Strattners maintains a regulated execution and underwriting framework to support its proprietary participation in public capital markets.
This framework exists exclusively to facilitate balance-sheet deployment in primary and secondary market transactions aligned with the group’s long-term investment strategies.
The Primary Market Execution & Principal Underwriting Framework enables Strattners to:
Participate directly in primary issuances and related public market transactions
Underwrite equity or debt instruments for proprietary investment purposes
Execute secondary market transactions in support of underwritten or strategic positions
Maintain appropriate regulatory standing when engaging in public markets
This framework supports internal execution only and does not constitute a brokerage, advisory, or underwriting service offering.
Where strategically appropriate, Strattners may participate in primary offerings as an underwriting principal, committing its own capital and assuming associated market and holding risk.
Such participation:
Is conducted exclusively for the account of Strattners or its affiliated investment vehicles
Does not involve issuer mandates, placement agreements, or distribution activities for third parties
Is undertaken in alignment with long-term ownership and capital preservation objectives
Strattners maintains internal governance frameworks aligned with internationally recognised securities regulations applicable to proprietary participation in public markets. These frameworks support compliant engagement in listed securities across relevant jurisdictions and are maintained solely for internal and structural purposes.
Strattners’ proprietary market participation is conducted within a defined regulatory and governance framework. Where applicable, internal policies and controls are aligned with key U.S. securities regulations commonly referenced in public market transactions, including:
Regulation M
Internal controls are designed to mitigate risks associated with market manipulation in connection with offerings and related secondary market activity undertaken for proprietary purposes.
Rule 10b-5
Governance standards are maintained to ensure accuracy and integrity in connection with securities transactions and related disclosures.
Section 17(b) of the Securities Act
Policies are in place to prevent misleading promotional conduct and to ensure appropriate disