious  of  expenses  and  works  hard  to  maintain  a 
sensible balance between good quality service and costs. 
The Board therefore considers the ongoing charges ratio 
to be a KPI and reviews the figure both in absolute terms 
and in comparison to the Company’s peers. The ongoing 
charges ratio for the year to 31 December 2021 was 1.8% 
(2020: 2.0%).  

Risk Management 
In fulfilling its oversight and risk management responsibilities, 
the Board maintains a framework of key risks which affect 
the Company and the related internal controls designed to 
enable  the  Directors  to  manage/mitigate  these  risks  as 
appropriate.  The  Directors  have  carried  out  a  robust 
assessment of the emerging and principal risks facing the 
Company, including those that would threaten its business 
model, future performance, solvency or liquidity. 

The principal risks can be categorised under the following 
broad headings: 

• Corporate Risks 
• Investment Risks 
• Operational Risks 
• Financial Risks 
• Legal and Regulatory Risks

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

25

1

Strategic Report

Business Review 
continued  

The following sections detail the risks the Board considers to be the most significant to the Company under these headings. 
The risks are broadly unchanged from the prior year.

Principal Risks and Uncertainties

Management and Mitigation

Corporate Risks 
The share price return may differ materially from 
the NAV per share i.e. the shares may trade at a 
material  discount  to  the  NAV  per  share.  A 
widening discount affects shareholder returns 
and satisfaction and, as such, could influence 
the outcome of the next continuation vote or, in 
extremis,  precipitate  the  requisitioning  of  a 
general meeting to wind-up the Company. 

Investment Risks 
The implementation of the investment strategy 
adopted  by  the  Portfolio  Manager  may  be 
unsuccessful  and  result  in  underperformance 
against the Company’s principal performance 
comparators and peer companies. 

The portfolio may be affected by market risk, 
that is volatile market movements (in both equity 
and foreign exchange markets) in the sectors 
and regions in which it invests. The Company is 
also exposed to concentration risk, which is the 
potentially  higher  volatility  arising  from  its 
relatively  concentrated  portfolio,  and  sector-
specific  risks  such  as  global  energy  and 
commodity prices or withdrawal of government 
subsidies for renewable energy.  

At each meeting, the Board: 
• reviews  the  Company’s  investment  objective  in  relation  to  the 
market, economic conditions and the operation of the Company’s 
peers; 

• discusses the Company’s future development and strategy; 
• reviews an analysis of the shareholder register and reports on 
investor sentiment from the Company’s corporate stockbroker 
and AIFM;  

• reviews the level of the share price discount to the NAV per share 
and, in consultation with its advisers, considers ways in which 
share price performance may be enhanced; and 

• reviews  the  Company’s  promotional  activities  and  distribution 
strategy, which have been delegated to Frostrow, to ensure the 
Company is promoted to current and potential investors.  

The Board regularly reviews the Company’s investment mandate 
and MCM’s long-term investment strategy in relation to market and 
economic conditions, and the performance of the Company’s peers. 
The Portfolio Manager provides an explanation of stock selection 
decisions and an overall rationale for the make-up of the portfolio, 
including the resource-efficiency credentials of the portfolio holdings. 
MCM discuss current and potential investment holdings with the 
Board on a regular basis.  
While market risk cannot be eliminated through diversification, it can 
be  potentially  reduced  through  hedging.  The  Board  sets  the 
Company’s policy on hedging, which is detailed on page 8 and 
details of the foreign exchange forwards in place are set out in the 
Portfolio Manager’s Review beginning on page 14. 
To manage concentration risk, the Board has appointed the AIFM 
and the Portfolio Manager to manage the portfolio within the remit 
of the investment objective and policy set out on pages 8 and 9. 
The investment policy limits ensure that the portfolio is diversified, 
reducing the risks associated with individual stocks and markets. 
Compliance with the investment restrictions is monitored daily by 
the AIFM and reported to the Board on a monthly basis. 
As part of its review of the going concern and longer-term viability 
of the Company, the Board also considers the sensitivity of the 
Company to changes in market prices and foreign exchange rates 
(see note 17 to the financial statements beginning on page 75), an 
analysis of how the portfolio would perform during a market crisis, 

26 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
Principal Risks and Uncertainties

Management and Mitigation

The departure of a key member of the portfolio 
management team may affect the Company’s 
performance.

for  dealing, 

Operational Risks  
As an externally managed investment trust, the 
Company is reliant on the systems of its service 
providers 
trade  processing, 
administrative  services,  financial  and  other 
functions.  If  such  systems  were  to  fail  or  be 
disrupted (including as a result of cyber crime or 
a pandemic) this could lead to a failure to comply 
regulations  and 
laws, 
with  applicable 
governance 
to  a 
financial loss. 

requirements  and/or 

Financial Risks 
The Company is exposed to liquidity risk and 
credit risk arising from the use of counterparties. 
If a counterparty were to fail it could adversely 
affect  the  Company  through  either  delay  in 
settlement or loss of assets. The most significant 
counterparty to which the Company is exposed 
is the Depositary, which is responsible for the 
safekeeping of the Company’s custodial assets.

and the ability of the Company to liquidate its portfolio if the need 
arose. Further details are included in the Going Concern and Viability 
Statements on pages 36 and 28 respectively. 
The Portfolio Manager reports to the Board on developments at 
MCM at each Board meeting. All investment decisions are made by 
an Investment Committee, reducing reliance on a single individual. 

The Board continuously monitors the performance of all the principal 
service providers with a formal evaluation process being undertaken 
each year. The Audit Committee reviews internal controls reports and 
key policies (including measures taken to mitigate cyber risks and 
disaster recovery procedures) put in place by its principal service 
providers. Both Frostrow and MCM provide a quarterly compliance 
report to the Audit Committee, which details their compliance with 
applicable laws and regulations. The Audit Committee maintains the 
Company’s risk matrix which details the risks to which the Company 
is exposed, the approach to managing those risks, the key controls 
relied upon and the frequency of the controls operation. Further 
details are set out in the Audit Committee Report on page 48.

The Company’s assets include liquid securities which can be sold 
to meet funding requirements, if necessary. Further information on 
financial instruments and risk can be found in note 17 to the financial 
statements beginning on page 75.  
The Board reviews the services provided by the Depositary and the 
internal controls report of the Custodian to ensure that the security 
of  the  Company’s  custodial  assets  is  maintained.  The  Portfolio 
Manager  is  responsible  for  undertaking  reviews  of  the  credit 
worthiness of the counterparties that it uses. The Board reviews the 
Portfolio  Manager’s  approved  list  of  counterparties  and  the 
Company’s use of those counterparties. Appropriate due diligence 
is undertaken to verify the existence and ownership of unquoted 
(non-custodial) assets. 

Legal and Regulatory Risks 
The regulatory or political environment in which 
the  Company  operates  could  change  to  the 
extent that it affects the Company’s viability. 

The  Board  monitors  regulatory  developments  but  relies  on  the 
services of its external advisers to ensure compliance with applicable 
law  and  regulations.  The  Board  has  appointed  a  specialist 
investment  trust  company  secretary  who  provides  industry  and 
regulatory updates at each Board meeting.

Impact of Covid-19 
The Board continues to monitor developments with respect 
to Covid-19. Restrictions imposed because of the pandemic 
have  challenged  operations,  but  the  Portfolio  Manager 

successfully continued dialogue with investee companies 
and the Board has stayed in close contact with the Portfolio 
Manager  and  has  continuously  monitored  portfolio  and 
share  price  developments.  All  of  the  Company’s  service 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

27

 
 
1

Strategic Report

Business Review 
continued  

providers  have  continued  to  provide  as-normal  services 
throughout,  notwithstanding  adopting  remote  working 
during the lockdowns.  

the following assumptions in assessing the Company’s 
longer-term viability: 

• There will continue to be demand for investment trusts;  

Impact of Ukraine Situation 
The Board is monitoring the events in Ukraine and related 
sanctions. To the best of the Board’s current knowledge the 
situation should have no direct impact on the Company and 
while  one  portfolio  company  is  affected  by  the  Russian 
sanctions,  Safran,  its  share  price  has  recovered  to 
December levels after initial volatility. 

Longer Term Viability Statement 
In accordance with the UK Corporate Governance Code, 
the  Directors  have  carefully  assessed  the  Company’s 
position and prospects as well as the principal risks and 
have formed a reasonable expectation that the Company 
will be able to continue in operation and meet its liabilities 
as they fall due over the next five financial years. The Board 
has  chosen  a  five  year  horizon  in  view  of  the  long-term 
nature and outlook adopted by the Portfolio Manager when 
making investment decisions. 

To make this assessment and in reaching this conclusion, 
the  Audit  Committee  has  considered  the  Company’s 
financial position and its ability to liquidate its portfolio and 
meet its liabilities as they fall due: 

• The  portfolio  is  principally  comprised  of  investments 
traded on major international stock exchanges. Based on 
historic analysis 86.7% of the current portfolio could be 
liquidated within 30 trading days with 83.5% in seven 
days and there is no expectation that the nature of the 
investments  held  within  the  portfolio  will  be  materially 
different in future; 

• The  expenses  of  the  Company  are  predictable  and 
modest in comparison with the assets and there are no 
capital  commitments  foreseen  which  would  alter  that 
position; and  

• The Company has no employees, only its non-executive 
Directors. Consequently it does not have redundancy or 
other employment related liabilities or responsibilities.  

The Audit Committee, as well as considering the potential 
impact  of  the  Company’s  principal  risks  and  various 
severe but plausible downside scenarios, has also made 

28 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

• The  Board  and  the  Portfolio  Manager  will  continue  to 
adopt a long-term view when making investments, and 
anticipated holding periods will be at least five years;  

• The Company invests principally in the securities of listed 
companies 
international  stock 
exchanges to which investors will wish to continue to 
have exposure;  

traded  on  major 

• The closed ended nature of the Company means that, 
unlike  open  ended  funds,  it  does  not  need  to  realise 
investments when shareholders wish to sell their shares; 

• Regulation will not increase to a level that makes running 

the Company uneconomical; and  

• The  performance  of  the  Company  will  continue  to  be 

satisfactory. 

Covid-19 was also factored into the key assumptions made 
by assessing its impact on the Company’s key risks and 
whether the key risks had increased in their potential to affect 
the normal, favourable and stressed market conditions. As 
part of this review the Board considered the impact of a 
significant  and  prolonged  decline  in  the  Company’s 
performance  and  prospects.  This  included  a  range  of 
plausible downside scenarios such as reviewing the effects 
of substantial falls in investment values and the impact of the 
Company’s ongoing charges ratio, which were the subject 
of stress testing. 

Board’s Duty to Promote the Success of 
the Company (s172) 
The  Directors  have  a  statutory  duty  to  promote  the 
success of the Company for the benefit of its members as 
a  whole,  whilst  also  having  regard  to  certain  broader 
matters. These include taking into consideration the likely 
consequences of any decision in the long-term; the need 
to foster the Company’s business relationships with its 
Portfolio Manager and other service providers; the impact 
of the Company’s operations on the community and the 
environment; the desire for the Company to maintain a 
reputation for high standards of business conduct; and 
the need to act fairly between members of the Company 
(s172 Companies Act 2006).  

The Board seeks to comply with these and the following describes how the Directors have had regard to the views of 
the Company’s stakeholders in their decision-making.

Who? 

Why?  

STAKEHOLDER 
GROUP 

THE BENEFITS OF ENGAGEMENT WITH 
THE COMPANY’S STAKEHOLDERS

Investors                    

Clear communication of the Company’s 
strategy and the performance against the 
Company’s objective can help the share 
price trade at a narrower discount or a wider 
premium to its net asset value, which 
benefits shareholders.

Who? 
HOW THE BOARD, THE AIFM AND THE 
PORTFOLIO MANAGER HAVE ENGAGED 
WITH THE COMPANY’S 
STAKEHOLDERS

   Frostrow as AIFM, the Portfolio Manager and 

the Company’s broker, on behalf of the 
Board, complete a programme of investor 
relations throughout the year (see also the 
following section on Company Promotion).  

  An analysis of the Company’s shareholder 

register is provided to the Directors at each 
Board meeting along with marketing reports 
from Frostrow. The Board reviews and 
considers the marketing plans on a regular 
basis. Reports from the Company’s broker 
are submitted to the Board on investor 
sentiment and industry issues.  

                                                                                                            Key mechanisms of engagement include:  
                                                                                                            l   The Annual General Meeting; 
                                                                                                            l   The Company’s website which hosts 

reports, video interviews with the Portfolio 
Manager and monthly factsheets; 

                                                                                                            l   One-on-one investor meetings; 
                                                                                                            l   As reported in the half year report, there 

was a significant vote against the re-
election of the Chairman at the last 
annual general meeting. Following 
engagement it was determined this was 
because his external appointments 
exceeded the internal corporate 
governance guidelines of a particular 
large shareholder. This shareholder did 
not engage before voting. The regular 
Board evaluation exercise already 
includes a review of Directors’ other time 
commitments (see page 43), but this was 
given greater emphasis at the latest 
review because of this vote; 

                                                                                                                l   The Board will explain in its announcement 

of the results of the AGM the actions it 
intends to take to consult Shareholders in 
order to understand the reasons behind 
any significant votes against; 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

29

 
 
 
 
                                   
1

Strategic Report

Business Review 
continued   

Who? 

Why?  

STAKEHOLDER 
GROUP 

THE BENEFITS OF ENGAGEMENT WITH 
THE COMPANY’S STAKEHOLDERS

Who? 
HOW THE BOARD, THE AIFM AND THE 
PORTFOLIO MANAGER HAVE ENGAGED 
WITH THE COMPANY’S 
STAKEHOLDERS

                                                                                                            l   Following engagement, an update will be 

Portfolio Manager     

Engagement with the Company’s Portfolio 
Manager is necessary to evaluate their 
performance against the Company’s stated 
strategy and to understand any risks or 
opportunities this may present. The Board 
ensures that the Portfolio Manager’s 
environmental, social and governance (“ESG”) 
approach is in line with standards elsewhere 
and is in line with the Board’s expectations. 

Engagement also helps ensure that Portfolio 
Management costs are closely monitored 
and remain competitive.

Service Providers      

The Company contracts with third parties 
for other services including: depositary; 
investment accounting & administration; 
company secretarial; and share registration. 
The Board ensures that the third parties to 
whom the services have been outsourced 
complete their roles in line with their service 
level agreements, thereby supporting the 
Company in its success and ensuring 
compliance with its obligations.

published no later than six months after 
the AGM and the Annual Report will 
detail the impact the Shareholder 
feedback has had on any decisions the 
Board has taken and any actions or 
resolutions proposed. 

   The Board meets regularly with the 

Company’s Portfolio Manager throughout 
the year both formally at the quarterly Board 
meetings and informally as needed. The 
Board also receives monthly performance 
and compliance reporting.  

  The Company produces an annual 

environmental impact statement setting out 
the environmental purpose of the Company 
and the impact its investments have, or 
intend to deliver. The report is included 
within this Annual Report on pages 18 to 21 
and is published as a separate document on 
www.menhaden.com. 

   It is the Board’s belief that Frostrow and 

Menhaden Capital Management LLP are the 
most important service providers in relation 
to the success of the Company. 

   The Board and Frostrow engage regularly 
with other service providers both in one-to-
one meetings and via regular written 
reporting. This regular interaction provides 
an environment where topics, issues and 
business development needs can be dealt 
with efficiently and collegiately. 

                                                                                                                The Board together with Frostrow maintained 

regular contact with the Company’s key 
service providers during the pandemic, as 
well as carrying out a review of the service 
providers’ business continuity plans and 
additional cyber security provisions.  

30 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
 
                                   
 
                                   
Who? 

Why?  

STAKEHOLDER 
GROUP 

THE BENEFITS OF ENGAGEMENT WITH 
THE COMPANY’S STAKEHOLDERS

Who? 
HOW THE BOARD, THE AIFM AND THE 
PORTFOLIO MANAGER HAVE ENGAGED 
WITH THE COMPANY’S 
STAKEHOLDERS

Portfolio companies    

Gaining a deeper understanding of the 
portfolio companies and their strategies as 
well as incorporating consideration of ESG 
factors into the investment process assists 
in understanding and mitigating risks of an 
investment as well as identifying future 
potential opportunities. 

  The Board encourages the Company’s 

Portfolio Manager to engage with companies 
and in doing so expects ESG issues to be a 
key consideration. 

  The Board receives an update on MCM’s 

engagement activities quarterly. 

What? 

WHAT WERE THE KEY TOPICS OF ENGAGEMENT? 

Key topics of engagement with investors 

l  Ongoing dialogue with shareholders concerning the 
strategy of the Company, performance and the 
portfolio.                                                                      

Outcomes and actions 
WHAT ACTIONS WERE TAKEN, INCLUDING 
PRINCIPAL DECISIONS?

 l The Portfolio Manager, Frostrow and the broker meet 
regularly with shareholders and potential investors to 
discuss the Company’s strategy, performance and 
portfolio.  

                                                In December 2020, The Board held a dedicated 

strategy session which reviewed the future strategy of 
the Company including an enhanced communication 
strategy with the Portfolio Manager, Frostrow and the 
broker in attendance. Strategy discussions continued 
as a constituent of the scheduled Board meetings 
during the last year. 

                                                To further aid the Board and investors in the 

monitoring of the NAV and the share price discount, 
the Board agreed that the Company’s NAV per share 
be announced daily rather than monthly from the start 
of 2021. 

Key topics of engagement with the external  
Portfolio Manager on an ongoing basis are  
portfolio composition, performance, outlook and  
business updates. 
l  The impact of Covid-19 upon their business and how 
components in the portfolio have been able to benefit 
during the pandemic, in particular through increased 
digitalisation.

 l The Board received regular updates from the Portfolio 

Manager throughout the Covid-19 pandemic, 
including its impact on investment decision making. 
Working practices adopted by the Portfolio Manager 
to cope with restrictions imposed because of the 
pandemic were also reviewed. No further action was 
considered necessary in this regard. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

31

                                   
 
 
 
 
 
1

Strategic Report

Business Review 
continued   

What? 

WHAT WERE THE KEY TOPICS OF ENGAGEMENT? 

l  The integration of ESG into the Portfolio Manager’s 
investment processes and their engagement with 
investee companies on ESG.

Other Service Providers 

l  The Directors have frequent engagement with the 
Company’s other service providers through the 
annual cycle of reporting and due diligence meetings 
or site visits by Frostrow. This engagement is 
completed with the aim of maintaining an effective 
working relationship and oversight of the services 
provided.

Company Promotion 
The  Company  has  appointed  Frostrow  to  promote  the 
Company’s shares to professional investors in the UK and 
Ireland. As investment company specialists, the Frostrow 
team  provides  a  continuous,  proactive  marketing, 
distribution and investor relations service that aims to grow 
the Company by encouraging demand for the shares. 

Frostrow  actively  engages  with  professional  investors, 
typically discretionary wealth managers, some institutions 
range  of  execution-only  platforms.  Regular 
and  a 
engagement helps to attract new investors and retain existing 
shareholders, and over time results in a stable share register 
made up of diverse, long-term holders. Frostrow, in turn, 
provides the Board with up-to-date and accurate information 
on the latest shareholder and market developments. 

Frostrow arranges and manages a continuous programme 
of one-to-one meetings with professional investors around 
the UK. These include regular meetings with ‘gate keepers’, 
the senior points of contact responsible for their respective 
organisations’  research  output  and  recommended  lists. 
The  programme  of  regular  meetings  also 
includes 
autonomous  decision  makers  within  large  multi-office 
groups, as well as small independent organisations. Some 
of these meetings involve MCM, but most of the meetings 
do  not,  which  means  the  Company  is  being  actively 
promoted while MCM focuses on managing the portfolio. 
The Chairman is also available to engage with shareholders. 

32 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Outcomes and actions 
WHAT ACTIONS WERE TAKEN, INCLUDING 
PRINCIPAL DECISIONS?

 l The Portfolio Manager reports regularly any ESG issues 
in the portfolio companies to the Board and the Board 
encourages the Portfolio Manager to engage with 
investee companies on climate change mitigation and 
reporting, which is expanded upon in the Impact 
Statement starting on page 18.

 l No specific action was required as the reviews of the 
Company’s service providers have been positive and 
the Directors believe their continued appointment is in 
the best interests of the Company. 

The Company also benefits from involvement in the regular 
professional investor seminars run by Frostrow in major 
centres,  notably  London  and  Edinburgh,  which  are 
focused on buyers of investment companies. 

The  creation  and  dissemination  of  information  on  the 
Company is also overseen by Frostrow. Frostrow produces 
all  key  corporate  documents,  monthly  factsheets,  annual 
the  Company’s  website 
reports 
and  manages 
www.menhaden.com.  All  Company 
information  and 
invitations to investor events, including updates from MCM 
on  the  portfolio  and  market  developments,  are  regularly 
emailed  to  a  growing  database,  overseen  by  Frostrow, 
consisting of professional investors across the UK and Ireland. 

Frostrow  maintains  close  contact  with  all  the  relevant 
investment trust broker analysts, particularly those from 
Numis Securities Limited, the Company’s corporate broker, 
but also others who publish and distribute research on the 
Company to their respective professional investor clients. 

Social, Human Rights and 
Environmental Matters 
The Company is an externally managed investment trust 
within  the  AIC  Environmental  Sector  and  invests  in 
companies and markets that are demonstrably delivering 
or benefiting significantly from the efficient use of energy or 
resources. The Board is responsible for oversight of the 
Portfolio  Manager  and  consequently  for  the  risks  and 

 
 
opportunities  that  derive  from  their  management  of  the 
Company’s  portfolio,  including  any  considered  to  be 
climate  related.  The  Company’s  resource  efficiency 
mandate is consistent with the drive towards net zero so 
the Company is well placed to benefit as investor focus 
evolves. The Company does not have any employees or 
premises,  nor  does  it  undertake  any  manufacturing  or 
other operations. All its functions are outsourced to third 
party service providers and therefore the Company itself 
does not have any employee or direct human rights issues, 
nor does it have any direct, material environmental impact. 
The  Company  therefore  has  no  environmental,  human 
rights, social or community policies. 

The  Company  recognises  risks  from  climate  change 
regulation,  such  as  potential  impacts  on  investee 
companies,  portfolio  construction,  marketing  and 
reputation. It also recognises the opportunity provided by 
the alignment of its investment objective and policy with 
the net zero agenda.  

The Board believes that the integration of financially material 
environmental, social and governance (“ESG”) factors into 
investment decision-making can reduce risk and enhance 
returns. The Portfolio Manager uses CDP ratings data as a 
basis  for  engagement  with  investee  companies  on 
ESG issues, including any considered to be climate related. 
More detail is included in the Company’s Environmental 
Impact Statement set out on pages 18 to 21.  

The  ongoing  engagement  and  dialogue  with  investee 
companies, including through proxy voting, are key parts 
of an asset stewardship role. 

The Directors encourage the Portfolio Manager to ensure 
the Company’s investments adhere to best practice in the 
management of ESG issues and encourage them to have 
due regard to the UN Global Compact and UN Principles 
of Responsible Investment. The Portfolio Manager was a 
signatory  to  the  Financial  Reporting  Council  2012  UK 
Stewardship Code and is reviewing its position against the 
requirements of the 2020 Code. 

As  an  investment  company,  the  Company  does  not 
provide goods or services in the normal course of business 
and does not have customers. Accordingly, the Company 
falls outside the scope of the Modern Slavery Act 2015. 
The Company’s suppliers are typically professional advisers 
and the Company’s supply chains are considered to be low 
risk in this regard. 

Anti-Bribery and Corruption Policy 
The  Board  has  adopted  a  zero-tolerance  approach  to 
instances  of  bribery  and  corruption.  Accordingly  it 
expressly prohibits anyone performing services or acting 
on  behalf  of  the  Company  from  accepting,  soliciting, 
paying,  offering  or  promising  to  pay  or  authorise  any 
payment,  public  or  private,  in  the  United  Kingdom  or 
abroad, to secure any improper benefit for themselves or 
for the Company. 

A  copy  of  the  Company’s  Anti  Bribery  and  Corruption 
Policy 
at 
www.menhaden.com. The policy is reviewed regularly by 
the Audit Committee. 

its  website 

found 

can 

be 

on 

Prevention of the Facilitation of Tax Evasion 
In response to the implementation of the Criminal Finances 
Act  2017,  the  Board  has  adopted  a  zero-tolerance 
approach to the criminal facilitation of tax evasion. A copy 
of the Company’s policy on preventing the facilitation of 
tax  evasion  can  be  found  on  the  Company’s  website 
www.menhaden.com. The policy is reviewed annually by 
the Audit Committee. 

This Strategic Report on pages 2 to 33 has been approved 
by the Board. 

Sir Ian Cheshire 
Chairman 
20 April 2022

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

33

2

Governance

Board of Directors

Emma Howard Boyd 
Emma  Howard  Boyd  has  been  the  chair  of  the 
Environment Agency since 2016. The Agency is a public 
body responsible for the protection and enhancement of 
the environment in England. 

She is also an ex-officio board member of the Department 
for Environment, Food & Rural Affairs and an advisor to 
the Board of Trade. Emma, with a background in finance, 
is  a  trustee,  board  member  or  advisor  of  a  number  of 
organisations, which include The Prince’s Accounting for 
Sustainability  Project,  the  Green  Finance  Institute,  the 
Coalition for Climate Resilient Investment, the Centre for 
Greening  Finance  and  Investment,  the  Council  for 
Sustainable Business, the European Climate Foundation, 
and recently became a non-executive director of Liontrust 
Asset  Management  PLC.  Emma  was 
the  UK 
commissioner to the Global Commission on Adaptation 
from 2018 until its sunset in January 2021. 

Past  roles  include  being  the  chair  of  trustees  at  Share 
Action,  vice  chair  of  Future  Cities  Capital,  and 
non-executive director of the Aldersgate Group and Thrive 
Renewables. 

Emma will step down from the Board at the conclusion of 
this year’s Annual General Meeting on 22 June 2022. 

Sir Ian Cheshire (Chairman) 
Sir Ian Cheshire is the chairman of Spire Healthcare Group 
plc, a non-executive director of BT Group plc and was 
appointed as the chairman of Channel 4 on 11 April 2022.  
In addition, he is chair of the Prince of Wales Charitable 
Fund and of the We Mean Business Coalition. 

Sir Ian was the chairman of Barclays UK, the ring-fenced 
retail bank, until December 2020. He was the group chief 
executive  of  Kingfisher  plc  from  January  2008  until 
February 2015 and prior to that he was chief executive of 
B&Q Plc from June 2005.  

Sir Ian was knighted in the 2014 New Year Honours for 
services to Business, Sustainability and the Environment. 

Duncan Budge 
Duncan  Budge  is  chairman  of  Dunedin  Enterprise 
Investment Trust plc and Artemis Alpha Trust plc, and a 
non-executive director of Lowland Investment Company 
plc, Biopharma Credit plc and Asset Value Investors Ltd. 

He  was  previously  a  director  of  J.  Rothschild  Capital 
Management from 1988 to 2012 and a director and chief 
operating officer of RIT Capital Partners plc from 1995 to 
2011.  Between  1979  and  1985  he  was  with  Lazard 
Brothers & Co. Ltd.

The Directors’ beneficial interests in the Company’s shares are set out in the Directors’ Remuneration Report on page 52. 

34 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
Barbara Donoghue 
Barbara  Donoghue  (also  known  as  Barbara  Donoghue 
Vavalidis)  is  a  non-executive  director  of  Byredo  AB,  a 
Stockholm based luxury fragrance company, having been 
its chair for the six years to 2020. 

Until  2020  she  was  also  a  partner  in  London  based 
Manzanita Capital, a private equity partnership specialising 
in  the  beauty  and  personal  care  industry.  Other  past 
appointments include chair of Susanne Kaufmann Ltd, an 
Austrian  based  beauty  company,  director  and  audit 
committee chair of Eniro AB, a Stockholm listed media 
company, member of the Competition Commission and 
Competition and Markets Authority and member of the 
board of the Independent Television Commission.  She had 
a  previous  career  in  finance  in  Toronto,  New  York  and 
London advising companies on raising debt and equity 
financing  and  on  executing  mergers  and  acquisitions, 
during which she worked at Bank of Nova Scotia, Bankers 
Trust and NatWest Markets. 

Howard Pearce 
Howard Pearce is the founder of HowESG Ltd, a specialist 
environmental,  asset  stewardship,  and  corporate 
governance consultancy business. He is also chairman of 
the Bank of Montreal Global Asset Management (EMEA) 
Responsible Investment Advisory Council. 

Previously  he  has  been  a  non  executive  director  of 
Response Global Media Limited, chair of the Pension Board 
of Avon and Wiltshire Pension Funds, board member and 
chair  of  the  Audit  Committee  of  Cowes  Harbour 
Commission, and a trustee and chair of the Investment and 
Audit Committees of the NHS ‘Above and Beyond’ charity. 
Between  2003  and  2013  Howard  was  the  head  of  the 
Environment  Agency  pension  fund  and  a  member  of  its 
Pensions and Investment Committee. Under his leadership, 
the fund won over 30 awards in the UK, Europe and globally 
for its financially and environmentally responsible investment, 
best  practice  fund  governance,  public  reporting  and  e-
communications. 

Meeting Attendance 
The  number  of  scheduled  meetings  of  the  Board  and  its  committees  held  during  the  year  and  each  Director’s 
attendance, is shown below: 

Type and number of meetings 
held in 2021
Sir Ian Cheshire
Duncan Budge
Emma Howard Boyd
Howard Pearce
Barbara Donoghue2  

Board
(4)
4
4
4
4
–

Audit Committee
(3)
31
3
3
3
–

Management 
Engagement 
Committee 
(1) 
1 
1 
1 
1 
– 

1 Sir Ian Cheshire is not a member of the Audit Committee but attended by invitation. 

2 Barbara Donoghue was appointed as a Director after the end of the financial year, on 1 February 2022.

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

35

 
 
2

Governance

Directors’ Report 

The Directors present their annual report on the affairs of 
financial 
the  Company  together  with  the  audited 
statements and the Independent Auditor’s Report for the 
year ended 31 December 2021. Disclosures relating to 
performance, future developments and risk management 
can be found within the Strategic Report on pages 2 to 33. 

Business and Status of the Company 
The Company is registered as a public limited company 
in England and Wales (registered number 09242421) and 
is an investment company within the terms of Section 833 
of  the  Companies  Act  2006  (the  “Act”).  Its  shares  are 
traded  on  the  main  market  of  the  London  Stock 
Exchange,  which  is  a  regulated  market  as  defined  in 
Section 1173 of the Act. 

The Company has received approval from HM Revenue & 
Customs as an investment trust under Sections 1158 and 
1159 of the Corporation Tax Act 2010. In the opinion of the 
Directors, the Company continues to direct its affairs so as 
to qualify for such approval. 

Continuation of the Company 
In accordance with the Company’s Articles of Association, 
a continuation vote was put to shareholders at the AGM 
held on 9 June 2020 and an overwhelming majority of 
98% of the votes cast were in favour of the Company’s 
continuation. The next opportunity for shareholders to vote 
on the continuation of the Company will be at the 2025 
AGM  and  there  will  be  opportunities  every  five  years 
thereafter. 

Results and Dividends 
The results attributable to shareholders for the year are 
shown  on  page  2  and  incorporated  in  this  Directors’ 
Report by reference. 

In accordance with the dividend policy set out on page 22 
the Board is recommending a final dividend, of 0.2p per 
ordinary share in respect of the year ended 31 December 
2021, to be payable on 29 June 2022 to shareholders on 
the register on 6 June 2022, with the shares marked ex-
dividend on 1 June 2022. An ordinary resolution to this 
effect is included in the AGM notice of meeting on page 86 
of this annual report. 

No dividends were declared in respect of the year ended 
31 December 2020. 

36 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

investment  activity, 

Going Concern 
the 
The  Company’s  portfolio, 
Company’s cash balances and revenue forecasts, and the 
trends  and  factors  likely  to  affect  the  Company’s 
performance are reviewed and discussed at each Board 
meeting.  The  Board  has  considered  a  detailed 
assessment of the Company's ability to meet its liabilities 
as they fall due, including stress tests which modelled the 
effects  of  substantial  falls  in  portfolio  valuations  and 
liquidity constraints on the Company’s NAV, cash flows 
and expenses. Based on the information available to the 
Directors at the date of this report, including the results of 
these stress tests, the conclusions drawn in the Viability 
Statement in the Strategic Report on page  28 and the 
Company’s cash balances, the Directors are satisfied that 
the  Company  has  adequate  financial  resources  to 
continue in operation for at least the next 12 months and 
that, accordingly, it is appropriate to continue to adopt the 
going concern basis in preparing the financial statements. 
In reaching these conclusions and those in the Longer-
Term Viability Statement, the stress testing conducted also 
featured consideration of the effects of Covid-19. 

Alternative Performance Measures 
The Financial Statements (on pages 62 to 80) set out the 
required statutory reporting measures of the Company’s 
financial performance. The Board additionally assesses 
the Company’s performance against a range of criteria 
that  are  viewed  as  particularly  relevant  for  investment 
trusts.  These  are  summarised  on  page  2,  explained  in 
greater detail in the Strategic Report under the heading 
‘Key  Performance  Indicators’  on  page  25  and  defined 
more  fully,  including  the  basis  of  calculation,  in  the 
Glossary  on  pages  82  and  83.  These  alternative 
performance measures are widely used in reporting within 
the investment company sector and the Directors believe 
they enhance the comparability of information and assist 
investors in understanding the Company’s performance.  

Capital Structure 
The  Company  has  a  single  share  class,  being  ordinary 
shares of 1p nominal value each, and has not issued any 
other  forms  of  security.  At  31  December  2021  the 
Company had 80,000,001 ordinary shares in issue and 
there has been no change up to the date of this report. 

Substantial Interests in Share Capital 
The Company was aware of the following substantial interests of 3% or more in the voting rights of the Company as at 
31 December 2021 and 31 March 2022. 

31 March 2022

31 December 2021 

Shareholder
Cavenham Private Equity
Generali Deutschland Versicherung
Ravenscroft
Charles Stanley
Armstrong Investments
Rath Dhu

Number
of
Ordinary
shares
15,635,000
10,000,000
5,339,950
3,417,793
2,600,000
2,400,000

% of
issued
share
capital
19.5
12.5
6.7
4.3
3.2
3.0

Number
of
Ordinary
shares
15,635,000
10,000,000
5,339,950
3,341,855
2,600,000
2,400,000

% of 
issued 
share 
capital 
19.5 
12.5 
6.7 
4.2 
3.2 
3.0

The voting rights of the ordinary shares on a poll are one 
vote for each share held. 

No shares were issued or repurchased during the year or 
to the date of this report. 

There are no: 

• restrictions  on  transfers  of  the  Company’s  ordinary 
shares, or in respect of their voting and dividend rights;  

• agreements, known to the Company, between holders  

regarding the transfer of ordinary shares; or 

• special rights with regard to control of the Company 

attaching to the ordinary shares. 

At the end of the year under review and to the date of this 
report, the Directors had shareholder authority to issue a 
further  800,000  ordinary  shares  and  to  repurchase  no 
more than 14.99% of the Company’s issued share capital. 
These  authorities  will  expire  at  the  forthcoming  Annual 
General Meeting. Proposals to renew the Board’s powers 
to issue and buy back shares are set out in the Notice of 
Annual General Meeting beginning on page 86. 

Beneficial Owners of Shares – Information 
Rights 
Beneficial owners of shares who have been nominated by 
the registered holder of those shares to receive information 
rights under section 146 of the Companies Act 2006 are 
required  to  direct  all  communications  to  the  registered 
holder  of  their  shares  rather  than  to  the  Company’s 
registrar or to the Company directly. 

Nominee Share Code 
Where  the  Company’s  shares  are  held  via  a  nominee 
company name, the Company undertakes: 

• to provide the nominee company with multiple copies 
of  shareholder  communications,  so  long  as  an 
indication of quantities has been provided in advance; 
and 

• to allow investors holding shares through a nominee 
company  to  attend  general  meetings,  provided  the 
correct  authority  from  the  nominee  company  is 
available.  

Nominee  companies  are  encouraged  to  provide  the 
necessary authority to underlying shareholders to attend 
the Company’s general meetings. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

37

 
2

Governance

Directors’ Report 
continued

Other Statutory Information 
The following information is disclosed in accordance with 
the Companies Act 2006: 

• the  rules  on  the  appointment  and  replacement  of 
directors  are  set  out  in  the  Company’s  articles  of 
association (the “Articles”). Any change to the Articles 
would be governed by the Companies Act 2006 and 
would be subject to a shareholder vote. 

• subject to the provisions of the Companies Act 2006, 
to the Articles, and to any directions given by special 
resolution,  the  business  of  the  Company  shall  be 
managed  by  the  Directors  who  may  exercise  all  the 
powers of the Company. The Directors’ authorities to 
issue and buy back shares in force at the end of the 
year, are recorded on page 37. 

• there are no agreements: 

(i)

to which the Company is a party that might affect its 
control following a takeover bid; or 

(ii) between the Company and its Directors concerning 

compensation for loss of office. 

Greenhouse Gas Emissions 
As the Company has no executive employees or premises 
and has engaged external firms to undertake investment 
management,  company  management  and  custodial 
activities, the Company is exempt from the requirements 
to  report  on  greenhouse  gas  emissions  from  its 
operations,  and  it  has  no  responsibility  for  any  other 
emissions-producing sources under the Companies Act 
2006 
(Strategic  Report  and  Directors’  Reports) 
Regulations 2013 or the Companies (Directors’ Report) 
and  Limited  Liability  Partnerships  (Energy  and  Carbon 
Report) Regulations 2018. 

The Company produces an annual environmental impact 
statement which is included within this Annual Report on 
pages  18  to  21  and  also  published  separately  on 
www.menhaden.com. The impact report provides further 
detail  on  the  environmental  goals  and  impact  of  the 
Company’s portfolio holdings. 

and  Development 

Common Reporting Standard (“CRS”) 
CRS is a global standard for the automatic exchange of 
information  commissioned  by  the  Organisation  for 
Economic  Cooperation 
and 
incorporated  into  UK  law  by  the  International  Tax 
the 
Compliance  Regulations  2015.  CRS 
Company to provide certain additional details to HMRC in 
relation to certain shareholders. The reporting obligation 
began  in  2016  and  is  an  annual  requirement.  The 
Company’s registrar, Link Group, has been engaged to 
collate such information and file the reports with HMRC 
on behalf of the Company. 

requires 

Directors’ & Officers’ Liability Insurance 
Cover 
Directors’  and  officers’  liability  insurance  cover  was 
maintained  by  the  Company  during  the  year  ended 
31  December  2021.  It  is  intended  that  this  cover  will 
continue  for  the  year  ending  31  December  2022  and 
subsequent years. 

Directors’ Indemnities 
During the year under review and to the date of this report 
indemnities were in force between the Company and each 
of its Directors under which the Company has agreed to 
indemnify each Director, to the extent permitted by law, in 
respect of certain liabilities incurred as a result of carrying 
out  his  or  her  role  as  a  director  of  the  Company.  The 
Directors  are  also  indemnified  against  the  costs  of 
defending criminal or civil proceedings or any claim by the 
Company or a regulator as they are incurred provided that 
where the defence is unsuccessful the Director must repay 
those defence costs to the Company. The indemnities are 
qualifying third party indemnity provisions for the purposes 
of the Companies Act 2006. 

A  copy  of  each  deed  of  indemnity  is  available  for 
inspection  at  the  Company’s  registered  office  during 
normal business hours and will be available for inspection 
at the Annual General Meeting. 

38 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Political Donations 
The  Company  has  not  made,  and  does  not  intend  to 
make, any political donations. 

Disclosure of Information to the Auditor 
The Directors are listed on pages 34 and 35. Each Director 
confirms that: 

• to the best of each Director’s knowledge and belief, 
there is no information relevant to the preparation of the 
audit  report  of  which  the  Company’s  Auditor  is 
unaware; and 

• each Director has taken all the steps a director might 
reasonably be expected to have taken to be aware of 
relevant  audit  information  and  to  establish  that  the 
Company’s Auditor is aware of that information.  

This  information  is  given  and  should  be  interpreted  in 
accordance  with  the  provisions  of  section  418  of  the 
Companies Act 2006. 

Annual General Meeting 
The Company’s Annual General Meeting (“AGM”) will be 
held at 25 Southampton Buildings, London WC2A 1AL on 
22 June 2022 at 12 noon.  

The business of the meeting is summarised in some detail 
in the Explanatory Notes to the Resolutions on pages 91 
to 92 of this Annual Report. 

The AGM resolutions include the following items of special 
business: 

Resolution 10 Authority to allot shares 

Resolution 11 Authority to disapply pre-emption rights 

Resolution 12 Authority to repurchase shares 

Resolution 13 Authority to hold General Meetings (other 
than the AGM) on at least 14 clear days’ notice. 

The full text of the resolutions can be found in the Notice 
of AGM beginning on page 86. 

The Board considers that the proposed resolutions are in 
the  best  interests  of  the  shareholders  as  a  whole. 
Accordingly,  the  Board  unanimously  recommends  to 
shareholders that they vote in favour of the resolutions to 
be proposed at the forthcoming AGM, as the Directors 
intend to do in respect of their own beneficial holdings.  

By order of the Board 

Frostrow Capital LLP  
Company Secretary  
20 April 2022 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

39

 
 
2

Governance

Statement of Directors’ Responsibilities 

Company  law  in  the  United  Kingdom  requires  the 
Directors to prepare financial statements for each financial 
year.  The  Directors  are  responsible  for  preparing  the 
financial statements in accordance with applicable law and 
regulations. In preparing these financial statements, the 
Directors have: 

Responsibility Statement of the Directors 
in respect of the Annual Report 
The  Directors,  whose  details  can  be 
found  on 
pages  34  and  35,  confirm  to  the  best  of  their 
knowledge that: 

• selected suitable accounting policies and applied them 

consistently; 

• made judgements and estimates that are reasonable 

and prudent; 

• followed applicable UK accounting standards; and 

• prepared the financial statements on a going concern 

basis. 

The  Directors  are  responsible  for  keeping  adequate 
accounting  records  which  disclose  with  reasonable 
accuracy at any time the financial position of the Company 
and enable them to ensure that the financial statements 
comply  with  the  Companies  Act  2006.  They  are  also 
responsible for safeguarding the assets of the Company 
and hence for taking reasonable steps for the prevention 
and detection of fraud and other irregularities. 

The  Directors  are  responsible  for  ensuring  that  the 
Directors’ Report and other information included in the 
Annual Report is prepared in accordance with company 
law in the United Kingdom. They are also responsible for 
ensuring  that  the  Annual  Report  includes  information 
required by the Listing Rules of the FCA. 

• the  financial  statements  within  this  Annual  Report, 
prepared  in  accordance  with  applicable  accounting 
standards,  give  a  true  and  fair  view  of  the  assets, 
liabilities, financial position and the return for the year 
ended 31 December 2021; and 

• the Chairman’s Statement, Strategic Report and the 
Directors’ Report include a fair review of the information 
required by 4.1.8R to 4.1.11R of the FCA’s Disclosure 
Guidance and Transparency Rules. 

The Directors consider that the Annual Report taken as a 
whole is fair, balanced and understandable and provides 
the  information  necessary  to  assess  the  Company’s 
position, performance, business model and strategy. 

On behalf of the Board 

Sir Ian Cheshire 
Chairman 
20 April 2022 

The financial statements are published on the Company’s 
website  www.menhaden.com.  The  maintenance  and 
integrity of this website, is the responsibility of Frostrow. 
The  work  carried  out  by  the  Auditor  does  not  involve 
consideration  of  the  maintenance  and  integrity  of  this 
website  and,  accordingly,  the  Auditor  accepts  no 
responsibility for any changes that have occurred to the 
financial statements since they were initially presented on 
the website. Visitors to the website need to be aware that 
legislation 
the 
preparation and dissemination of the financial statements 
may differ from legislation in their jurisdiction. 

the  United  Kingdom  governing 

in 

40 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Corporate Governance Statement

The Board and Committees 
Responsibility for effective governance lies with the Board whose role is to promote the long-term success of the 
Company. The governance framework of the Company reflects the fact that as an externally managed investment 
company, it has no employees and outsources portfolio management services to Menhaden Capital Management LLP 
and risk management, company management, company secretarial, administrative and marketing services to Frostrow 
Capital LLP. The Board generates value for shareholders through its oversight of the service providers and management 
of costs associated with running the Company. 

The Board 

Chairman – Sir Ian Cheshire 

Four additional non-executive Directors, all considered independent. 

Key roles and responsibilities: 

–  to provide leadership and set strategy within a framework of effective controls which enable risk to be assessed 

and managed; 

–  to ensure that a robust corporate governance framework is implemented; and 

–  to challenge constructively and scrutinise performance of all outsourced activities. 

Management Engagement 
Committee 

Chairman – Sir Ian Cheshire 

All Directors 

Key roles and responsibilities: 

–  to review the contracts, the performance and the 
remuneration of the Company’s principal service 
providers; and 

–  to make recommendations to the Board regarding 
the continuing appointment of the AIFM and the 
Portfolio Manager. 

Audit Committee 

Chairman – Howard Pearce 

Duncan Budge, Barbara Donoghue, 
Emma Howard Boyd 

Key roles and responsibilities: 

–  to review the Company’s financial reports; 

–  to oversee the risk and control environment; and 

–  to  review  the  performance  of  the  Company’s 

external Auditor. 

Copies of the full terms of reference, which clearly define the responsibilities of each committee, can be obtained from 
the Company Secretary, will be available for inspection at the Annual General Meeting, and can be found on the Company’s 
website www.menhaden.com.  

The Directors have decided that, given the size of the Board and the fact that all Directors are considered to be 
independent, it is unnecessary to form separate remuneration and nomination committees; the duties that would fall to 
those committees are carried out by the Board as a whole. However, the Chairman takes no part in discussions 
regarding his own remuneration and will not chair any discussions relating to the appointment of his successor. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

41

2

Governance

Corporate Governance Statement 
continued

The Board has considered the AIC Code of Corporate 
Governance (the “AIC Code”). The AIC Code addresses 
all the principles set out in the UK Corporate Governance 
Code (the “UK Code”), as well as setting out additional 
provisions  on  issues  that  are  of  specific  relevance  to 
investment companies. 

The Board considers that reporting against the principles 
and provisions of the AIC Code (which has been endorsed 
by  the  Financial  Reporting  Council)  will  provide  better 
information to shareholders. By reporting against the AIC 
Code, the Company meets its obligations under the UK 
Code  (and  associated  disclosure  requirements  under 
paragraph 9.8.6 of the Listing Rules) and as such does 
not need to report further on issues contained in the UK 
Code which are irrelevant to the Company. 

The  AIC  Code  is  available  on  the  AIC’s  website 
www.theaic.co.uk and the UK Code can be viewed on the 
Financial Reporting Council website www.frc.org.uk. 

The AIC Code includes an explanation of how the AIC 
Code adapts the principles and provisions set out in the 
UK  Code  to  make  them  relevant  for  investment 
companies. 

The  Company  has  complied  with  the  principles  and 
provisions of the AIC Code with the exception that the 
Board has not appointed a senior independent director. 
The Board considers that this is not necessary given the 
small size of the Board and the Company’s shareholder 
register. 

Purpose and Strategy 
The purpose and strategy of the Company are described 
in the Strategic Report on page 22. 

The Board 
Board Culture 
The Board aims to fully enlist differences of opinion, unique 
vantage  points  and  areas  of  expertise.  The  Chairman 
encourages open debate to foster a supportive and co-
operative approach for all participants. Strategic decisions 
are discussed openly and constructively. The Board aims 
to be open and transparent with shareholders and other 
stakeholders  and  for  the  Company  to  conduct  itself 
responsibly,  ethically  and  fairly  in  its  relationships  with 
service providers. 

42 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Responsibilities of the Chairman  
The Chairman’s primary role is to provide leadership to the 
Board, assuming responsibility for its overall effectiveness 
in directing the company. The Chairman is responsible for: 

• ensuring that the Board is effective in its task of setting 
and  implementing  the  Company’s  direction  and 
strategy; 

• taking  the  chair  at  general  meetings  and  Board 
meetings, conducting meetings effectively and ensuring 
all Directors are involved in discussions and decision-
making; 

• setting the agenda for Board meetings and ensuring the 
Directors receive accurate, timely and clear information 
for decision-making; 

• taking  a  leading  role  in  determining  the  Board’s 

composition and structure; 

• overseeing  the  induction  of  new  directors  and  the 

development of the Board as a whole; 

• leading  the  annual  board  evaluation  process  and 
assessing the contribution of individual Directors;  

• supporting  and  also  challenging  the  AIFM  and  the 
(and  other  suppliers  where 

Portfolio  Manager 
necessary); 

• ensuring effective communications with shareholders 

and, where appropriate, stakeholders; and 

• engaging with shareholders to ensure that the Board 

has a clear understanding of shareholder views. 

Director Independence 
The Board is comprised of five non-executive Directors, 
each  of  whom  is  independent  of  the  AIFM  and  the 
Portfolio  Manager.  Each  of  the  Directors,  including  the 
Chairman,  was 
independent  on  appointment  and 
continues to be independent when assessed against the 
circumstances set out in Provision 13 of the AIC Code 
(and  Provision  12  of  the  AIC  Code  which  relates 
specifically  to  the  Chairman).    Accordingly,  the  Board 
considers that all of the Directors are independent and 
there are no relationships or circumstances which are likely 
to impair or could appear to impair their judgement. 

Conflicts of Interest 
In line with the Companies Act 2006, the Board has the 
power to authorise any potential conflicts of interest that 
may arise and impose such limits or conditions as it thinks 
fit.  A  register  of  interests  and  potential  conflicts  is 
maintained and is reviewed at every Board meeting. It was 
resolved at each Board meeting during the year that there 
were  no  direct  or  indirect  interests  of  a  Director  that 
conflicted with the interests of the Company. Appropriate 
authorisation will be sought prior to the appointment of 
any  new  director  or  if  any  new  conflicts  or  potential 
conflicts arise. 

Directors’ Other Commitments 
As part of the annual Board evaluation process, each of 
the Directors assessed the overall time commitment of 
their  external  appointments  and  it  was  concluded  that 
they all have sufficient time to discharge their duties. 

Board Meetings 
The primary focus at regular Board meetings is the review 
of  investment  performance  and  associated  matters, 
including  asset  allocation,  marketing/investor  relations, 
gearing, peer group information and industry issues. The 
Board reviews key investment and financial data, revenue 
and expenses projections, analyses of asset allocation, 
transactions, performance comparisons, share price and 
net asset value performance. The Board’s approach to 
addressing  share  price  performance  during  the  year  is 
described in the Chairman’s Statement on page 6. 

The  Board  is  responsible  for  setting  the  Company’s 
the  continued 
corporate  strategy  and 
appropriateness of the Company’s investment objective, 
investment strategy and investment restrictions at each 
meeting. 

reviews 

The number of meetings and the individual attendance by 
directors is set out on page 35. 

Matters Reserved for Decision by the Board 
The Board has adopted a schedule of matters reserved 
for its decision. This includes, inter alia, the following: 

• requirements under the Companies Act 2006, including 
approval  of  the  half  yearly  and  annual  financial 
statements,  recommendation  of  the  final  dividend  (if 
the 
any),  declaration  of  any 

interim  dividends, 

appointment or removal of the Company Secretary, and 
determining the policy on share issuance and buybacks; 

• matters 

relating 

to  certain  Stock  Exchange 
requirements  and  announcements,  the  Company’s 
internal  controls,  and  the  Company’s  corporate 
governance structure, policy and procedures; 

• decisions relating to the strategic objectives and overall 
management  of 
the 
appointment or removal of the AIFM and other service 
providers, and review of the Investment Policy; and 

the  Company, 

including 

• matters relating to the Board and Board committees, 
including the terms of reference and membership of the 
committees, the appointment of directors (including the 
Chairman)  and 
the  determination  of  Directors’ 
remuneration. 

Day-to-day  operational  and  portfolio  management  is 
delegated to Frostrow and MCM respectively.  

The  Board  takes  responsibility  for  the  content  of 
communications regarding major corporate issues, even 
if Frostrow or MCM act as spokesmen. The Board is kept 
informed of relevant promotional material that is issued by 
Frostrow. 

Stewardship and the Exercise of Voting Powers 
The Board has delegated authority to MCM (as Portfolio 
Manager) to engage with companies held in the portfolio 
and to vote the shares owned by the Company. The Board 
has instructed that MCM submit votes for such shares 
wherever possible. MCM may refer to the Board on any 
matters of a contentious nature. 

The  Portfolio  Manager’s  approach  to  stewardship, 
including  their  consideration  of  environmental,  social 
and governance issues, is set out in their UK Stewardship 
Code (2012) Compliance Statement which can be found 
on the Company’s website www.menhaden.com.  

Independent Professional Advice 
The Board has formalised arrangements under which the 
Directors,  in  the  furtherance  of  their  duties,  may  seek 
independent  professional  advice  at  the  Company’s 
expense. No such advice was sought during the year. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

43

2

Governance

Corporate Governance Statement 
continued

Company Secretary 
The Directors have access to the advice and services of 
an investment trust specialist Company Secretary through 
its  appointed  representative,  which  is  responsible  for 
advising  the  Board  on  all  governance  matters.  The 
Company Secretary ensures governance procedures are 
followed and that the Company complies with applicable 
statutory and regulatory requirements.  

Board Tenure, Succession and Evaluation 
Tenure 
The tenure of each independent, non-executive director, 
including  the  Chairman,  is  not  ordinarily  expected  to 
exceed nine years. However, the Board has agreed that 
the tenure of the Chairman may be extended for a limited 
time  provided  such  an  extension  is  conducive  to  the 
Board’s overall orderly succession. The Board believes 
that  this  more  flexible  approach  to  the  tenure  of  the 
Chairman is appropriate in the context of the regulatory 
rules that apply to investment companies, which ensure 
that  the  chair  remains  independent  after  appointment, 
while  being  consistent  with  the  need  for  regular 
refreshment and diversity. 

Notwithstanding  this  expectation,  the  Board  considers 
that a director’s tenure does not necessarily reduce his or 
her ability to act independently and will continue to assess 
each Director’s independence annually, through a formal 
performance evaluation. 

Board Evaluation 
During the course of 2021, the performance of the Board, 
its committees and the individual Directors (including each 
Director’s  independence  and  time  commitments)  was 
evaluated through a formal assessment process led by the 
Chairman.  Mr  Pearce  led  the  assessment  of  the 
Chairman’s performance. 

The  Chairman  is  satisfied  that  the  Directors  are  all 
independent,  the  structure  and  operation  of  the  Board 
continues to be effective and that there is a satisfactory 
mix  of  skills,  experience  and  knowledge.  Board 
succession was identified as an area to be addressed and 
progress on this is discussed in following sections. 

All Directors submit themselves for annual re-election by 
shareholders. Further information on the contribution of 
each individual Director can be found in the explanatory 

44 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

notes to the notice of the AGM on page 91. Following the 
that 
the  Board 
evaluation  process, 
shareholders vote in favour of the Directors’ re-election at 
the forthcoming AGM.  

recommends 

Diversity Policy 
The Board supports the principle of Boardroom diversity, 
of which gender is one important aspect.  The Company’s 
policy is that the Board should be comprised of directors 
who  collectively  display  the  necessary  balance  of 
professional  skills,  experience,  length  of  service  and 
industry knowledge and that appointments to the Board 
should  be  made  on  merit,  against  objective  criteria, 
including diversity in its broadest sense.  

The objective of the policy is to have a broad range of 
approaches,  backgrounds,  skills,  knowledge  and 
experience represented on the Board. The Board believes 
that this will make the Board more effective at promoting 
the long-term sustainable success of the company and 
generating value for all shareholders by ensuring there is 
a breadth of perspectives among the directors and the 
challenge needed to support good decision-making. To 
this  end  achieving  a  diversity  of  perspectives  and 
backgrounds on the Board will be a key consideration in 
any Director search process. 

The current gender balance of three men and two women 
meets  the  recommendation  of  Lord  Davies’  report  on 
Women  on  Boards.  The  Board  is  aware  that  targets 
concerning ethnic diversity have been recommended for 
FTSE  250  companies.  While  the  Company  is  not  a 
constituent and the Board is small in size, the Board will 
continue  to  monitor  developments  in  this  area  and  will 
consider diversity during future director search processes. 

Succession  
The Board regularly considers its structure and recognises 
the need for progressive refreshment. 

The Board has an approved succession planning policy 
to ensure that (i) there is a formal, rigorous and transparent 
procedure for the appointment of new directors; and (ii) 
the  Board  is  comprised  of  members  who  collectively 
display  the  necessary  balance  of  professional  skills, 
experience,  length  of  service  and  industry/Company 
knowledge.  

All of the Directors who served during the financial year 
were  appointed when the Company was established and 
consequently  their  tenures  coincide.  The  Board  is 
committed to ensuring that there is an orderly succession 
with appropriate overlap of new Directors and, with that 
in  mind,  scouted  for  prospective  candidates  during 
the year.  

Appointments to the Board 
The rules governing the appointment and replacement of 
directors  are  set  out  in  the  Company’s  articles  of 
association and the aforementioned succession planning 
policy. Where the Board appoints a new director during 
the  year,  that  director  will  stand  for  election  by 
shareholders at the next AGM. Subject to there being no 
conflict  of  interest,  all  Directors  are  entitled  to  vote  on 
candidates for the appointment of new directors and on 
the recommendation for shareholders’ approval for the 
Directors  seeking  re-election  at  the  Annual  General 
Meeting. When considering new appointments, the Board 
endeavours to ensure that it has the capabilities required 
to  be  effective  and  oversee  the  Company’s  strategic 
priorities. This will include an appropriate range, balance 
and  diversity  of  skills,  experience  and  knowledge.  The 
Company is committed to ensuring that any vacancies 
arising are filled by the most qualified candidates.  

Following a scouting exercise during the course of the year 
the  Board  appointed  Barbara  Donoghue  as  a  new 
non-executive Director with effect from 1 February 2022. 
The  Board  did  not  utilise  the  services  of  an  external 
agency or advertise the position as it was considered that 
the Board’s contacts were sufficient to identify candidates 
of  high  quality  with  relevant  skills  and  experience. 
Ms Donoghue will offer herself for election by shareholders 
at the forthcoming AGM. 

Audit, Risk and Internal Control 
The Statement of Directors’ Responsibilities on page 40 
describes  the  Directors’  responsibility  for  preparing 
this report. 

The  Audit  Committee  Report,  beginning  on  page  47, 
explains  the  work  undertaken  to  allow  the  Directors  to 
make this statement and to apply the going concern basis 
of  accounting.  It  also  sets  out  the  main  roles  and 
responsibilities and the work of the Audit Committee and 
describes  the  Directors’  review  of  the  Company’s  risk 
management and internal control systems. 

A description of the principal risks facing the Company 
and  an  explanation  of  how  they  are  being  managed  is 
provided in the Strategic Report on pages 25 to 27. 

The Board’s assessment of the Company’s longer-term 
viability is set out in the Strategic Report on page 28. 

Remuneration 
The  Directors’  Remuneration  Report  beginning  on 
page  51  and  the  Directors’  Remuneration  Policy  on 
page  53  set  out  the  levels  of  remuneration  for  each 
Director  and  explain  how  Directors’  remuneration 
is determined. 

Service Providers 
Relationship with the AIFM and the Portfolio Manager 
Representatives 
in 
from  Frostrow  and  MCM  are 
attendance at each Board meeting to address questions 
on  specific  matters  and  seek  approval  for  specific 
transactions that they are required to refer to the Board. 
There is a respectful and constructive partnership between 
the Board, the AIFM and the Portfolio Manager, and the 
three parties worked closely together throughout the year. 

The  Management  Engagement  Committee  evaluates 
Frostrow and MCM’s performance and reviews the terms 
of  the  AIFM  and  Portfolio  Management  Agreements  at 
least  annually.  The  outcome  of  this  year’s  review  is 
described on page 24. 

Relationship with Other Service Providers 
The Management Engagement Committee monitors and 
evaluates all of the Company’s other service providers, 
including the Depositary, Registrar and Broker. At the most 
recent  review  in  November  2021,  the  Committee 
concluded that all the service providers were performing 
well and should be retained on their existing terms and 
conditions. 

Whistleblowing 
The  Board  has  gained  assurance  on  whistleblowing 
procedures at the Company’s principal service providers 
to ensure employees at those companies are supported 
in speaking up and raising concerns. No concerns relating 
to the Company were raised during the year. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

45

2

Governance

Corporate Governance Statement 
continued

Shareholders 
Shareholder Relations 
During the year, representatives of Frostrow, MCM and 
Numis  Securities  Limited  (the  Company’s  corporate 
stockbroker) regularly met with institutional shareholders 
and  private  client  asset  managers  to  understand  their 
views on governance and the Company’s performance. 
Reports  on  investor  sentiment  and  the  feedback  from 
investor meetings were discussed with the Directors at the 
following  Board  meeting.  The  Chairman  is  available  to 
meet with investors on request. 

Shareholder Communications 
The Directors welcome the views of all shareholders and 
place considerable importance on communications with 
them.  Shareholders  wishing  to  communicate  with  the 
Chairman, or any other member of the Board, may do so 
by writing to the Company Secretary. 

The Board supports the principle that the Annual General 
Meeting (“AGM”) be used to communicate with private 
investors. In particular, shareholders are encouraged to 
attend the AGM, where they are given the opportunity to 
question the Chairman, the Board and representatives of 
the Portfolio Manager. In addition, the Portfolio Manager 
makes  a  presentation  to  shareholders  covering  the 
investment performance and strategy of the Company at 

the AGM. Whilst it is hoped that it will be possible to hold 
the forthcoming AGM in a normal in-person format, the 
Board may need to make changes to the arrangements if 
the Government imposes restrictions on such gatherings. 
Accordingly, shareholders are encouraged to register their 
votes on our registrar’s website (www.signalshares.com) 
ahead  of  the  meeting  and  to  check  the  Company’s 
website  (www.menhaden.com)  near  the  meeting  date, 
where  any  changes  to  arrangements  will  be  posted.   
Details of the votes in respect of each resolution will be 
announced  to  the  market  and  published  on  the 
Company’s website after the meeting. 

Significant Holdings and Voting Rights 
Details of the shareholders with substantial interests in the 
Company’s shares, the Directors’ authorities to issue and 
repurchase the Company’s shares, and the voting rights 
of  the  shares  are  set  out  in  the  Directors’  Report  on 
page 37. 

By order of the Board 

Frostrow Capital LLP 
Company Secretary 
20 April 2022 

46 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Audit Committee Report 

Statement from the Audit Committee 
Chairman 
I am pleased to present the Audit Committee report for 
the year ended 31 December 2021. The Committee met 
three times during the year under review. 

The role of the Committee is to ensure that shareholder 
interests  are  properly  protected  in  relation  to  the 
application  of  financial  reporting  and  internal  control 
principles and to assess the effectiveness of the audit. The 
Committee’s roles and responsibilities are set out in full in 
its terms of reference which are available on request from 
the  Company  Secretary  and  can  be  seen  on  the 
Company’s website (www.menhaden.com). A summary 
of the Committee’s main responsibilities and how it has 
fulfilled them is set out below. 

objectivity as well as the effectiveness of the external 
audit process; 

• to agree the scope of the external Auditor’s work and 

to approve their remuneration; and 

• to develop and implement policy on the engagement of 
the external Auditor to supply non-audit services and 
to review and approve any non-audit work to be carried 
out by the external Auditor. 

Meetings and Business 
The following matters were dealt with at the Committee’s 
meetings: 

March 2021 
• Review  of  the  Company’s  annual  results,  including 

review of the Auditor’s report to the Committee; 

Composition 
The  Audit  Committee  comprises  Howard  Pearce 
(Chairman of the Committee), Duncan Budge, Barbara 
Donoghue and Emma Howard Boyd whose biographies 
are  set  out  on  pages  34  and  35.  The  Committee  as  a 
whole  has  experience  relevant  to  the  investment  trust 
industry  with  Committee  members  having  a  range  of 
financial  and  investment  experience.  Mr  Pearce  has 
extensive  experience  in  audit,  having  chaired  the  audit 
committees  of  numerous  organisations  as  outlined  on 
page 35. Mr Budge serves on the audit committees of the 
three  other 
is  a 
non-executive director. 

trusts  of  which  he 

investment 

Responsibilities 
In summary, the Committee’s principal functions are: 

• to monitor the integrity of the Company’s annual and 
half-year financial statements and any announcements 
relating to the Company’s financial performance; 

• to review the internal controls and risk management 
systems  of  the  Company  and  its  third-party  service 
providers; 

• to make recommendations to the Board regarding the 
appointment, re-appointment or removal of the external 
Auditor,  and  to  be  responsible  for  leading  an  audit 
tender process at least once every ten years; 

• to  have  primary  responsibility  for  the  Company’s 
relationship  with 
including 
reviewing  the  external  Auditor’s  independence  and 

the  external  Auditor, 

• Approval  of 

the 
the  Annual  Report, 
Environmental  Impact  Statement  and  the  unquoted 
investment valuations; 

including 

• Review  of  risk  management,  internal  controls  and 

compliance; and 

• Review of the need for an internal audit function. 

September 2021 
• Review of the Company’s terms of reference, non-audit 

services policy and audit tender guidelines; 

• Review of the outcome and effectiveness of the 2020 

year end audit and any matters arising; 

• Review of the Company’s half year results; 

• Approval  of  the  Half  Year  Report  and  financial 
statements, and the unquoted investment valuations;  

• Review  of  risk  management,  internal  controls  and 

compliance; and 

• Review of the Company’s anti bribery and corruption 
policy and the policy on the prevention of the facilitation 
of tax evasion, and the measures put in place by the 
Company’s service providers. 

November 2021 
• Review of the Auditor’s plan and terms of engagement 

for the 2021 year end  audit;  

• Review of new or revised reporting requirements and 

audit standards; 

• Review of the valuation methodology for the unquoted 

investments; and 

• Review of risks, internal controls and compliance.

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

47

A summary of the principal risks facing the Company is 
provided in the Strategic Report on pages 25 to 27. 

Against this background, a risk matrix has been developed 
which covers all key risks that the Company faces, the 
likelihood of their occurrence and their potential impact, 
how these risks are monitored and the mitigating controls 
in place.  

The  Board  has  delegated  to  the  Audit  Committee 
responsibility for the review and maintenance of the risk 
matrix and it reviews, in detail, the risk matrix each time it 
meets, bearing in mind emerging risks and any changes 
to the Company, its environment or service providers since 
the last review. Any significant changes to the risk matrix 
are  discussed  with  the  whole  Board.  There  were  no 
changes to the Company’s risk management processes 
during the year and no significant failings or weaknesses 
were  identified  from  the  Committee’s  most  recent  risk 
review. 

The Committee reviews internal controls reports from its 
principal  service  providers  on  an  annual  basis.  The 
Committee  is  satisfied  that  appropriate  systems  have 
been in place for the year under review and up to the date 
of approval of this report. 

2

Governance

Audit Committee Report 
continued

Performance Evaluation 
The  Committee  reviewed  the  results  of  the  annual 
evaluation of its performance during the year. As part of 
the evaluation, the Committee reviewed the following: 

• the composition of the Committee; 

• the performance of the Committee Chairman; 

• how the Committee had monitored compliance with 

corporate governance regulations; 

• how  the  Committee  had  considered  the  quality  and 
appropriateness of financial accounting and reporting; 

• the Committee’s review of significant risks and internal 

controls; and 

• the  Committee’s  assessment  of  the  independence, 
competence  and  effectiveness  of  the  Company’s 
external Auditor. 

It  was  concluded  that  the  Committee  was  performing 
satisfactorily and there were no formal recommendations 
made to the Board. 

Internal Controls and Risk Management 
The Board has overall responsibility for risk management 
and for the review of the internal controls of the Company, 
undertaken in the context of its investment objective. 

The Audit Committee, on behalf of the Board, reviews the 
key business, operational, compliance and financial risks 
facing the Company. In arriving at its judgement of what 
risks the Company faces, the Committee and the Board 
have considered the Company’s operations in light of the 
following factors: 

• the  nature  of  the  Company,  with  all  management 
functions outsourced to third party service providers; 

• the  nature  and  extent  of  risks  which  it  regards  as 
acceptable for the Company to bear within its overall 
investment objective; 

• the likelihood of such risks becoming a reality; and 

• the  Company’s  ability  to  reduce  the  likelihood  and 

impact of such risk.  

48 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Significant Reporting Matters 
The Committee considered the significant issues in respect of the Annual Report, including the financial statements. 
The table below sets out the key areas of audit risk identified and also explains how these were addressed. 
Significant risk

How the risk was addressed 

existence 

Valuation, 
and 
ownership  of  investments,  in 
particular unquoted investments

Risk of revenue being misstated 
due to the improper recognition 
of revenue.

The  valuation  of  investments  is  undertaken  in  accordance  with  the  accounting 
policies in note 1 to the financial statements beginning on page 66. Controls are in 
place to ensure that valuations are appropriate and existence is verified through 
reconciliations with the Depositary. The Committee discussed with Frostrow and 
MCM the process by which the unquoted investments are valued, and ownership 
documented, including the reconciliation process with the Depositary. They also 
reviewed  the  valuation  of  the  unquoted  investments  as  at  31  December  2021, 
including the level of any discounts to net asset value applied to the unquoted 
valuations, to ensure that they were carried out in accordance with the accounting 
policy set out in note 1(b) on page 68. Having reviewed the valuations, the Committee 
confirmed that they were satisfied that the investments had been valued correctly. 

The Committee took steps to gain an understanding of the processes in place to 
record investment income and transactions.

Financial Statements 
The Board has asked the Committee to confirm that in its 
opinion the Board can make the required statement that 
the Annual Report taken as a whole is fair, balanced and 
understandable and provides the information necessary 
for  shareholders  to  assess  the  Company’s  position, 
performance,  business  model  and  strategy.  The 
Committee has given this confirmation on the basis of: 

• the procedures followed in the production of the Annual 
Report, including the processes in place to assure the 
accuracy of factual content; 

• the extensive levels of review that were undertaken in 
the production process, by Frostrow and also by the 
Committee; and 

• the internal control environment operated by Frostrow 
Capital LLP (the AIFM), Menhaden Capital Management 
LLP (the Portfolio Manager), JP Morgan (the Depositary) 
and other service providers. 

The Committee is satisfied that it is appropriate for the 
Board to prepare the financial statements on the going 
concern basis. Further detail can be found on page 36. 
The financial statements can be found on pages 62 to 80. 

The Committee also considered the longer-term viability 
of the Company in connection with the Board’s statement 
in  the  Strategic  Report  on  page  28.  The  Committee 

reviewed the Company’s financial position (including its 
cash flows and liquidity position), the principal risks and 
uncertainties and the results of stress tests and scenarios 
which  considered  the  impact  of  severe  stock  market 
volatility on shareholders’ funds. This included modelling 
further substantial market falls, and significantly reduced 
market liquidity, to that experienced recently in connection 
with the coronavirus pandemic. The scenarios assumed 
that there would be significant falls in asset prices, that the 
Company’s existing capital commitments would be drawn 
down rapidly and in large instalments, that there would be 
no sales of or distributions from private investments, and 
that listed portfolio companies would cut their dividends. 

The  results  illustrated  the  potential  impact  on  the 
Company’s NAV, expenses, cash flows and ability to meet 
its liabilities and capital commitments. In even the most 
stressed  scenario,  the  Company  was  shown  to  have 
sufficient cash, or to be able to liquidate a sufficient portion 
of  its  listed  holdings,  in  order  to  be  able  to  meet  its 
liabilities  as  they  fall  due.  Based  on  the  information 
available  to  the  Directors  at  the  time,  the  Committee 
therefore concluded it was reasonable for the Board to 
expect  that  the  Company  will  be  able  to  continue  in 
operation and meet its liabilities as they fall due over the 
next five financial years. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

49

2

Governance

Audit Committee Report 
continued

External Auditor 
In  addition  to  the  reviews  undertaken  at  Committee 
meetings, I met with Mazars LLP (“Mazars”) on 9 March 
2022 to discuss the progress of the audit and the draft 
Annual Report. 

In order to fulfil the Committee’s responsibility regarding 
the independence of the Auditor, the Committee reviewed: 

• the senior audit personnel in the audit plan, in order to 
ensure that there were sufficient, suitably experienced 
staff  with  knowledge  of  the  investment  trust  sector 
working on the audit; 

• the steps the Auditor takes to ensure its independence 

and objectivity; 

• the  statement  by  the  Auditor  that  they  remain 
independent  within  the  meaning  of  the  relevant 
regulations and their professional standards; and 

• the need for any non-audit services to be performed by 
the  Auditor  (there  were  none  during  the  year  under 
review). 

In order to consider the effectiveness of the audit process, 
we reviewed: 

• the  Auditor’s  execution  and  fulfilment  of  the  agreed 
audit plan, including their ability to communicate with 
management and to resolve any issues promptly and 
satisfactorily, and the audit partner’s leadership of the 
audit team; 

• the quality of the report arising from the audit itself; and 

• feedback from the Auditor and also Frostrow as the 
AIFM  on  the  conduct  of  the  audit  and  their  working 
relationship. 

is  satisfied  with 

the  Auditor’s 
The  Committee 
independence and the effectiveness of the audit process, 
together  with  the  degree  of  diligence  and  professional 
scepticism brought to bear. 

Non-Audit Services 
The Auditor did not carry out any non-audit work during 
the year. The Audit Committee will monitor the need for 
non-audit work to be performed by the Auditor, if any, in 
accordance with the Company’s non-audit services policy. 

50 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

The Audit Committee will also seek assurances from the 
Auditor that they maintain suitable policies and procedures 
ensuring independence, and monitor compliance with the 
relevant regulatory requirements on an annual basis. 

Auditor Reappointment 
Stephen Eames was the audit partner for the financial year 
under review and he has confirmed Mazars’ willingness to 
continue  to  act  as  Auditor  to  the  Company  for  the 
forthcoming financial year.  Mazars’ appointment is subject 
to  shareholder  approval  at  the  next  Annual  General 
Meeting to be held on 22 June 2022 and the resolution  
can be found in the Notice of AGM on page 86. 

As  a  public  company  listed  on  the  London  Stock 
Exchange, the Company is subject to mandatory auditor 
rotation  requirements.    Based  on  these  requirements, 
another tender process will be conducted no later than 
2029.  The Committee will, however, continue to consider 
annually  the  need  to  go  to  tender  for  audit  quality, 
remuneration or independence reasons. 

Howard Pearce 
Chairman of the Audit Committee 
20 April 2022 

 
Directors’ Remuneration Report 

Statement from the Chairman 
I  am  pleased  to  present  the  Directors’  Remuneration 
Report  to  shareholders.  An  ordinary  resolution  for  the 
approval of this report will be put to shareholders at the 
Company’s forthcoming Annual General Meeting. The law 
requires the Company’s Auditor to audit certain disclosures 
provided  in  this  report.  Where  disclosures  have  been 
audited,  they  are  indicated  as  such  and  the  Auditor’s 
opinion  is  included  in  their  report  to  shareholders  on 
pages 54 to 61. 

The Board considers the framework for the remuneration 
of the Directors on an annual basis. It reviews the ongoing 
appropriateness of the Company’s remuneration policy 
and  the  individual  remuneration  of  the  Directors  by 
reference to the activities and particular complexities of 
the Company and in comparison with other companies of 
a  similar  structure  and  size.  This  is  in  line  with  the 
AIC Code. 

Directors’ fees during the year were unchanged from the 
previous year: £50,000 per annum for the Chairman and 
£25,000  per  annum  for  Directors,  with  Directors  who 
serve  on  the  Audit  Committee  receiving  an  additional 
£15,000  per  annum.    Directors’  fees  have  remained 

unchanged  since  the  Company’s  launch  in  2015.  The 
Board as a whole reviewed the fee levels at a meeting held 
on 16 November 2021 and it was decided that they would 
remain  unchanged  for  the  year  ending  31  December 
2022. The projected fees for 2022 are set out on page 53.  
No remuneration consultants were appointed during the 
year (2020: none). 

Levels of remuneration reflect both the time commitment 
and  responsibility  of  the  role.  The  Directors  are 
remunerated exclusively by fixed fees in cash and do not 
receive bonus payments or pension contributions from the 
Company, hold options to acquire shares in the Company, 
or  other  benefits.  All  Directors  are  entitled  to  the 
reimbursement  of  reasonable  out  of  pocket  expenses 
incurred  by  them  in  order  to  perform  their  duties  as 
directors of the Company. 

The simple fee structure reflects the non-executive nature 
of the Board, which itself reflects the Company’s business 
model as an externally managed investment trust (please 
refer to the Business Review beginning on page 22 for 
more  information).  Accordingly,  statutory  disclosure 
to  executive  directors’  and 
requirements 
employees’ pay do not apply. 

relating 

Single total figure of remuneration (audited) 

Director

Date of 
appointment
to the Board

Sir Ian Cheshire

3 October 2014

Duncan Budge

3 October 2014

Emma Howard Boyd

3 October 2014

Howard Pearce

3 October 2014

Barbara Donoghue^

1 February 2022

2021
Taxable
expenses

–

–

–

Total

50,000

40,000

40,000

2,464

42,464

n/a

n/a

Fees

50,000

40,000

40,000

40,000

n/a

Fees

50,000

40,000

40,000

40,000

n/a

TOTAL

170,000

2,464

172,464

170,000

2020
Taxable
expenses

–

–

–

580

n/a

580

Total

50,000

40,000

40,000

40,580

n/a

170,580

Percentage 
change in 
fees (%) 

0 

0 

0 

0 

n/a 

^ Barbara Donoghue was appointed as a Director after the end of the financial year. 

No payments have been made to any former directors. It is the Company’s policy not to pay compensation upon leaving 
office for whatever reason. None of the fees referred to in the above table were paid to any third party in respect of the 
services provided by any of the Directors. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

51

 
 
 
2

Governance

Directors’ Remuneration Report 
continued

Directors’ Interests in the Company’s 
Shares (audited) 

Ordinary
shares
of 1p each
as at
31 Dec 2021

Ordinary 
shares 
of 1p each 
as at 
31 Dec 2020 

115,000
10,000
23,000
40,000
n/a
188,000

115,000 
10,000 
23,000 
40,000 
n/a 
188,000 

Sir Ian Cheshire
Duncan Bridge
Emma Howard Boyd
Howard Pearce
Barbara Donoghue^
Total

^ Barbara Donoghue was appointed as a Director with effect from 

1 February 2022. She holds 216,693 shares in the Company, which she 
held on appointment. 

No changes have been notified to the date of this report. 

The Company does not have share options or a share 
scheme,  and  does  not  operate  a  pension  scheme.   
Directors are not required to own shares in the Company. 

Performance 
The graph below shows the total shareholder return of the 
Company since its launch on 31 July 2015 against the RPI 
plus 3% over the same period. 

%

160.0

140.0

120.0

100.0

80.0

60.0

40.0

20.0

0.0

Jul 15 Jan 16 Jul 16 Jan 17 Jul 17

Jan18

Jul 18 Jan 19 Jul 19 Jan 20 Jul 20

Jan 21

Jul 21

RPI+3%

Company Share Price Total Return

Source: Frostrow Capital LLP, Office for National Statistics  
Rebased to 100 as at 31 July 2015 

52 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Relative Cost of Directors’ Remuneration 
The table below shows the comparative cost of Directors’ 
fees compared with the level of dividend distribution and 
Company  expenses  for  the  years  ended  31  December 
2020 and 2021. 

Total returns
Directors’ fees
Dividends paid
Total ongoing 
expenses

2021
£’000
18,399
194
–

2020
£’000
12,453
189
–

Change  
% 
48% 
3% 
– 

2,139

1,913

12% 

Statement of Voting at the AGM 
At the Annual General Meeting held on 3 June 2021 the 
results  in  respect  of  the  resolution  to  approve  the 
Directors’ Remuneration Report were as follows: 

Votes cast
for

Votes cast 
against

36,667,870
100.0%

–
–

Votes  
withheld 

3,303* 

*Votes withheld are not votes by law and are therefore not counted in the 
calculation of votes for or against a resolution. 

By order of the Board 

Sir Ian Cheshire 
Chairman 
20 April 2022 

 
 
 
 
  
Directors’ Remuneration Policy 

is 

that 

remuneration  policy 

The  Company’s 
the 
remuneration of each Director should be commensurate 
with the duties, responsibilities and time commitment of 
each respective role and consistent with the requirement 
to attract and retain directors of appropriate quality and 
experience. The remuneration should also be comparable 
to that of investment trusts of similar size and structure. 

The Directors’ fees for 2021 and 2022 are shown in the 
table below. The Company does not have any employees. 

Directors’ Fees Current and Projected 

Directors are remunerated in the form of fixed fees payable 
monthly  in  arrears.  There  are  no  long  or  short-term 
incentive  schemes,  share  option  schemes  or  pension 
arrangements and the fees are not specifically related to 
the  Directors’  performance,  either 
individually  or 
collectively. 

Sir Ian Cheshire
Duncan Budge
Howard Pearce
Emma Howard Boyd1
Barbara Donoghue2

Fees (£)
2022
50,000
40,000
40,000
19,111
36,667
185,778

Fees (£) 
2021 
50,000 
40,000 
40,000 
40,000 
n/a 
170,000 

The Directors’ remuneration is determined within the limits 
set  out  in  the  Company’s  Articles  of  Association.  The 
present limit is £500,000 in aggregate per annum. 

It is the Board’s intention that the remuneration policy will 
be  considered  by  shareholders  at  the  annual  general 
meeting at least once every three years. If, however, the 
remuneration policy is varied, shareholder approval will be 
sought at the AGM following such variation. The Board will 
formally review the remuneration policy at least once a 
year to ensure that it remains appropriate. 

This  policy  was  last  approved  by  shareholders  at  the 
Annual  General  Meeting  held  in  2019.  Accordingly,  an 
ordinary resolution for the approval of this policy will be 
put to shareholders at the  Annual General Meeting to be 
held on 22 June 2022. It is intended that this policy will 
remain  in  place  for  the  following  financial  year  and 
subsequent financial periods. 

No  communications  have  been 
from 
shareholders  regarding  Directors’  remuneration.  The 
Board  will  consider  any  comments  received  from 
shareholders on the remuneration policy. 

received 

1 Emma Howard Boyd will step down from the Board on 22 June 2022. 
2 Barbara Donoghue was appointed as a Director with effect from 

1 February 2022. 

Any  new  director  appointed  to  the  Board  will,  at  the   
current remuneration levels, receive a fee of £25,000 per 
annum.  Directors  who  serve  on  the  Audit  Committee 
receive  an  additional  fee  of  £15,000  per  annum.  The 
fee  of  £25,000 
Chairman  receives  an  additional 
per annum. 

All Directors are non-executive, appointed under the terms 
of letters of appointment and none has a service contract. 
The Directors’ letters of appointment may be inspected at 
the  Company’s  registered  office.  The  terms  of  their 
appointment  provide  that  Directors  shall  retire  and  be 
subject to election at the first annual general meeting after 
their  appointment  and  to  re-election  every  three  years 
thereafter. However, the Directors submit themselves for 
annual re-election by shareholders, in line with the AIC 
Code of Corporate Governance. The terms also provide 
that a Director may be removed without notice and that 
compensation will not be due on leaving office. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

53

 
 
2

Governance

Independent Auditor’s Report to the  
Members of Menhaden Resource Efficiency PLC  

Opinion 
We have audited the financial statements of Menhaden Resource Efficiency PLC (the “Company”) for the year ended 
31 December 2021 which comprise the Income Statement, the Statement of Changes in Equity, the Statement of 
Financial Position, the Statement of Cash Flows and notes to the financial statements, including a summary of significant 
accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and 
United Kingdom Accounting Standards, including FRS 102, “The Financial Reporting Standard applicable in the UK 
and Republic of Ireland” (United Kingdom Generally Accepted Accounting Practice). 

In our opinion, the financial statements: 

• give a true and fair view of the state of the Company’s affairs as at 31 December 2021 and of its return for the year 

then ended; 

• have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice; and 

• have been prepared in accordance with the requirements of the Companies Act 2006. 

Basis for opinion 
We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our 
responsibilities under those standards are further described in the “Auditor’s responsibilities for the audit of the financial 
statements” section of our report. We are independent of the Company in accordance with the ethical requirements that 
are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard, as applied to public 
interest entities and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe 
that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. 

Conclusions relating to going concern 
In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of accounting 
in the preparation of the financial statements is appropriate.  

Our audit procedures to evaluate the directors’ assessment of the Company’s ability to continue to adopt the going 
concern basis of accounting included but were not limited to: 

• Undertaking an initial assessment at the planning stage of the audit to identify events or conditions that may cast 

significant doubt on the Company’s ability to continue as a going concern; 

• Reviewing the directors’ going concern assessment including Covid-19 implications based on a ‘most likely’ (base 

case) scenario and a ‘worst case scenario’ as approved by the board of directors on 20 April 2022;  

• Making enquiries of directors to understand the period of assessment considered by the Directors, the completeness 
of the adjustments taken into account and implication of those when assessing the ‘most likely’ scenario and the 
‘worst case scenario’. This included examining the minimum cash inflow and committed outgoings under the ‘base 
case’ cash flow forecasts and evaluated whether the directors’ conclusion that liquidity headroom remained in all 
events was reasonable; 

• Assessing and challenging the appropriateness of the directors’ key assumptions in their cashflow forecasts, by 
reviewing supporting and contradictory evidence in relation to these key assumptions and assessing the directors’ 
consideration of severe but plausible scenarios;  

• Testing the accuracy and functionality of the model used to prepare the directors’ forecasts; and 

• Evaluating the appropriateness of the directors’ disclosures in the financial statements on going concern. 

54 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions 
that, individually or collectively, may cast significant doubt on the Company’s ability to continue as a going concern for 
a period of at least twelve months from when the financial statements are authorised for issue. 

Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant 
sections of this report. 

In relation to the Company’s reporting on how it has applied the UK Corporate Governance Code, we have nothing 
material to add or draw attention to in relation to the directors’ statement in the financial statements about whether the 
director’s considered it appropriate to adopt the going concern basis of accounting. 

Key audit matters 
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the 
financial statements of the current period and include the most significant assessed risks of material misstatement 
(whether or not due to fraud) we identified, including those which had the greatest effect on: the overall audit strategy; 
the allocation of resources in the audit; and directing the efforts of the engagement team. These matters were addressed 
in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not 
provide a separate opinion on these matters. 

We summarise below the key audit matters in forming our opinion above, together with an overview of the principal 
audit procedures performed to address each matter and key observations arising from those procedures. 

This matter, together with our findings, were communicated to those charged with governance through our Audit 
Completion Report. 

Key Audit Matter

How our scope addressed this matter 

the 

Valuation,  existence  and  ownership  of 
investment portfolio 
The Company has a significant portfolio of quoted and 
unquoted  investments,  these  are  measured  in 
accordance with the requirements under FRS102 and 
the Statement of Recommended Practice issued by 
the Association of Investment Companies. 

Investments  make  up  101%  of  total  net  assets  by 
value and are considered to be the key driver for the 
Company. The investments are made up of unquoted 
investments and quoted investments. 

There  is  a  significant  level  of  judgements  made  in 
ascertaining  the  fair  value  of  these  unquoted 
investments. There is a risk that judgements made 
when valuing the unquoted investments may lead to 
a misstatement in the value recorded in the Statement 
of Financial Position.

Unquoted investments 
• understanding management’s process to value unquoted 
investments  through  discussions  with  management  and 
examination  of  control  reports  on  the  third  party  service 
organisations; 

• obtaining and agreeing confirmation of investments held in 
order to obtain comfort over existence and ownership;  

• we engaged our valuation experts in considering whether 
the  methodology  and  assumptions  applied  for  valuing 
unquoted investments were in accordance with published 
guidance,  principally  the  International  Private  Equity  and 
Venture Capital Valuation Guidelines. This included reviewing 
the investment valuation policies of the private equity funds, 
reviewing  the  fund’s  latest  available  audited  financial 
statements, reviewing the fund’s latest valuation statements, 
reviewing any recent transactions and discussion with the 
fund’s management where applicable;

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

55

 
2

Governance

Independent Auditor’s Report 
continued 

Key Audit Matter

How our scope addressed this matter 

The quoted investments are included initially at fair 
value which is taken to be their cost and subsequently 
valued at fair value which are quoted bid prices for 
investments traded in active markets. Although the 
quoted investments are valued at quoted bid prices, 
there  is  a  risk  that  errors  in  valuation  can  have  a 
significant impact on the numbers presented. 

See  pages  67  and  68  for  further  details  on  the 
accounting policy for investments and page 67 for key 
judgements made. 

There is also a risk that investments recorded might 
not exist or might not be owned by the Company. 

We  therefore  identified  valuation,  existence  and 
ownership of investments as a key audit matter as it 
had the greatest effect on our overall audit strategy 
and allocation of resources.

• reviewing whether there are any going concern issues and 
uncertainties in relation to Covid-19 for the actual portfolio 
companies as well as their underlying investments;  

• agreeing valuation of unquoted investments to year end fair 
values as reported in valuation statements received directly 
from the investee funds; and 

• reviewing  the  adequacy  of  the  disclosure  in  the  financial 
statements including valuation methodology, assumptions 
and fair value hierarchy used. Ensuring that the methodology 
applied is in accordance with FRS102 and the Statement of 
Recommended  Practice  issued  by  the  Association  of 
Investment Companies. 

Quoted investments 
• understanding  management’s  process  to  value  quoted 
investments  through  discussions  with  management  and 
third  party 
examination  of  control  reports  on 
administrator; 

the 

• agreeing  the  valuation  of  quoted  investments  to  an 

independent source of market prices; 

• analysing the trading history of securities to see whether 
they have been traded frequently and valued at which they 
have  been  traded  to  ensure  there  are  no  unusual  price 
movements indicating the year end prices are stale; 

• obtaining and agreeing confirmation from the custodian of 
investments held in order to obtain comfort over existence 
and ownership; and 

• reviewing  the  adequacy  of  the  disclosure  in  the  financial 
statements and ensure that the methodology applied is in 
accordance  with  FRS102  and 
the  Statement  of 
Recommended  Practice  issued  by  the  Association  of 
Investment Companies.  

Our observations 
Based  on  the  work  performed  and  evidence  obtained,  we 
consider the methodology and assumptions used to value the 
investments as appropriate. We did not note any issues with 
regard to the existence or the ownership of the investments 
held as at 31 December 2021.

56 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
Our application of materiality and an overview of the scope of our audit 
The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for 
materiality. These, together with qualitative considerations, helped us to determine the scope of our audit and the 
nature, timing and extent of our audit procedures on the individual financial statement line items and disclosures and 
in evaluating the effect of misstatements, both individually and on the financial statements as a whole. Based on our 
professional judgement, we determined materiality for the financial statements as a whole as follows: 

Overall materiality

How we determined it

£1,245,000 

This has been calculated with reference to the Company’s net assets, of which 
it represents approximately 1%. 

Rationale for benchmark applied

Net assets have been identified as the principal benchmark within the financial 
statements as it is considered to be the focus of the shareholders.  

Performance materiality

Reporting threshold

Approximately  1%  of  net  assets  have  been  chosen  to  reflect  the  level  of 
understanding of the stakeholders of the Company in relation to the inherent 
uncertainties around accounting estimates and judgements. 

Performance  materiality  is  set  to  reduce  to  an  appropriately  low  level  the 
probability that the aggregate of uncorrected and undetected misstatements 
in the financial statements exceeds materiality for the financial statements as a 
whole. 

On the basis of our risk assessments, together with our assessment of the 
overall control environment, our judgement was that performance materiality 
was £933,000 which is approximately 75% of overall materiality. 

At planning stage, we agreed with the directors that we would report to them 
misstatements  identified  during  our  audit  above  £36,000  as  well  as 
misstatements below that amount that, in our view, warranted reporting for 
qualitative  reasons.  This  threshold  has  increased  to  £37,000  following  our 
revised materiality using net assets as at 31 December 2021. 

As part of designing our audit, we assessed the risk of material misstatement in the financial statements, whether due 
to fraud or error, and then designed and performed audit procedures responsive to those risks. In particular, we looked 
at where the directors made subjective judgements, such as assumptions on significant accounting estimates. 

We tailored the scope of our audit to ensure that we performed sufficient work to be able to give an opinion on the 
financial statements as a whole. We used the outputs of our risk assessment, our understanding of the Company, its 
environment, controls, and critical business processes, to consider qualitative factors to ensure that we obtained 
sufficient coverage across all financial statement line items. 

Other information 
The other information comprises the information included in the annual report other than the financial statements and 
our  auditor’s  report  thereon.  The  directors  are  responsible  for  the  other  information.  Our  opinion  on  the  financial 
statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we 
do not express any form of assurance conclusion thereon. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

57

2

Governance

Independent Auditor’s Report 
continued 

Our responsibility is to read the other information and, in doing so, consider whether the other information is materially 
inconsistent with the financial statements or our knowledge obtained in the course of audit or otherwise appears to be 
materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required 
to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the 
work we have performed, we conclude that there is a material misstatement of this other information, we are required 
to report that fact. 

We have nothing to report in this regard. 

Opinions on other matters prescribed by the Companies Act 2006 
In our opinion, the part of the directors’ remuneration report to be audited has been properly prepared in accordance 
with the Companies Act 2006. 

In our opinion, based on the work undertaken in the course of the audit: 

• the information given in the Strategic Report and the Directors’ Report for the financial year for which the financial 
statements  are  prepared  is  consistent  with  the  financial  statements  and  those  reports  have  been  prepared  in 
accordance with applicable legal requirements; 

• the information about internal control and risk management systems in relation to financial reporting processes and 
about share capital structures, given in compliance with rules 7.2.5 and 7.2.6 in the Disclosure Guidance and 
Transparency Rules sourcebook made by the Financial Conduct Authority (the FCA Rules), is consistent with the 
financial statements and has been prepared in accordance with applicable legal requirements; and 

• information  about  the  Company’s  corporate  governance  code  and  practices  and  about  its  administrative, 
management and supervisory bodies and their committees complies with rules 7.2.2, 7.2.3 and 7.2.7 of the FCA 
rules. 

Matters on which we are required to report by exception 
In light of the knowledge and understanding of the Company and its environment obtained in the course of the audit, 
we have not identified material misstatements in; 

• the Strategic Report or the Directors’ Report; or  

• the information about internal control and risk management systems in relation to financial reporting processes and 

about share capital structures, given in compliance with rules 7.2.5 and 7.2.6 of the FCA Rules. 

We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 requires us 
to report to you if, in our opinion: 

• adequate accounting records have not been kept by the Company, or returns adequate for our audit have not been 

received from branches not visited by us; or 

• the  Company  financial  statements  and  the  part  of  the  directors’  remuneration  report  to  be  audited  are  not  in 

agreement with the accounting records and returns; or 

• certain disclosures of directors’ remuneration specified by law are not made; or 

• we have not received all the information and explanations we require for our audit; or 

• a corporate governance statement has not been prepared by the Company.

58 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Corporate governance statement 
The Listing Rules require us to review the directors’ statement in relation to going concern, longer-term viability and 
that part of the Corporate Governance Statement relating to the Company’s compliance with the provisions of the 
UK Corporate Governance Code specified for our review. 

Based on the work undertaken as part of our audit, we have concluded that each of the following elements of the 
Corporate Governance Statement is materially consistent with the financial statements or our knowledge obtained 
during the audit: 

• Directors’ statement with regards the appropriateness of adopting the going concern basis of accounting and any 

material uncertainties identified set out on page 36; 

• Directors’ explanation as to its assessment of the entity’s prospects, the period this assessment covers and why the 

period is appropriate set out on page 28; 

• Directors’ statement on fair, balanced and understandable set out on page 40; 

• Board’s  confirmation  that  it  has  carried  out  a  robust  assessment  of  the  e-merging  and  principal  risks  set  out  on 

pages 25 to 27; 

• The section of the annual report that describes the review of effectiveness of risk management and internal control 

systems set out on page 48 and; 

• The section describing the work of the audit committee set out on pages 47 to 50. 

Responsibilities of Directors 
As explained more fully in the directors’ responsibilities statement set out on page 40, the directors are responsible for 
the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal 
control as the directors determine is necessary to enable the preparation of financial statements that are free from 
material misstatement, whether due to fraud or error. 

In preparing the financial statements, the directors are responsible for assessing the Company’s ability to continue as 
a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of 
accounting unless the directors either intend to liquidate the Company or to cease operations, or have no realistic 
alternative but to do so. 

Auditor’s responsibilities for the audit of the financial statements  
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from 
material  misstatement,  whether  due  to  fraud  or  error,  and  to  issue  an  auditor’s  report  that  includes  our  opinion. 
Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with 
ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and 
are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic 
decisions of users taken on the basis of these financial statements. 

The extent to which our procedures are capable of detecting irregularities, including fraud is detailed below. 

Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line 
with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

59

2

Governance

Independent Auditor’s Report 
continued 

Based on our understanding of the Company and its industry, we considered that non-compliance with the following 
laws and regulations might have a material effect on the financial statements: HMRC Investment Trust conditions. 

To help us identify instances of non-compliance with these laws and regulations, and in identifying and assessing the 
risks of material misstatement in respect to non-compliance, our procedures included but were not limited to:  

• At the planning stage of our audit, gaining an understanding of the legal and regulatory framework applicable to the 
Company and the industry in which it operates and considered the risk of acts by the Company which were contrary 
to the applicable laws and regulations;  

• Discussing with the directors and management the policies and procedures in place regarding compliance with laws 

and regulations;  

• Discussing amongst the engagement team the identified laws and regulations, and remaining alert to any indications 

of non-compliance; and 

• During the audit, focusing on areas of laws and regulations that could reasonably be expected to have a material 
effect on the financial statements from our general commercial and sector experience and through discussions with 
the  directors  (as  required  by  auditing  standards),  from  inspection  of  the  Company’s  regulatory  and  legal 
correspondence and review of minutes of directors’ meetings in the year we identified that the principal risks of 
non-compliance with laws and regulations related to breaches of regulatory requirements of the HMRC Investment 
Trust conditions. We also considered those other laws and regulations that have a direct impact on the preparation 
of financial statements, such as the Companies Act 2006 and UK tax legislation.  

We also considered those laws and regulations that have a direct effect on the preparation of the financial statements, 
such as the Companies Act 2006. 

In addition, we evaluated the directors' and management's incentives and opportunities for fraudulent manipulation of 
the financial statements, including the risk of management override of controls, and determined that the principal risks 
related to posting manual journal entries to manipulate financial performance, management bias through judgements 
and assumptions in significant accounting estimates, in particular in relation to unquoted investment valuation and 
significant one-off or unusual transactions. 

Our procedures in relation to fraud included but were not limited to: 

• Making enquiries of the directors and management on whether they had knowledge of any actual, suspected or 

alleged fraud; 

• Gaining an understanding of the internal controls established to mitigate risks related to fraud; 

• Discussing amongst the engagement team the risks of fraud such as opportunities for fraudulent manipulation of 
financial  statements,  and  determined  that  the  principal  risks  were  related  to  posting  manual  journal  entries  to 
manipulate financial performance, management bias through judgements and assumptions in significant accounting 
estimates, in particular in relation to investment valuations, and significant one-off or unusual transactions; and 

• Addressing the risks of fraud through management override of controls by performing journal entry testing. 

The primary responsibility for the prevention and detection of irregularities including fraud rests with both those charged 
with governance and management. As with any audit, there remained a risk of non-detection of irregularities, as these 
may involve collusion, forgery, intentional omissions, misrepresentations or the override of internal controls. 

60 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

The risks of material misstatement that had the greatest effect on our audit are discussed in the “Key audit matters” 
section of this report.  

A  further  description  of  our  responsibilities  is  available  on  the  Financial  Reporting  Council’s  website  at 
www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report. 

Other matters which we are required to address 
Following the recommendation of the audit committee, we were appointed by the Audit Committee on 25 November 
2021 to audit the financial statements for the year ending 31 December 2021 and subsequent financial periods. The 
period of total uninterrupted engagement is three years, covering the years ending 31 December 2019 to 31 December 
2021.  

The non-audit services prohibited by the FRC’s Ethical Standard were not provided to the Company and we remain 
independent of the Company in conducting our audit. 

Our audit opinion is consistent with the additional report to the audit committee. 

Use of the audit report 
This report is made solely to the Company’s members as a body in accordance with Chapter 3 of Part 16 of the 
Companies Act 2006. Our audit work has been undertaken so that we might state to the Company’s members those 
matters we are required to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted 
by law, we do not accept or assume responsibility to anyone other than the Company and the Company’s members 
as a body for our audit work, for this report, or for the opinions we have formed. 

Stephen Eames (Senior Statutory Auditor) for and on behalf of Mazars LLP 
Chartered Accountants and Statutory Auditor 
The Pinnacle 
160 Midsummer Boulevard 
Milton Keynes 
MK9 1FF 
20 April 2022

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

61

3

Financial Statements

Income Statement

Notes

Revenue
£’000

For the year ended
31 December 2021
Capital
£’000

Total
£’000

For the year ended  
31 December 2020 
Capital
£’000

Revenue
£’000

Total 
£’000 

Gains on investments held at fair value  
through profit or loss

Income from investments held at fair value  
through profit or loss

Management fees and  
performance fee provisions

Other expenses

Net return/(loss) before taxation

Taxation

Net return/(loss) after taxation

Return/(loss) per ordinary share  
– basic and diluted (pence)

8

2

3

4

5

6

–

21,124

21,124

–

13,803

13,803 

1,156

–

1,156

577

–

577 

(338)

(450)

368

(65)

303

(3,028)

(3,366)

–

(450)

18,096

18,464

–

(65)

18,096

18,399

(276)

(454)

(153)

(14)

(167)

(1,183)

(1,459) 

–

(454) 

12,620

12,467 

–

(14) 

12,620

12,453 

0.4

22.6

23.0               (0.2)

15.8            15.6 

The “Total” column of this statement is the Income Statement of the Company. The “Revenue” and “Capital” columns 
are supplementary to this and are prepared under guidance published by the AIC. 

All revenue and capital items in the above statement derive from continuing operations. 

The Company has no recognised gains and losses other than those shown above and therefore no separate Statement 
of Total Comprehensive Income has been presented. 

The accompanying notes on pages 66 to 80 are an integral part of these financial statements. 

62 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
Statement of Changes in Equity

For the year ended 31 December 2021 

                                                                                                     Ordinary 
                                                                                                          share 
                                                                                                        capital 
                                                                                     Notes            £’000 

Special
reserve
£’000 

At 31 December 2020                                                                           800

77,371

Net return after taxation                                                                             –

–

At 31 December 2021                                                                          800

77,371

 Capital
 reserve
 £’000

27,900

18,096

45,996

Revenue 
reserve 
 £’000 

61

303

364

 Total  
 £’000  

106,132 

18,399 

124,531 

For the year ended 31 December 2020 

                                                                                                     Ordinary 
                                                                                                          share 
                                                                                                        capital 
                                                                                     Notes            £’000 

Special
reserve
 £’000 

At 31 December 2019                                                                          800

77,371

Net return/(loss) after taxation                                                                   –

Dividends paid – revenue                                                      7                   –

–

–

 Capital
 reserve
 £’000

15,280

12,620

–

Revenue 
 reserve 
 £’000 

548

(167)

(320)

 Total  
 £’000  

93,999 

12,453 

(320) 

At 31 December 2020                                                                          800

77,371

27,900

61

106,132 

The accompanying notes on pages 66 to 80 are an integral part of these financial statements. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

63

 
 
3

Financial Statements

Statement of Financial Position

Fixed assets 

Investments

Current assets 

Debtors

Derivative financial instruments

Cash

Current liabilities 

Creditors

Derivative financial instruments

Net current assets

Non-current liabilities 

Performance fee provisions

Net assets

Capital and reserves 

Ordinary share capital

Special reserve

Capital reserve

Revenue reserve

Total shareholders’ funds

Net asset value per share – basic and diluted (pence)

Notes

8

 10 

9

 11 

9

12

 13

 18

 14

As at
31 December
2021
£’000

As at 
31 December 
2020 
 £’000 

125,615

103,035 

218

–

878

1,096

(404)

(99)

593

(1,677)

124,531

800

77,371

45,996

364

124,531

155.7

105 

1,930 

1,413 

3,448 

(351) 

– 

3,097 

– 

106,132 

800 

77,371 

27,900 

61 

106,132 

132.7 

The financial statements on pages 62 to 80 were approved by the Board of Directors and authorised for issue on 
20 April 2022 and were signed on its behalf by: 

Sir Ian Cheshire 
Chairman 

The accompanying notes on pages 66 to 80 are an integral part of these financial statements.  

Menhaden Resource Efficiency PLC – Company Registration Number 09242421 (Registered in England and Wales) 

64 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
 
 
 
Statement of Cash Flows

Net cash outflow from operating activities

Cash flows from investing activities 

Purchases of investments

Sales of investments

Settlement of derivatives

Net cash inflow/(outflow) from investing activities

Cash flows from financing activities 

Equity dividends paid

Net cash outflow from financing activities

Decrease in cash and cash equivalents

Cash and cash equivalents at start of the year

Cash and cash equivalents at the end of the year

For the
year ended
31 December
2021
£’000

For the 
year ended 
31 December 
2020 
 £’000 

(1,108)

(1,225) 

Notes

15

(20,492)

20,163

902

573

–

–

(535)

1,413

878

(26,096) 

13,071 

104 

(12,921) 

(320) 

(320) 

(14,466) 

15,879 

1,413 

The accompanying notes on pages 66 to 80 are an integral part of these financial statements. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

65

  
3

Financial Statements

Notes to the Financial Statements 
For the year ended 31 December 2021

1.

ACCOUNTING POLICIES 
The  principal  accounting  policies,  all  of  which  have  been  applied  consistently  throughout  the  year  in  the 
preparation of these financial statements, are set out below: 

(a) Basis of Preparation 
The financial statements have been prepared in accordance with United Kingdom company law, FRS 102 ‘The 
Financial  Reporting  Standard  applicable  in  the  UK  and  Ireland’,  the  Statement  of  Recommended  Practice 
‘Financial Statements of Investment Trust Companies and Venture Capital Trusts’ (the ‘SORP’), and the historical 
cost convention, as modified by the valuation of investments at fair value through profit or loss. The Board has 
considered a detailed assessment of the Company’s ability to meet its liabilities as they fall due, including stress 
and liquidity tests which modelled the effects of substantial falls in markets and significant reductions in market 
liquidity, on the Company’s financial position and cash flows. Further information on the assumptions used in 
the stress scenarios is provided in the Audit Committee report on page 49. The results of the tests showed that 
the Company would have sufficient cash, or the ability to liquidate a sufficient proportion of its listed holdings, to 
meet its liabilities as they fall due. Based on the information available to the Directors at the time of this report, 
including the results of the stress tests, the Company’s cash balances, and the liquidity of the Company’s listed 
investments, the Directors are satisfied that the Company has adequate financial resources to continue in 
operation for at least the next 12 months and that, accordingly, it is appropriate to adopt the going concern 
basis in preparing these financial statements. 

The Company’s financial statements are presented in sterling, being the functional and presentational currency 
of  the  Company.  All  values  are  rounded  to  the  nearest  thousand  pounds  (£’000)  except  where  otherwise 
indicated. 

Fair value measurements are categorised into a fair value hierarchy based on the degree to which the inputs to 
the fair value measurements are observable and the significance of the inputs to the fair value measurement in 
its entirety, which are described as follows: 

•

•

•

Level 1 – fair values measured using quoted prices (unadjusted) in active markets for identical assets or 
liabilities; 

Level 2 – fair values measured using valuation techniques for all inputs significant to the measurement other 
than quoted prices included within Level 1 that are observable for the asset or liability, either directly (i.e. as 
prices) or indirectly (i.e. derived from prices); 

Level 3 – fair values measured using valuation techniques for which any significant input to the valuation is 
not based on observable market data (unobservable inputs). 

Details in respect of the fair value of the Company's financial assets and liabilities are disclosed in note 17 to the 
Financial Statements.  

Presentation of the Income Statement 
In  order  to  reflect  better  the  activities  of  an  investment  trust  company  and  in  accordance  with  the  SORP, 
supplementary information which analyses the Income Statement between items of a revenue and capital nature 
has been presented alongside the Income Statement. The net revenue return is the measure the Directors believe 
appropriate in assessing the Company’s compliance with certain requirements set out in Sections 1158 and 
1159 of the Corporation Tax Act 2010. Refer to 1(e) for details on how expenses are allocated to revenue and 
capital.  

66 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

1.

ACCOUNTING POLICIES continued 
Critical Accounting Judgements and Key Sources of Estimation Uncertainty  
Critical  accounting  judgements  and  key  sources  of  estimation  uncertainty  used  in  preparing  the  financial 
information  are  continually  evaluated  and  are  based  on  historical  experience  and  other  factors,  including 
expectations of future events that are believed to be reasonable. The resulting estimates will, by definition, seldom 
equal the related actual results. 

The key estimates and assumptions that have a significant risk of causing a material adjustment to the carrying 
amounts  of  assets  and  liabilities  relate  to  the  valuation  of  the  Company’s  unquoted  (Level  3)  investments. 
£15,776,000 or 12.6% (2020: £13,380,000 or 13.0%) of the Company’s portfolio is comprised of unquoted 
investments. These are all valued in line with accounting policy 1(b) below. Under the accounting policy the 
reported net asset value or price of recent transactions methodologies have been adopted in valuing those 
investments, as set out on page 68. 

As the Company has judged that it is appropriate to use reported NAVs in valuing unquoted investments as set 
out in note 17 (vi), the Company does not have any key assumptions concerning the future, or other key sources 
of estimation uncertainty in the reporting period, which may have a significant risk of causing a material adjustment 
to the carrying amounts of assets and liabilities within the next financial year.  

Whilst  the  Board  considers  the  methodologies  and  assumptions  adopted  in  the  valuation  of  unquoted 
investments to be supportable, reasonable and robust, because of the inherent uncertainty of valuation, the 
values used may differ significantly from the values that would have been used had a ready market for the 
investment existed. These values may need to be revised as circumstances change and material adjustments 
may still arise as a result of a reappraisal of the unquoted investments’ fair value within the next year. 

In using a figure of 25% in the disclosures, set out on page 79, in relation to unquoted investments the Directors 
had regard to the nature of the investments, the wide range of possible outcomes, and public information on 
secondary market transactions in private equity funds. 

Segmental Analysis 
The Board is of the opinion that the Company is engaged in a single segment of business, namely investing in 
accordance with the Company’s Investment Objective, and consequently no segmental analysis is provided. 

(b) Investments Held at Fair Value Through Profit or Loss 
All investments are measured on initial recognition and at subsequent reporting dates at fair value in accordance 
with FRS 102 Section 11: Basic Financial Instruments and Section 12: Other Financial Instruments Issues. 

Purchases and sales of quoted investments are recognised on the trade date where a contract exists whose 
terms require delivery within a time frame determined by the relevant market. Purchases and sales of unlisted 
investments are recognised when the contract for acquisition or sale becomes unconditional. 

Changes  in  the  fair  value  of  investments  and  gains  and  losses  on  disposal  are  recognised  in  the  Income 
Statement as ‘gains or losses on investments’. The fair value of the different types of investment held by the 
Company is determined as follows: 

• Quoted Investments 

Fair value is deemed to be bid or last trade price depending on the convention of the exchange on which it 
is quoted. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

67

3

Financial Statements

Notes to the Financial Statements 
continued

1.

ACCOUNTING POLICIES continued 
(b) Investments Held at Fair Value Through Profit or Loss continued 
• Unquoted Investments 

Fair value is determined using recognised valuation methodologies in accordance with the International 
Private Equity and Venture Capital Association valuation guidelines (IPEVCA Guidelines**). 

Where an investment has been made recently, or there has been a transaction in an investment, the Company 
may use the transaction price as the best indicator of fair value. In such a case changes or events subsequent 
to the relevant transaction date would be assessed to ascertain if they imply a change in the investment’s fair 
value. 

The Company’s unquoted investments comprise of limited partnerships or other entities set up by third parties 
to invest in a wider range of investments, or to participate in a larger investment opportunity than would be 
feasible for an individual investor, and to share the costs and benefits of such investment. 

For these investments, in line with the IPEVCA Guidelines, and in the absence of transactions in the investments, 
the fair value estimate is based on the attributable proportion of the reported net asset value of the unquoted 
investment derived from the fair value of underlying investments. Valuation reports provided by the manager or 
general partner of the unquoted investments are used to calculate fair value where there is evidence that the 
valuation is derived using fair value principles that are consistent with the Company’s accounting policies and 
valuation methods. Such valuation reports may be adjusted to take account of changes or events to the reporting 
date, or other facts and circumstances which might impact the underlying value. 

If a decision to sell an unquoted investment or portion thereof has been made then the fair value would be the 
expected sales price where this is known or can be reliably estimated. 

Where a portion of an unquoted investment has been sold the level of any discount implicit in the sale price will 
be reviewed at each measurement date for that unquoted investment, taking account of the performance of the 
unquoted investment and any other factors relevant to the value of the unquoted investment. 

(c) Derivatives 
Derivatives comprise foreign currency forwards used to hedge the Company’s foreign currency exposure. The 
forwards comprise sterling receivable and a foreign currency deliverable. Derivatives are classified as financial 
assets or financial liabilities at fair value through profit or loss. Gains or losses are recognised as capital income 
or expense in the Income Statement. The fair value of the forwards is the receivable ‘leg’ less the deliverable 
‘leg’ translated at the exchange rate at the date of the Statement of Financial Position. 

(d) Investment Income 
Dividends receivable are recognised on the ex-dividend date. Where no ex-dividend date is quoted, dividends 
are recognised when the Company’s right to receive payment is established. UK dividends are shown net of tax 
credits and foreign dividends are gross of the appropriate rate of withholding tax. 

Fixed returns on non-equity shares and debt securities are recognised on a time apportionment basis so as to 
reflect the effective yield when it is probable that economic benefit will flow to the Company. Where income 
accruals previously recognised, but not received, are no longer considered to be reasonably expected to be 
received, due to doubt over their receipt, then these amounts are reversed through expenses. 

Income distributions from limited partnership funds are recognised when the right to the distribution is established. 

68 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

1.

ACCOUNTING POLICIES continued 

(e) Expenses 
All expenses are accounted for on an accruals basis. Expenses are charged through the revenue column of the 
Income Statement except as follows: 

•

•

expenses which are incidental to the acquisition or disposal of an investment are charged to the capital 
column of the Income Statement; and 

expenses  are  charged  to  the  capital  column  of  the  Income  Statement  where  a  connection  with  the 
maintenance or enhancement of the value of the investments can be demonstrated. In this respect the 
portfolio management and AIFM fees have been charged to the Income Statement in line with the Board’s 
expected long-term split of returns, in the form of capital gains and income, from the Company’s portfolio. 
As a result 20% of the portfolio management and AIFM fees are charged to the revenue column of the Income 
Statement and 80% are charged to the capital column of the Income Statement. 

Any performance fee accrued or paid is charged in full to the capital column of the Income Statement. 

(f) Taxation 
The tax effect of different items of expenditure is allocated between capital and revenue using the marginal basis. 
Deferred taxation is provided on all timing differences that have originated but not been reversed by the Statement 
of Financial Position date other than those differences regarded as permanent. This is subject to deferred tax 
assets only being recognised if it is considered more likely than not that there will be suitable profits from which 
the reversal of timing differences can be deducted. Any liability to deferred tax is provided for at the rate of tax 
enacted or substantively enacted. 

(g) Foreign Currency 
Transactions recorded in overseas currencies during the year are translated into sterling at the exchange rate 
ruling on the date of the transaction. Assets and liabilities denominated in overseas currencies are translated into 
sterling at the exchange rates ruling at the date of the Statement of Financial Position. 

Any gains or losses on the translation of foreign currency balances, whether realised or unrealised, are taken to 
the capital or the revenue column of the Income Statement, depending on whether the gain or loss is of a capital 
or revenue nature. 

(h) Cash and Cash Equivalents 
Cash and cash equivalents are defined as cash and demand deposits readily convertible to known amounts of 
cash and subject to insignificant risk of changes in value. 

(i) Share Capital 
Ordinary shares issued by the Company are recognised at the proceeds or fair value received with the excess 
of the amount received over nominal value being credited to the share premium account. Direct issue costs net 
of tax are deducted from equity. 

(j) Capital Reserves 
The following are transferred to this reserve: gains and losses on the realisation of investments; changes in the 
fair  values  of  investments;  and  expenses,  together  with  the  related  taxation  effect,  charged  to  capital  in 
accordance with the Company's accounting policy on expenses in 1(e). 

Any gains in the fair value of investments that are not readily convertible to cash are treated as unrealised gains 
in the capital reserve. The amounts within capital reserve less unrealised gains are available for distribution.  

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

69

3

Financial Statements

Notes to the Financial Statements 
continued

1.

ACCOUNTING POLICIES continued 

(k) Special Reserve 
The special reserve arose following court approval in 2016 to cancel the share premium account. This reserve 
is distributable and can be used to fund share repurchases. 

(l) Revenue Reserve 
The revenue reserve represents the surplus of accumulated revenue profits being the excess of income derived 
from holding investments less the costs associated with running the Company. This reserve may be distributed 
by way of dividends, when positive. 

2.

INCOME FROM INVESTMENTS HELD AT FAIR VALUE THROUGH PROFIT OR LOSS 

Income from investments 

Unquoted distributions

Dividends from quoted investments

3.

AIFM AND PORTFOLIO MANAGEMENT FEES 

AIFM fee

Portfolio management fee

Performance fee provisions

4.

OTHER EXPENSES 

Revenue
£’000

Capital
£’000

52

 286

–

338 

208

1,143

1,677

3,028

Revenue
£’000

Capital
£’000

Directors’ remuneration

Employers NIC on directors’ remuneration

Auditor’s remuneration for the audit of  
    the Company’s financial statements  

Registrar fee

Broker retainer

Legal and professional costs

Custody fees

Other costs

Total expenses

176 

18 

44

17

30

10

47

108

450

–

–

–

–

–

–

–

–

–

2021
Total
£’000

260

1,429

1,677

3,366

2021
Total
£’000

176

18

44

17

30

10

47

108

450

2021
£’000

550

606

1,156

Revenue
£’000

Capital
£’000

 42 

234 

–

276 

 168 

 936 

79

2020 
£’000 

90 

487 

577 

2020 
Total 
£’000 

210 

 1,170 

79 

1,183

1,459 

Revenue
£’000

Capital
£’000

171 

18 

41

17

30

8

46

123

454

–

–

–

–

–

–

–

–

–

2020 
Total 
£’000 

171  

18  

41 

17 

30 

8 

46 

123 

454 

The Company has no employees and details of the amounts paid to Directors are included in the Directors’ 
Remuneration Report beginning on page 51.

70 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
5.

TAXATION ON NET RETURN 

(a) Analysis of charge in period 

UK corporation tax 

Overseas taxation

Revenue
£’000

Capital
£’000

2021
Total
£’000

Revenue
£’000

Capital
£’000

2020 
Total 
£’000 

65 

–

65

14 

–

 14  

(b) Factors affecting current tax charge for the year 
Approved investment trusts are exempt from tax on capital gains made within the Company. 

The  tax  charged  for  the  period  is  lower  than  the  standard  rate  of  corporation  tax  in  the  UK  of  19.0% 
(2020: 19.0%). The difference is explained below. 

Net return/(loss) before taxation

Corporation tax at 19.0% (2020: 19.0%)

Non-taxable gains on investments held  
    at fair value through profit or loss

Overseas withholding taxation

Non-taxable overseas dividends

Excess management expenses*

Current tax charge for the year

Revenue
£’000

368

70

–

65 

(220)

150

65

Capital
£’000

18,096

3,438

2021
Total
£’000

18,464

3,508

(4,013)

(4,013)

–

–

575

–

65

(220)

725

65

Revenue
£’000

(153)

(29)

–

14 

(110)

139

14 

Capital
£’000

12,620

2,398

2020 
Total 
£’000 

12,467 

2,369 

(2,623)

(2,623) 

–

– 

225

–

 14 

(110) 

364 

 14  

*Excess management expenses are expenses that are not relieved in full against income generated by the Company. 

(c) Provision for deferred tax 
No provision for deferred taxation has been made in the current period. The Company has not provided for 
deferred tax on capital profits and losses arising on the revaluation or disposal of investments, as it is exempt 
from tax on these items because of its status as an investment trust company. 

The UK Government announced in the 2021 budget that from 1 April 2023, the rate of corporation tax in the 
United Kingdom will increase from 19% to 25%. Companies with profits of £50,000 or less will continue to be 
taxed at 19%, which is a new small profits rate. Where taxable profits are between £50,000 and £250,000, the 
higher 25% rate will apply but with a marginal relief applying as profits increase. The Company has not recognised 
a deferred tax asset of £2,950,000 (25% tax rate) (2020: £1,527,000,  19% tax rate) as a result of excess 
management expenses. It is not anticipated that these excess expenses will be utilised in the foreseeable future. 

6.

RETURN/(LOSS) PER SHARE  
The  capital,  revenue  and  total  return  per  ordinary  share  are  based  on  the  net  return/(loss)  shown  in  the 
Income  Statement  on  page  62  and  the  weighted  average  number  of  ordinary  shares  in  issue  80,000,001 
(2020: 80,000,001). 

There are no dilutive instruments issued by the Company. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

71

 
 
 
3

Financial Statements

Notes to the Financial Statements 
continued

7.

DIVIDENDS PAID 
Under UK GAAP, final dividends are not recognised until they are approved by shareholders and interim dividends 
are not recognised until they are paid. They are also debited directly from reserves. Amounts recognised as 
distributable in these financial statements were as follows: 

2019 interim dividend of 0.4p per share

2021
£’000

–

2020 
£’000 

320 

In respect of the year ended 31 December 2021, a final dividend of 0.2p per share or £160,000 in total has been 
recommended to shareholders and, if the resolution is passed at the AGM, will be reflected in the Annual Report 
for the year ending 31 December 2022. Details of the ex-dividend and payment dates are shown on page 7. 

The Board’s current policy is to only pay dividends out of revenue reserves, if the need arises in order to maintain 
investment trust status. The amount of revenue reserves available for distribution as at 31 December 2021 is 
£364,000 (2020: £61,000). The Company generated a revenue profit in the year ended 31 December 2021 of 
£303,000 (2020: £167,000 loss). 

8.

INVESTMENTS 

                                                                                                      2021                                                             2020 
                                                                                 Quoted       Unquoted                                  Quoted       Unquoted 
                                                                          Investments     Investments               Total     Investments     Investments               Total 
                                                                                    £’000              £’000              £’000              £’000              £’000              £’000 

Opening balance 

Cost at 1 January                                           60,672          18,758          79,430          38,258          22,922          61,180 

Investment holdings gains at 1 January            22,963               642          23,605          11,302            4,365          15,667 

Valuation at 1 January                                  83,635          19,400        103,035          49,560          27,287          76,847 

Movement in the year: 

Purchases at cost                                           15,503            4,989          20,492          25,537               559          26,096 

Sales – proceeds received                             (11,579)          (9,486)        (21,065)          (3,903)          (9,272)        (13,175) 

Net movement in investment  
holdings gains/(losses)                                   22,280               873          23,153          12,441               826          13,267 

Valuation at 31 December                            109,839          15,776        125,615          83,635          19,400        103,035 

Closing balance 

Cost at 31 December                                      68,965          17,901          86,866          60,672          18,758          79,430 

Investment holding gains/(losses)  
at 31 December                                              40,874           (2,125)         38,749          22,963               642          23,605 

Valuation at 31 December                            109,839          15,776        125,615          83,635          19,400        103,035 

The Company received £21,065,000 (2020: £13,175,000) from investments sold in the year. The book cost of 
these investments was £13,056,000 (2020: £7,846,000). These investments have been revalued over time and 
until they were sold any unrealised gains/losses were included in the fair value of the investments.

72 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
 
 
8.

INVESTMENTS continued 

Gains on investments 

Net movement in investment holding gains in the year

Net movement in derivative holding (losses)/gains in the year

Gains on investments

2021
£’000

23,153

(2,029)

21,124

2020 
£’000 

13,267 

536 

13,803 

Total unrealised gains, including transfers, during the year were £15,144,000 (2020: £7,937,000).  

Purchase transaction costs were £28,000 (2020: £17,000). These comprise mainly commission and stamp duty. 

Sales transaction costs were £5,000 (2020: £2,000). These comprise mainly commission. 

9.

DERIVATIVES 

Fair value of FX forwards

2021
£’000

(99)

2020 
£’000 

1,930 

FX forwards are currently used to hedge the Company’s exposure to the euro and US dollar. See note 17(ii) for 
further details. The Company received £902,000 (2020: received £104,000) on FX forwards closed during the 
year. The FX forwards are revalued over time and any gains/losses (both realised and unrealised) are included in 
gains/(losses) on investments in the capital column of the Income Statement. 

10. DEBTORS 

VAT recoverable

Withholding tax recoverable

Prepayments and accrued income

11. CREDITORS 

Performance fees 

Other creditors and accruals

The performance fee mechanism is explained on page 23. 

2021
£’000

2

49

167

218

2021
£’000

–

404

404

2020 
£’000 

8 

70 

27 

105 

2020 
£’000 

79 

272 

351 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

73

 
 
 
 
3

Financial Statements

Notes to the Financial Statements 
continued

12. PERFORMANCE FEE PROVISIONS 

Performance fee provisions are recognised when a present obligation arises from past events, it is probable that 
the obligation will materialise and it is possible for a reliable estimate to be made, but the timing of settlement or 
the exact amount is uncertain. 

The Company has provided for the performance fee obligation to its Portfolio Manager that has arisen in the 
reporting period, being the first year of the three-year performance period that commenced on 1 January 2021. 
This amounted to £1,677,000 in performance fee provisions as at 31 December 2021 (2020: payable of £79,000 
as disclosed in note 11 above). The amount provided is the Directors’ best estimate of the obligation based on 
the NAV as at 31 December 2021 and has been charged to the capital column of the Income Statement. If 
crystalised, settlement of performance fee provisions will take place following approval of the annual results for 
the year ended 31 December 2023, during financial year 2024. Incremental changes to the provision will be 
recognised in each subsequent period until crystallisation.  

Full details of the performance fee arrangement can be found in the Performance Fee section in the Strategic 
Report. 

13. SHARE CAPITAL 

Issued and fully paid: 

80,000,001 ordinary shares of 1p per share

2021
£’000

2020 
£’000 

800

800 

There is a single class of ordinary shares. The voting rights of the ordinary shares on a poll are one vote for each 
share held. There are no: 

restrictions on transfer of, or in respect of the voting or dividend rights of, the Company’s ordinary shares; 

agreements, known to the Company, between holders of securities regarding the transfer of ordinary shares; 

•

•

or 

•

special rights with regard to control of the Company attaching to the ordinary shares 

14. NET ASSET VALUE PER SHARE 

Net asset value per share

2021

155.7p

2020 

132.7p 

The net asset value per share is based on the assets attributable to equity shareholders of  £124,531,000 
(2020: £106,132,000) and on the number of ordinary shares in issue at the year end of 80,000,001. 

There are no dilutive instruments issued by the Company. 

74 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
15. RECONCILIATION OF NET CASH OUTFLOW FROM OPERATING ACTIVITIES 

Gains before finance costs and taxation

Gains made on investments

Increase in other debtors

Increase in creditors, accruals and performance fee provisions

Net taxation suffered on investment income

Net cash outflow from operating activities

16. RELATED PARTIES 

The following are considered to be related parties: 

•

•

Frostrow Capital LLP 

The Directors of the Company 

2021
£’000

18,464

(21,124)

(2,660)

(134)

1,730

(44)

(1,108)

2020 
£’000 

12,467 

(13,803) 

(1,336) 

(5) 

123 

(7) 

(1,225) 

Details of the relationship between the Company and the Company’s AIFM are disclosed in the Strategic Report 
on page 23. Details of fees paid to Frostrow by the Company can be found in note 3 on page 70. All material 
related party transactions have been disclosed in note 3 on page 70. Details of the remuneration of the Directors 
can be found in note 4 and in the Directors’ Remuneration Report starting on page 51. Details of the Directors’ 
interests in the capital of the Company can be found on page 51. 

The balance outstanding to Frostrow at the year end was £23,000 (2020: £20,000). No balances were due to 
the Directors (2020: nil). 

17.

FINANCIAL INSTRUMENTS 
Risk management policies and procedures 
The Company’s financial instruments comprise securities and other investments, cash balances and certain 
debtors and creditors that arise directly from its operations. 

As an investment trust, the Company invests in equities and other investments for the long term so as to achieve 
its Investment Objective as stated on page 8. In pursuing its Investment Objective, the Company is exposed to 
a variety of risks that could result in a reduction in the Company’s net assets. 

The main risks that the Company faces arising from its use of financial instruments are: 

(i) market risk (including foreign currency risk, interest rate risk and other price risk) 

(ii)

liquidity risk 

(iii) credit risk 

These risks, with the exception of liquidity risk, and the Directors’ approach to the management of them, are set 
out in the Strategic Report on pages 25 to 27. The AIFM, in close co-operation with the Board and the Portfolio 
Manager, co-ordinates the Company’s risk management. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

75

 
3

Financial Statements

Notes to the Financial Statements 
continued

17.

FINANCIAL INSTRUMENTS continued 
(i) Other price risk 
In pursuance of the Investment Objective, the Company’s portfolio is exposed to the risk of fluctuations in market 
prices and foreign exchange rates. 

The Board manages these risks through the use of investment limits and guidelines as set out on pages 8 and 9, 
and monitors the risks through monthly compliance reports from Frostrow, with reports from Frostrow and the 
Portfolio Manager also presented at each Board meeting. In addition, Frostrow monitors the exposure of the 
Company and compliance with the investment limits and guidelines on a daily basis. 

Other price risk sensitivity 
Other price risk may affect the value of the quoted investments. 

If market prices at the date of the Statement of Financial Position had been 25% higher or lower while all other 
variables  had  remained  constant:  the  revenue  return  would  have  decreased/increased  by  £66,000  (2020: 
£62,000); the capital return would have increased/decreased by £24,450,000 (2020: £18,571,000); and, the 
return on equity would have increased/decreased by £24,384,000 (2020: £18,509,000). The calculations are 
based on the portfolio as at the respective dates of the Statement of Financial Position and are not representative 
of the year as a whole. 

(ii) Foreign currency risk 
A significant proportion of the Company’s portfolio positions are denominated in currencies other than sterling 
(the Company’s functional currency, and the currency in which it reports its results). As a result, movements in 
exchange rates can significantly affect the sterling value of those items. 

Foreign currency risk is monitored in conjunction with other price risk as described above. The Portfolio Manager 
uses foreign currency forwards to hedge the foreign currency risk. Currently, approximately two thirds of the 
Company’s euro and US dollar exposures are hedged. 

Foreign currency exposure 
The fair values of the Company’s assets and liabilities that are denominated in foreign currencies are shown 
below: 

                                                                                                       2021                                                                                2020 
                                                                                                            Current                                                                                 Current
                                                      Investments      Derivatives*            assets                  Net    Investments      Derivatives             assets
                                                                 £’000              £’000              £’000              £’000              £’000              £’000              £’000

Net 
£’000 

U.S. dollar                            102,158      (48,015)                1       54,144       77,148      (39,860)               2 

37,290 

Euro                                        15,806        (8,400)              49         7,455       16,584        (8,956)             70 

7,698 

Other                                               –                –              38              38                –                –              31 

 31 

                                            117,964     (56,415)              88       61,637       93,732      (48,816)           103 

(45,019) 

*Derivatives comprise foreign currency forwards used to partially hedge the Company’s exposure to overseas currencies. 

76 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
 
17.

FINANCIAL INSTRUMENTS continued 
Foreign currency sensitivity 
The following table details the sensitivity of the Company’s net return for the year and shareholders’ funds to a 
10% increase and decrease in sterling against the relevant currency. 

These percentages have been determined based on market volatility in exchange rates over the period since 
launch.  The  sensitivity  analysis  is  based  on  the  Company’s  significant  foreign  currency  exposures  at  each 
Statement of Financial Position date. 

USD
£’000

6,016

(4,922)

2021
EUR
£’000

828

(678)

Other
£’000

4

(3)

USD
£’000

4,143

(3,390)

2020 
EUR
£’000

 855 

(700)

Other 
£’000 

 3 

(3) 

Sterling depreciates

Sterling appreciates

(iii) Interest rate risk 
Interest rate changes may affect: 

–

–

the level of income receivable from floating and fixed rate securities and cash at bank and on deposit; and 

the fair value of investments in fixed interest securities. 

Interest rate exposure 
The exposure of financial assets and liabilities to fixed and floating interest rates, is shown below. 

Cash

2021

2020 

Fixed
rate
£’000

–

–

Floating
rate
£’000

878

878

Fixed
rate
£’000

–

–

Floating 
rate 
£’000 

1,413 

1,413 

Interest rate sensitivity 
If interest rates had been 1% higher or lower and all other variables were held constant, the Company’s net return 
for the year ended 31 December 2021 and the net assets would increase/decrease by £9,000 (2020: £14,000). 

(iv) Liquidity risk 
This is the risk that the Company will encounter difficulty in meeting obligations associated with financial liabilities. 

The  main  liquidity  requirements  the  Company  may  face  are  its  commitments  to  the  investments  in  limited 
partnership funds, as set out in note 19 on page 80. These commitments can be drawn down on 3 or 10 days 
notice. Having reviewed the nature of the investment and the track record of the underlying mandate for the 
most significant commitment, to TCI Real Estate Fund III Limited, the Board consider that it will be drawn down 
gradually over the life of the investment and as such poses a low risk to the liquidity of the Company. Frostrow 
and/or the Portfolio Manager are in regular contact with the managers of the limited partnership funds, as a part 
of which they would be made aware of, and plan accordingly for any drawdowns under those commitments. 

The Company’s assets comprise quoted securities (equity shares, fixed income and fund investments), cash, 
and unquoted limited partnership funds and investments. Whilst the unquoted investments are illiquid, short-
term flexibility is achieved through the quoted securities, which are liquid, and cash which is available on demand. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

77

 
 
3

Financial Statements

Notes to the Financial Statements 
continued

17.

FINANCIAL INSTRUMENTS continued 
(iv) Liquidity risk (continued) 
The liquidity of the quoted securities is monitored on at least a monthly basis to ensure that there is sufficient 
liquidity to meet the company’s liabilities and any forthcoming drawdowns. 

(v) Credit risk 
Credit risk is the risk of failure of a counterparty to discharge its obligations resulting in the Company suffering a 
financial loss. The quoted debt investments are managed as part of an investment portfolio, and their credit risk 
is considered in the context of their overall investment risk. 

Credit risk exposure 

Derivative financial instruments

Current assets: 

Other receivables (amounts due from brokers, dividends and interest receivable)

Cash 

2021
£’000

224

218

878

2020 
£’000 

1,930 

105 

1,413 

(vi) Hierarchy of investments 
The Company’s investments are valued within a fair value hierarchy that reflects the significance of the inputs 
used in making the fair value measurements as described in the accounting policies beginning on page 66. 

At 31 December 2021

Investments

Derivatives

At 31 December 2020

Investments

Derivatives

Level 3 investments at 31 December 2021 
                                                                            Cost
                                                                             ’000

Value 
£’000

Helios Co-Invest LP1                                   US$6,084

10,174

KKR Aqueduct Co-Invest LP2                          £4,000

TCI Real Estate Partners Fund III Ltd          US$2,169

WCP Growth Fund LP                                      £7,447

4,000

1,602

–

1 Described as X-ELIO in the portfolio statement  
2 Described as John Laing in the portfolio statement  

Level 1
£’000

109,839

Level 2
£’000

Level 3
£’000

Total 
£’000 

–

15,776

125,615 

–

(99)

–

(99) 

Level 1
£’000

89,655

Level 2
£’000

Level 3
£’000

Total 
£’000 

–

13,380

103,035 

–

1,930

–

1,930 

Ownership

4.73%

Valuation basis 

NAV 

1.23% 

Price of recent transactions 

1.18%

NAV 

10.30% 

Discount to adjusted NAV 

78 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

  
 
 
 
17.

FINANCIAL INSTRUMENTS continued 
Level 3 investments at 31 December 2020 
                                                                            Cost
                                                                             ’000

Value 
£’000

Ownership

Valuation basis 

Helios Co-Invest LP1                                   US$7,484

11,120

4.73% 

NAV 

WCP Growth Fund LP                                      £7,447

TCI Real Estate Partners Fund III Ltd          US$2,713

26

2,235

10.30% 

Discount to adjusted NAV 

1.18%

NAV 

1 Described as X-ELIO in the portfolio statement  

During the year, the Company realised a gain of £996,000 on Helios Co-Invest LP after receiving a distribution 
of £2,034,000, which followed the disposal of a portfolio of X-ELIO’s operating assets in Spain (2020: the 
Company realised a gain of £1,267,000 after receiving a £5,017,000 distribution from Helios Co-Invest LP, 
following the sale of its 30% stake in X-ELIO). Helios Co-Invest LP remained the largest unquoted investment of 
the Company as at 31 December 2021. 

In  December  2021,  the  Company  completed  a  new  co-investment  with  KKR  in  John  Laing  with  an  initial 
investment of £4 million. It is expected that the development pipeline of infrastructure assets developed by John 
Laing will provide the Company with opportunities to commit additional capital over time.  

The fair value WCP Growth Fund LP was written down by £26,000 during the year (2020: £416,000). 

If a 25% discount to NAV was applied to the NAV of the level 3 investments as at 31 December 2021, or the 
discount  already  applied  was  increased  by  25%,  the  impact  would  have  been  a  decrease  of  £3,512,000 
(2020: £3,217,000) in net assets and the net return for the year. 

(vii) Capital management policies and procedures 
The Company’s capital management objectives are to ensure that it will be able to continue as a going concern 
and to maximise the income and capital return to its equity shareholders through an appropriate level of gearing. 

The Board’s policy is to limit gearing to a maximum of 20% of the Company’s net assets. Currently the Company 
does not have any gearing and there are no facilities in place. 

The capital structure of the Company comprises the equity share capital (ordinary shares), retained earnings and 
other reserves as disclosed on the Statement of Financial Position on page 64. 

The Board, with the assistance of the AIFM and the Portfolio Manager, monitors and reviews the broad structure 
of the Company’s capital on an ongoing basis. This includes a review of: 

–

the planned level of gearing, which takes into account the Portfolio Manager’s view of the market; 

– whether to buy back equity shares, either for cancellation or to hold in treasury, in light of any share price 

discount to net asset value per share; 

– whether to issue new equity shares; and, 

–

the extent to which revenue in excess of that required for distributions should be retained. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

79

3

Financial Statements

Notes to the Financial Statements 
continued

18. CAPITAL RESERVE 

2021
Capital Reserves

2020 
Capital Reserves 

At 1 January

Net gains on investments

Investment 
 Holding 
Gains
£’000

25,534

13,115

Other

£’000

2,366

8,009

Total
£’000

27,900

21,124

Expenses charged to capital

(3,028)

–

(3,028)

Investment 
Holding 
 (Losses)  
/Gains
£’000

Other
£’000

Total 
£’000 

(1,780) 

 17,060 

 15,280 

5,329

(1,183)

8,474

13,803 

–

(1,183) 

At 31 December

7,347

38,649

45,996

2,366 

25,534

27,900 

Sums within the Total Capital Reserve less unrealised gains (those on investments not readily convertible to cash) 
are available for distribution. In addition, the Revenue Reserve is available for distribution. 

19.

FINANCIAL COMMITMENT 
The Company has made commitments to provide additional funds to the following investments: 

   WCP Growth Fund LP

  Helios Co-Invest LP

Sterling
Commitment

£52,000

£46,000

Local currency
Commitment

Notice of 
drawdown 

–

10 business days 

US$62,000

3 business days 

  TCI Real Estate Partners Fund III Limited

£3,140,000

US$4,253,000

10 business days 

20.

THE COMPANY 
The Company is a public limited company (PLC) incorporated in England and Wales. Its principal activity is that 
of an investment trust company within the meaning of sections 1158/1159 of the Corporation Tax Act 2010 and 
its registered office and principal place of business is 25 Southampton Buildings, London, WC2A 1AL. The 
Company’s  name  changed  from  Menhaden  PLC  to  Menhaden  Resource  Efficiency  PLC  with  effect  from 
23 June 2021. 

80 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

 
Shareholder Information 

Financial Calendar 
31 December

Financial Year End 

March/April

Final Results Announced 

June

30 June

Annual General Meeting, Dividend Payable (if any) 

Half Year End 

September

Half Year Results Announced 

Annual General Meeting 
The Annual General Meeting of Menhaden Resource Efficiency PLC will be held at the offices of Frostrow Capital LLP, 
25 Southampton Buildings, London WC2A 1AL on 22 June 2022 at 12 noon. 

Share Prices 
The Company’s ordinary shares are listed on the London Stock Exchange under ‘Investment Companies’. The price is 
given daily in the Financial Times and other newspapers. 

Change of Address 
Communications with shareholders are mailed to the address held on the share register. In the event of a change of 
address or other amendment this should be notified to the Company’s Registrar, Link Group, under the signature of 
the registered holder. 

Net Asset Value 
The net asset value of the Company’s shares can be obtained on the Company’s website at www.menhaden.com and 
is published daily via the London Stock Exchange. 

Profile of the Company’s Ownership 
% of ordinary shares held at: 

31 December 2021

31 December 2020 

13.0%

10.2%

34.0%

33.1%

29.5%

43.5%

Family Offices

Wealth Managers & Private Banks

Family Offices

Wealth Managers & Private Banks

19.9%

16.8%

Institutions

Retail Platforms

Institutions

Retail Platforms

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

81

4

Further Information

Glossary

Alternative Investment Fund Managers Regulations (“UK AIFMD”) 
Agreed by the European Parliament and the Council of the European Union and transposed into UK legislation, the UK 
AIFMD classifies certain investment vehicles, including investment companies, as Alternative Investment Funds (“AIFs”) 
and requires them to appoint an Alternative Investment Fund Manager (“AIFM”) and depositary to manage and 
oversee  the  operations  of  the  investment  vehicle.  The  Board  of  the  Company  retains  responsibility  for  strategy, 
operations and compliance and the Directors retain a fiduciary duty to shareholders. 

Compounding Hurdle 
The payment of a performance fee is conditional on the Company’s NAV being above the high watermark and the 
return on the gross proceeds from the IPO of the Company exceeding an annualised compound return of 5%. 

Discount or Premium 
A description of the difference between the share price and the net asset value per share. The size of the discount or 
premium is calculated by subtracting the share price from the net asset value per share and is usually expressed as a 
percentage (%) of the net asset value per share. If the share price is higher than the net asset value per share the result 
is a premium. If the share price is lower than the net asset value per share, the shares are trading at a discount. 

Gearing 
In simple terms gearing is borrowing. An investment trust can borrow money to invest in additional investments for its 
portfolio.  The  effect  of  the  borrowing  on  shareholders’  funds  is  called  ‘gearing’.  If  the  Company’s  assets  grow, 
shareholders’ funds grow proportionately more because the debt remains the same. But if the value of the Company’s 
assets falls, the situation is reversed. Gearing can therefore enhance performance in rising markets but can adversely 
impact performance in falling markets. 

Gearing represents borrowings at par less cash and cash equivalents expressed as a percentage of shareholders’ 
funds. Potential gearing is the company’s borrowings expressed as a percentage of shareholders’ funds. 

High Watermark 
The high watermark is the highest net asset value that the Company has reached on which a performance fee has 
been paid. Its initial level was set at 100p on the launch of the Company. 

Leverage 
For the purposes of the UK AIFMD, leverage is any method which increases the Company’s exposure, including the 
borrowing of cash and the use of derivatives. It is expressed as a ratio between the Company’s exposure and its net 
asset  value  and  can  be  calculated  using  gross  and  commitment  methods.  Under  the  gross  method,  exposure 
represents the sum of the Company’s positions after the deduction of sterling cash balances, without taking into account 
any hedging and netting arrangements. Under the commitment method, exposure is calculated without the deduction 
of sterling cash balances and after certain hedging and netting positions (as detailed in the UK AIFMD) are offset against 
each other. 

Net Asset Value (“NAV”) 
The value of the Company’s assets, principally investments made in other companies and cash being held, minus any 
liabilities. The NAV per share is also described as ‘shareholders’ funds’ per share. The NAV is often expressed in pence 
per share after being divided by the number of shares in issue. The NAV per share is unlikely to be the same as the 
share price which is the price at which the Company’s shares can be bought or sold by an investor. The share price is 
determined principally by the relationship between the demand for and supply of the shares. 

82 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

NAV Total Return (APM) 
The theoretical total return on shareholders’ funds per share, reflecting the change in NAV assuming that any dividends 
paid to shareholders were reinvested at NAV at the time the shares were quoted ex-dividend. A way of measuring 
investment management performance of investment trusts which is not affected by movements in the share price. 

                                                                                                                                                                            31 December          31 December 
                                                                                                                                                                                         2021                       2020 

Opening NAV                                                                                                                                                                  132.7p                    117.5p 
Increase in NAV                                                                                                                                                                 23.0p                      15.2p 
Closing NAV                                                                                                                                                                   155.7p                    132.7p 
% increase in NAV                                                                                                                                                           17.3%                     12.9% 
Impact of dividend reinvested                                                                                                                                                   –                       0.3% 
NAV total return                                                                                                                                                               17.3%                     13.2% 

Share Price Total Return (APM) 
The return to the investor, on a last traded price to a last traded price basis, assuming that all dividends paid were 
reinvested, without transaction costs, into the shares of the Company at the time the shares were quoted ex-dividend. 

                                                                                                                                                                            31 December          31 December 
                                                                                                                                                                                         2021                       2020 

Opening share price                                                                                                                                                         99.0p                      96.5p 
Increase in share price                                                                                                                                                      13.0p                        2.5p 
Closing share price                                                                                                                                                         112.0p                      99.0p 
% increase in share price                                                                                                                                                 13.1%                       2.6% 
Impact of dividend reinvested                                                                                                                                                   –                       0.4% 
Share price total return                                                                                                                                                    13.1%                       3.0% 

Ongoing Charges (APM) 
Ongoing charges are calculated by taking the Company’s annualised operating expenses and expressing them as a 
percentage  of  the  average  daily  net  asset  value  of  the  Company  over  the  year.  The  costs  of  buying  and  selling 
investments are excluded, as are interest costs, taxation, costs of buying back or issuing shares and other non-recurring 
costs.  These  items  are  excluded  because  if  included,  they  could  distort  the  understanding  of  the  Company’s 
performance for the year and the comparability between periods. 

                                                                                                                                                                            31 December          31 December 
                                                                                                                                                                                         2021                       2020 
                                                                                                                                                                                        £’000                      £’000 

Total Expenses                                                                                                                                                                 2,138                      1,913 

Average NAVs                                                                                                                                                               117,721                    93,724 

Ongoing charge ratio                                                                                                                                                         1.8%                       2.0% 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

83

 
 
 
 
 
 
4

Further Information

How to Invest 

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

Investment Platforms 
The Company’s shares are traded openly on the London Stock Exchange and can be purchased through a stock-broker 
or other financial intermediary. The shares are available through savings plans (including Investment Dealing Accounts, 
ISAs, Junior ISAs and SIPPs) which facilitate both regular monthly investments and lump sum investments in the 
Company’s shares. There are a number of investment platforms that offer these facilities. A list of some of them, that 
is not comprehensive nor constitutes any form of recommendation, can be found below: 

AJ Bell Youinvest
Barclays Stockbrokers
Bestinvest
Charles Stanley Direct
EQi
FundsDirect
Halifax Investing
Hargreaves Lansdown
HSBC
iDealing
interactive investor
IWEB
Saga Share Dealing
   Saxo Markets
Wealth Club

http://www.youinvest.co.uk 
https://www.barclays.co.uk/smart-investor 
http://www.bestinvest.co.uk  
https://www.charles-stanley-direct.co.uk 
https://www.eqi.co.uk 
http://www.fundsdirect.co.uk 
http://www.halifax.co.uk/investing.html 
http://www.hl.co.uk 
https://hsbc.co.uk/investments 
http://www.idealing.com 
http://www.ii.co.uk 
http://www.iweb-sharedealing.co.uk  
https://www.saga.co.uk/money/share-dealing 
https://www.home.saxo 
https://www.wealthclub.co.uk

84 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Risk warnings 
– Past performance is no guarantee of future performance. 

– The value of your investment and any income from it may go down as well as up and you may not get back the 
amount invested. This is because the share price is determined by the changing conditions in the relevant stock 
markets in which the Company invests and by the supply and demand for the Company’s shares. 

– As the shares in an investment trust are traded on a stock market, the share price will fluctuate in accordance with 
supply and demand and may not reflect the underlying net asset value of the shares; where the share price is less 
than the underlying value of the assets, the difference is known as the ‘discount’. For these reasons, investors may 
not get back the original amount invested. 

– Although the Company’s financial statements are denominated in sterling, it may invest in stocks and shares that 
are denominated in currencies other than sterling and to the extent they do so, they may be affected by movements 
in exchange rates. As a result, the value of your investment may rise or fall with movements in exchange rates. 

– Investors should note that tax rates and reliefs may change at any time in the future. 

– The value of ISA and Junior ISA tax advantages will depend on personal circumstances. The favourable tax treatment 

of ISAs and Junior ISAs may not be maintained. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

85

4

Further Information

Notice of the Annual General Meeting 

Notice is hereby given that the Annual General Meeting of Menhaden Resource Efficiency PLC will be held at the offices 
of Frostrow Capital LLP, 25 Southampton Buildings, London WC2A 1AL on Wednesday, 22 June 2022 at 12 noon 
for the following purposes: 

Ordinary Business 
To consider and, if thought fit, pass the following as ordinary resolutions: 

1.

2.

3.

4.

5.

6.

To receive and accept the Annual Report for the year ended 31 December 2021, including the financial statements 
and the directors’ and auditor’s reports thereon. 

To receive and approve the Directors’ Remuneration Report for the year ended 31 December 2021. 

To approve the Company's Remuneration Policy. 

To declare a final dividend of 0.2p per ordinary share for the year ended 31 December 2021. 

To re-elect Sir Ian Cheshire as a Director of the Company. 

To re-elect Duncan Budge as a Director of the Company. 

7. 

To re-elect Howard Pearce as a Director of the Company. 

8.

9.

To elect Barbara Donoghue as a Director of the Company.  

To re-appoint Mazars LLP as the Company’s Auditor to hold office from the conclusion of the meeting to the 
conclusion of the next Annual General Meeting at which accounts are laid, and to authorise the Audit Committee 
to determine their remuneration. 

Special Business 
To consider and, if thought fit, pass the following resolutions of which resolutions 11,12 and 13 will be proposed as 
special resolutions: 

Authority to Issue Shares 
10. THAT, in substitution for all existing authorities, the Directors be and are hereby generally and unconditionally 
authorised in accordance with Section 551 of the Companies Act 2006 (the “Act”) to exercise all powers of the 
Company to allot relevant securities (within the meaning of section 551 of the Act) up to a maximum aggregate 
nominal amount of £80,000 (or if changed, the number representing 10% of the issued share capital of the 
Company at the date of the meeting at which this resolution is proposed) provided that this authority shall expire 
at the conclusion of the Annual General Meeting of the Company to be held in 2023 or 15 months from the date 
of passing this resolution, whichever is the earlier, unless previously revoked, varied or renewed by the Company 
in general meeting and provided that the Company shall be entitled to make, prior to the expiry of such authority, 
an offer or agreement which would or might require relevant securities to be allotted after such expiry and the 
Directors may allot relevant securities pursuant to such offer or agreement as if the authority conferred hereby 
had not expired. 

Disapplication of Pre-emption Rights 
11. THAT, in substitution of all existing powers, the Directors be and are hereby generally empowered pursuant to 
sections 570 and 573 of the Companies Act 2006 (the “Act”) to allot equity securities (within the meaning of 

86 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

section 560 of the Act) for cash pursuant to the authority conferred on them by resolution 10 set out in the notice 
convening the Annual General Meeting at which this resolution is proposed or otherwise as if section 561(1) of 
the Act did not apply to any such allotment and to sell relevant shares (within the meaning of section 560 of the 
Act, which includes the sale of relevant shares which, immediately before the sale, were held by the Company as 
treasury shares) for cash as if section 561(1) of the Act did not apply to any such sale, provided that this power 
shall be limited to the allotment of equity securities pursuant to:  

(a)   an offer of equity securities open for acceptance for a period fixed by the Directors where the equity securities 
respectively attributable to the interests of holders of shares of 1 penny each in the Company (“Shares”) are 
proportionate (as nearly as may be) to the respective numbers of Shares held by them but subject to such 
exclusions or other arrangements in connection with the issue as the Directors may consider necessary, 
appropriate, or expedient to deal with equity securities representing fractional entitlements or to deal with legal 
or practical problems arising in any overseas territory, the requirements of any regulatory body or stock 
exchange, or any other matter whatsoever; and 

(b)  (otherwise  than  pursuant  to  sub-paragraph  (a)  above)  an  offer  or  offers  of  equity  securities  of  up  to  an 
aggregate nominal value of £80,000 (or if changed, the number representing 10% of the issued share capital 
of the Company at the date of the meeting at which this resolution is proposed) and expires at the conclusion 
of the next Annual General Meeting of the Company after the passing of this resolution or 15 months from the 
date of passing this resolution, whichever is the earlier, unless previously revoked, varied or renewed by the 
Company in general meeting and provided that the Company shall be entitled to make, prior to the expiry of 
such authority, an offer or agreement which would or might require equity securities to be allotted after such 
expiry and the Directors may allot equity securities pursuant to such offer or agreement as if the power 
conferred hereby had not expired. 

Authority to Repurchase ordinary shares 
12. THAT the Company be and is hereby generally and unconditionally authorised in accordance with section 701 of 
the Companies Act 2006 (the “Act”) to make one or more market purchases (within the meaning of section 693(4) 
of the Act) of ordinary shares of 1 penny each in the capital of the Company (“Shares”) (either for cancellation or 
to be held, sold or otherwise dealt with as treasury shares in accordance with the Act) provided that: 

(a)   the maximum aggregate number of Shares authorised to be purchased is 11,992,000 or, if changed, the 
number representing approximately 14.99% of the issued share capital of the Company at the date of the 
meeting at which this resolution is proposed; 

(b)  the minimum price (exclusive of expenses) which may be paid for a Share is 1 penny; 

(c)   the maximum price (exclusive of expenses) which may be paid for a Share is an amount equal to the greater 
of (i) 105% of the average of the middle market quotations for a Share as derived from the Daily Official List 
of the London Stock Exchange for the five business days immediately preceding the day on which that Share 
is purchased and (ii) the higher of the price of the last independent trade in shares and the highest then current 
independent bid for shares on the London Stock Exchange; 

(d)  the authority hereby conferred shall expire at the conclusion of the Annual General Meeting of the Company 
to be held in 2023 or, if earlier, on the expiry of 15 months from the date of the passing of this resolution unless 
such authority is renewed prior to such time; and 

(e)   the Company may make a contract to purchase Shares under this authority before the expiry of such authority 
which will or may be executed wholly or partly after the expiration of such authority, and may make a purchase 
of Shares in pursuance of any such contract. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

87

4

Further Information

Notice of the Annual General Meeting 
continued

General Meetings 
13. THAT the Directors be authorised to call general meetings (other than the Annual General Meeting of the Company) 
on not less than 14 clear days’ notice, such authority to expire on the conclusion of the next Annual General 
Meeting of the Company or if earlier, on the expiry 15 months from the date of the passing of the resolution. 

Shareholders  should  note  that,  should  Government  restrictions  make  it  impossible  to  hold  a  physical 
meeting the Board will only conduct the statutory formal business this year in order to meet the minimum 
legal requirements. In that case arrangements will be made for shareholders to attend via a webinar, view 
a presentation by the Portfolio Manager and ask questions in advance. Shareholders are encouraged to 
view the Company’s website, www.menhaden.com for further information nearer the time. Questions to 
the  Board  and  the  Portfolio  Manager  can  be  submitted  by  email  to  the  Company  Secretary  at 
info@frostrow.com. Should time pressures make it impossible to answer all questions during the webinar, 
then an effort will be made to answer them on the website afterwards. 

All shareholders should look on the Company’s website, www.menhaden.com for any late changes to the 
AGM arrangements and whether attendance will be restricted.  

In any case, all shareholders are strongly advised to exercise their votes in advance of the meeting by proxy, 
by following the voting instructions overleaf. Subject to any Government restrictions on meeting attendance 
generally, registering proxy votes online will not restrict attendance of the AGM in person.  

By order of the Board

Frostrow Capital LLP 
Company Secretary 
20 April 2022

Registered Office: 
25 Southampton Buildings 
London WC2A 1AL 

88 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Notes 
1. Members are entitled to appoint a proxy to exercise all or any of their rights to attend and to speak and vote on their behalf at the 
meeting. A shareholder may appoint more than one proxy in relation to the meeting provided that each proxy is appointed to exercise 
the rights attached to a different share or shares held by that shareholder. A proxy need not be a shareholder of the Company. However, 
if you appoint the Chairman of the AGM as your proxy, this will ensure that your votes are cast in accordance with your wishes in the 
event that restrictions on attendance are imposed by the Government at the time of the meeting. In such an eventuality, if any other 
person is appointed as your proxy, they may not be able to attend the meeting to vote on your behalf. 

2.

A vote withheld is not a vote in law, which means that the vote will not be counted in the calculation of votes for or against the resolutions. 
If no voting indication is given, a proxy may vote or abstain from voting at his/her discretion. A proxy may vote (or abstain from voting) 
as he or she thinks fit in relation to any other matter which is put before the meeting. 

3. Hard copy forms of proxy have not been included with this notice. Members can vote by: logging onto www.signalshares.com and 
following  instructions,  requesting  a  hard  copy  form  of  proxy  directly  from  the  registrars,  Link  Group,  by  emailing 
enquiries@linkgroup.co.uk; or, in the case of CREST members, utilising the CREST electronic proxy appointment service in accordance 
with the procedures set out below. To be valid any appointment of a proxy must be completed, signed and received at Link Group, 
PXS 1, Central Square, 29 Wellington Street, Leeds LS1 4DL no later than 12 noon on 20 June 2022. 

4.

5.

6.

7.

8.

In the case of a member which is a company, the instrument appointing a proxy must be executed under its seal or signed on its behalf 
by a duly authorised officer or attorney or other person authorised to sign. Any power of attorney or other authority under which the 
instrument is signed (or a certified copy of it) must be included with the instrument. 

The return of a completed proxy form, other such instrument or any CREST Proxy Instruction (as described below) will not prevent a 
shareholder attending the meeting and voting in person if he/she wishes to do so. 

Any person to whom this notice is sent who is a person nominated under section 146 of the Companies Act 2006 to enjoy information 
rights (a “Nominated Person”) may, under an agreement between him/her and the shareholder by whom he/she was nominated, have 
a right to be appointed (or have someone else appointed) as a proxy for the meeting. If a Nominated Person has no such proxy 
appointment right or does not wish to exercise it, he/she may, under any such agreement, have a right to give instructions to the 
shareholder as to the exercise of voting rights. 

The statement of the rights of shareholders in relation to the appointment of proxies in paragraphs 1 and 3 above does not apply to 
Nominated Persons. The rights described in these paragraphs can only be exercised by shareholders of the Company. 

Pursuant to regulation 41 of the Uncertificated Securities Regulations 2001, only shareholders registered on the register of members 
of the Company (the “Register of Members”) at close of business on 20 June 2022 (or, in the event of any adjournment, on the date 
which is two business days before the time of the adjourned meeting) will be entitled to attend and vote or be represented at the 
meeting in respect of shares registered in their name at that time. Changes to the Register of Members after that time will be disregarded 
in determining the rights of any person to attend and vote at the meeting. 

9.

As at 19 April 2022 (being the last business day prior to the publication of this notice) the Company’s issued share capital consists of 
80,000,001 ordinary shares, carrying one vote each. Therefore, the total voting rights in the Company as at 19 April 2022 are 80,000,001. 

10. CREST members who wish to appoint a proxy or proxies through the CREST electronic proxy appointment service may do so by using 
the procedures described in the CREST Manual. CREST Personal Members or other CREST sponsored members, and those CREST 
members who have appointed a service provider(s), should refer to their CREST sponsor or voting service provider(s), who will be able 
to take the appropriate action on their behalf. 

11.

In  order  for  a  proxy  appointment  or  instruction  made  using  the  CREST  service  to  be  valid,  the  appropriate  CREST  message 
(a “CREST Proxy Instruction”) must be properly authenticated in accordance with the specifications of Euroclear UK and Ireland Limited 
(“CRESTCo”), and must contain the information required for such instruction, as described in the CREST Manual. The message, 
regardless of whether it constitutes the appointment of a proxy or is an amendment to the instruction given to a previously appointed 
proxy must, in order to be valid, be transmitted so as to be received by the issuer’s agent (ID RA10) no later than 48 hours before the 
time appointed for holding the meeting, excluding non-business days. For this purpose, the time of receipt will be taken to be the time 
(as determined by the timestamp applied to the message by the CREST Application Host) from which the issuer’s agent is able to retrieve 
the message by enquiry to CREST in the manner prescribed by CREST. After this time any change of instructions to proxies appointed 
through CREST should be communicated to the appointee through other means. 

12. CREST members and, where applicable, their CREST sponsors, or voting service providers should note that CRESTCo does not make 
available special procedures in CREST for any particular message. Normal system timings and limitations will, therefore, apply in relation 
to the input of CREST Proxy Instructions. It is the responsibility of the CREST member concerned to take (or, if the CREST member is a 
CREST personal member, or sponsored member, or has appointed a voting service provider, to procure that his CREST sponsor or voting 
service provider(s) take(s)) such action as shall be necessary to ensure that a message is transmitted by means of the CREST system by 
any particular time. In this connection, CREST members and, where applicable, their CREST sponsors or voting system providers are 
referred, in particular, to those sections of the CREST Manual concerning practical limitations of the CREST system and timings. 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

89

4

Further Information

Notice of the Annual General Meeting 
continued

13. The Company may treat as invalid a CREST Proxy Instruction in the circumstances set out in Regulation 35(5)(a) of the Uncertificated 

Securities Regulations 2001. 

14.

In the case of joint holders, where more than one of the joint holders purports to appoint a proxy, only the appointment submitted by the 
most senior holder will be accepted. Seniority is determined by the order in which the names of the joint holders appear in the Register 
of Members in respect of the joint holding (the first named being the most senior). 

15. Members who wish to change their proxy instructions should submit a new proxy appointment using the methods set out above. Note 
that the cut-off time for receipt of proxy appointments (see above) also applies in relation to amended instructions; any amended proxy 
appointment received after the relevant cut-off time will be disregarded. 

16. Members who have appointed a proxy using a hard-copy proxy form and who wish to change the instructions using another hard-copy 
form, should contact Link Group on 0371 664 0300. Calls are charged at the standard geographic rate and will vary by provider. Calls 
outside the United Kingdom will be charged at the applicable international rate. Lines are open between 9.00 a.m. to 5.30 p.m., Monday 
to Friday excluding public holidays in England and Wales. 

17.

18.

If a member submits more than one valid proxy appointment, the appointment received last before the latest time for the receipt of 
proxies will take precedence. 

In order to revoke a proxy instruction, members will need to inform the Company. Members should send a signed hard copy notice 
clearly stating their intention to revoke a proxy appointment to Link Group, PXS 1, Central Square, 29 Wellington Street, Leeds LS1 4DL. 

In the case of a member which is a company, the revocation notice must be executed under its common seal or signed on its behalf by 
an officer of the company or an attorney for the company. Any power of attorney or any other authority under which the revocation notice 
is signed (or a duly certified copy of such power of attorney) must be included with the revocation notice. If a member attempts to revoke 
their proxy appointment but the revocation is received after the time for receipt of proxy appointments then, subject to paragraph 4, the 
proxy appointment will remain valid. 

19.

It is possible that Government guidance could require the Company to impose restrictions on shareholders wishing to attend the AGM. 
Such restrictions may include limiting the number of shareholders permitted to attend the AGM in person. 

90 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Explanatory Notes to the Resolutions

Resolution 1 – To receive the Annual Report 
The Annual Report for the year ended 31 December 2021, 
incorporating the financial statements and this Notice of 
Meeting,  will  be  presented  to  the  Annual  General 
Meeting (AGM). 

Duncan Budge 
Duncan has over 35 years’ experience from his career in 
the city and the investment trust sector, and his first-hand 
knowledge enables the Board to engage authoritatively 
with the Portfolio Manager on their investment strategy. 

Resolution 2 – Directors’ Remuneration Report 
It is mandatory for listed companies to put their report on 
Directors’ remuneration to an advisory shareholder vote 
every year. The Directors’ Remuneration Report is set out 
on pages 51 and 52 of this Annual Report. 

Resolution 3 – Directors' Remuneration Policy 
It is mandatory for listed companies to put their Directors' 
remuneration policy to a binding shareholder vote at least 
every three years. The Directors' Remuneration Policy is 
set out on page 53 of this Annual Report. 

Resolution 4  – Dividend  
It  is  necessary  for  the  Company  to  pay  a  dividend  in 
respect of the year ended 31 December 2021 in order for 
it to retain investment trust status. Accordingly, the Board 
is recommending the declaration of a dividend of 0.2p per 
ordinary share, payment of which will afford compliance 
with the requirement for the Company to retain no more 
than 15% of the income from shares and securities in the 
year. 

Resolutions 5 to 8 – Re-election and Election of Directors  
Resolutions 5 to 8 deal with the re-election and election 
of the Directors. Biographies of each of the Directors can 
be found on pages 34 and 35 of this Annual Report. 

The specific reasons why (in the Board’s opinion) each 
Directors’ contribution is, and continues to be, important 
to the Company’s long-term sustainable success are as 
follows: 

Sir Ian Cheshire 
Sir  Ian’s  leadership  of  the  Board  draws  on  30  years’ 
experience in the retail, charity, and banking sectors. His 
focus  is  on  long-term  strategic  issues,  including  the 
sustainability and environmental impact of the portfolio. 

Barbara Donoghue 
Barbara has a wealth of experience gained over more than 
30 years to contribute to Board and Committee decision 
making, including from past board room appointments, 
corporate finance and private equity. 

Howard Pearce 
Howard has over 30 years’ experience advising at Board 
level on green investment and significant expertise of audit 
committee  chairmanship  which  aids  the  Company’s 
financial and environmental impact reporting. 

Resolution  9  –  Re-appointment  of  Auditor  and  the 
determination of their remuneration 
Resolution 9 is for the re-appointment of Mazars LLP as 
the Company’s independent Auditor to hold office until the 
next AGM of the Company and also authorises the Audit 
Committee  to  set  their  remuneration.  Following  the 
implementation of the Competition and Markets Authority 
order  on  Statutory  Audit  Services,  only  the  Audit 
Committee  may  negotiate  and  agree  the  terms  of  the 
Auditor’s service agreement. 

Resolutions 10 and 11 – Issue of Shares 
Ordinary Resolution 10 in the Notice of Annual General 
Meeting  is  to  renew  the  authority  to  allot  new  ordinary 
shares  up  to  an  aggregate  of  10%  of  the  Company’s 
existing  issued  share  capital  at  the  date  of  the  Annual 
General Meeting). This authority (if granted) will expire on 
the date of the next Annual General Meeting or after a 
period of 15 months from the date of the passing of the 
resolution,  whichever  is  earlier.  This  means  that  the 
authority  will  have  to  be  renewed  at  the  next  Annual 
General Meeting unless previously renewed.  

When  shares  are  to  be  allotted,  Section  551  of  the 
Companies  Act  2006  (the  “Act”)  provides  that  existing 
shareholders  have  pre-emption  rights  and  that  the  new 
shares  must  be  offered  first  to  such  shareholders  in 
proportion  to  their  existing  holding  of  shares.  However, 
shareholders  can,  by  special  resolution,  authorise  the 
Directors to allot shares otherwise than by a pro rata issue 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

91

4

Further Information

Explanatory Notes to the Resolutions 
continued

to  existing  shareholders.  Special  Resolution  11  will,  if 
passed, give the Directors power to allot (and/ or sell from 
treasury) for cash equity securities up to the equivalent of 
10%  of  the  Company’s  existing  share  capital,  as  if 
Section 551 of the Act does not apply. This is the same 
nominal  amount  of  share  capital  that  the  Directors  are 
seeking the authority to allot pursuant to Resolution 10. This 
authority will also expire on the date of the next Annual 
General Meeting or after a period of 15 months, whichever 
is earlier. This authority will not be used in connection with 
a rights issue by the Company.  

The  Directors  intend  to  use  the  authority  given  by 
Resolutions 10 and 11 to allot shares and disapply pre-
emption rights only in circumstances where this will be 
clearly beneficial to shareholders as a whole. The issue 
proceeds would be available for investment in line with the 
Company’s investment policy. No issue of shares will be 
made  which  would  effectively  alter  the  control  of  the 
Company without the prior approval of shareholders in 
general meeting. 

Resolution 12 – Share Repurchases 
The principal aim of a share buy-back facility is to enhance 
shareholder value by acquiring shares at a discount to net 
asset value, as and when the Directors consider this to be 
appropriate. The purchase of shares, when they are trading 
at a discount to net asset value per share, should result in 
an  increase  in  the  net  asset  value  per  share  for  the 
remaining shareholders. This authority, if conferred, will only 
be exercised if to do so would result in an increase in the 
net asset value per share for the remaining shareholders 
and  if  it  is  considered  to  be  in  the  best  interests  of 
shareholders  generally.  Any  purchase  of  shares  will  be 
made within guidelines established from time to time by 
the Board. 

Under the current Listing Rules, the maximum price that 
may be paid on the exercise of this authority must not 
exceed the higher of (i) 105% of the average of the middle 
market quotations for the shares over the five business 
days immediately preceding the date of purchase and (ii) 
the higher of the last independent trade and the highest 
current independent bid on the trading venue where the 
purchase is carried out. The minimum price which may be 
paid is 1 penny per share. 

92 Menhaden Resource Efficiency PLC 

Annual Report for the year ended 31 December 2021

Special  Resolution  12  in  the  Notice  of  Annual  General 
Meeting seeks to renew the authority to purchase in the 
market  a  maximum  of  14.99%  of  shares  in  issue 
(amounting  to  11,952,000  shares  at  the  date  of  this 
Annual Report). The authority (if granted) will expire on the 
date of the next Annual General Meeting or after a period 
of 15 months from the date of passing of the resolution, 
whichever is earlier. This means in effect that the authority 
will  have  to  be  renewed  at  the  next  Annual  General 
Meeting or earlier if the authority has been exhausted. 

Resolution 13 – General Meetings 
Special Resolution 13 seeks shareholder approval for the 
Company to hold General Meetings (other than the AGM) 
on 14 clear days’ notice, which is the minimum notice 
period permitted by the Companies Act 2006. This is a 
routine  resolution  necessitated  by  the  EU  Shareholder 
Rights Directive, which has been transcribed into UK law. 

The  Company  will  only  use  this  shorter  notice  period 
where it is merited by the purpose of the meeting and will 
endeavour  to  give  at  least  14  working  days’  notice  if 
possible. 

Recommendation 
The Board considers that the resolutions relating to the 
above items are in the best interests of shareholders as a 
whole. Accordingly, the Board unanimously recommends 
to  shareholders  that  they  vote  in  favour  of  the  above 
resolutions, as the Directors intend to do in respect of their 
own beneficial holdings totalling 404,693 shares. 

Company Information 

Directors 
Sir Ian Cheshire (Chairman) 
Duncan Budge 
Barbara Donoghue (with effect from 1 February 2022) 
Emma Howard Boyd 
Howard Pearce 

Company Registration Number 
09242421 (Registered in England and Wales) 
The Company is an investment company as defined under 
Section 833 of the Companies Act 2006 
The Company was incorporated on 30 September 2014. The 
Company was incorporated as BGT Capital PLC. 

Auditor 
Mazars LLP 
The Pinnacle 
160 Midsummer Boulevard 
Milton Keynes 
MK9 1FF 

Corporate Broker 
Numis Securities Limited 
45 Gresham St 
London  
EC2V 7BF  

Website 
Website: www.menhaden.com  

Registered Office 
25 Southampton Buildings 
London WC2A 1AL 

Alternative Investment Fund Manager,  
Company Secretary and Administrator 
Frostrow Capital LLP 
25 Southampton Buildings, London WC2A 1AL 
Telephone: 0203 008 4910 
E-mail: info@frostrow.com  
Website: www.frostrow.com  
Authorised and regulated by the Financial Conduct Authority 

If you have an enquiry about the Company or if you would like 
to receive a copy of the Company’s monthly fact sheet by 
e-mail, please contact Frostrow Capital using the above e-mail 
address. 

Portfolio Manager 
Menhaden Capital Management LLP 
2nd Floor 
Heathmans House 
19 Heathmans Road 
London 
SW6 4TJ 
Authorised and regulated by the Financial Conduct Authority 

Depositary 
J.P. Morgan Europe Limited 
25 Bank Street 
London E14 5JP 

Registrar 
Link Group 
10th Floor 
Central Square 
29 Wellington Street 
Leeds LS1 4DL 
Telephone: + 44 371 664 0300 
E-mail: enquiries@linkgroup.co.uk 
Shareholder Portal: www.signalshares.com 
Website: www.linkgroup.eu  
Please contact the Registrars if you have a query about a 
certificated holding in the Company’s shares. 
†Calls are charged at the standard geographic rate and will vary by provider. Calls 
outside the UK will be charged at the applicable international rate. Lines are open 
from 9.00 a.m. to 5.30 p.m. Monday to Friday excluding public holidays in England 
and Wales. 

Share Price Listings 
The price of your shares can be found in various publications 
including the Financial Times, The Daily Telegraph, The Times 
and The Scotsman. 

The Company’s net asset value per share is announced daily 
and is available, together with the share price, on the TrustNet 
website at www.trustnet.com. 

Identification Codes 
Shares:

SEDOL
ISIN
BLOOMBERG 
EPIC

Legal Entity Identifier  
2138004NTCUZTHFWXS17

: BZ0XWD0 
: GB00BZ0XWD04 
: MHN LN 
: MHN 

Menhaden Resource Efficiency PLC 
Annual Report for the year ended 31 December 2021

93

Menhaden PLC – Annual Report

Company Summary

Menhaden PLC (the “Company”) is an investment trust. Its shares are listed on the premium segment of the Official 

List and traded on the main market of the London Stock Exchange. The Company is a member of the Association of 

30 September 2014 to 31 December 2015

Annual Report for the period from incorporation on

Menhaden Capital PLC

Investment Companies.

Investment Objective

Management

The Company aims to generate long-term shareholder returns, predominantly in the form of capital growth, by investing 

in businesses and opportunities delivering or benefiting from the efficient use of energy and resources irrespective of 

their size, location or stage of development.

The Company employs Frostrow Capital LLP as its Alternative Investment Fund Manager (“AIFM”) to provide company 

management,  company  secretarial,  administrative  and  marketing  services.  Frostrow  and  the  Company  have  jointly 

appointed Menhaden Capital Management LLP as the Portfolio Manager. Further details of these appointments are 

The Company’s capital structure is composed solely of Ordinary Shares. Details are given on page 36 and in note 12 

provided on pages 25 and 26.

Capital Structure

to the financial statements on page 75.

ISA Status

The Company’s shares are eligible for Stocks and Shares ISAs.

Retail Investors advised by IFAs

The Company currently conducts its affairs so that its shares can be recommended by Independent Financial Advisers 

(“IFAs”) in the UK to ordinary retail investors in accordance with the Financial Conduct Authority (“FCA”) rules in relation 

to non-mainstream investment products and intends to continue to do so. The shares are excluded from the FCA’s 

restrictions which apply to non-mainstream pooled investment products because they are shares in an investment 

trust.

Menhaden

Menhaden are forage fish that occur in great abundance in the West Atlantic Ocean. The name, Menhaden, is derived 

from the Native American expression “he fertilises” referring to the wide spread use of the fish as a fertiliser. Menhaden 

filter vast quantities of water and play a key role in the food chain. It has been argued that the environmental movement 

and fisheries ecology rose from the first collapse in the population of Menhaden in the 1860s as this was used as a 

prominent example of mankind’s impact on the oceans and the importance of using resources sustainably.

A member of the Association of Investment Companies
A member of the Association of Investment Companies

Disability Act
Disability Act
Copies of this annual report and other documents issued by the Company are available from the Company Secretary. If needed, copies can be 
Copies of this annual report and other documents issued by the Company are available from the Company Secretary. If needed, copies can be 
made available in a variety of formats, including Braille, audio tape or larger type as appropriate. You can contact the Registrar to the Company, 
made available in a variety of formats, including Braille, audio tape or larger type as appropriate. You can contact the Registrar to the Company, 
Link Asset Services, which has installed telephones to allow speech and hearing impaired people who have their own telephone to contact them directly, 
Link Asset Services, which has installed telephones to allow speech and hearing impaired people who have their own telephone to contact them directly, 
without the need for an intermediate operator, for this service please call 0800 731 1888.
without the need for an intermediate operator, for this service please call 0800 731 1888.
Specially trained operators are available during normal business hours to answer queries via this service. Alternatively, if you prefer to go through 
Specially trained operators are available during normal business hours to answer queries via this service. Alternatively, if you prefer to go through 
a ‘typetalk’ operator (provided by the RNID) you should dial 18001 followed by the number you wish to dial.
a ‘typetalk’ operator (provided by the RNID) you should dial 18001 followed by the number you wish to dial.

Environment
Environment
This report is printed on Revive 100% White Silk a totally recycled paper produced using 100% recycled waste at a mill that has been awarded 
This report is printed on Revive 100% White Silk a totally recycled paper produced using 100% recycled waste at a mill that has been awarded 
the ISO 14001 certificate for environmental management.
the ISO 14001 certificate for environmental management.

The pulp is bleached using a totally chlorine free (TCF) process.
The pulp is bleached using a totally chlorine free (TCF) process.

Menhaden Resource Efficiency PLC  
Menhaden PLC  
25 Southampton Buildings 
25 Southampton Buildings 
London WC2A 1AL
London WC2A 1AL

www.menhaden.com  
www.menhaden.com  
Tel +44(0) 203 008 4910
Tel +44(0) 203 008 4910

Perivan  262674
Perivan  257636

M

e

n

h

a

d

e

n

R

e

s

o

u

r

c

e

E

f

fi

c

i

e

n

c

y

P

L

C

A

n

n

u

a

l

R

e

p

o

r

t

f

o

r

t

h

e

y

e

a

r

e

n

d

e

d

3

1

D

e

c

e

m

b

e

r

2

0

2

1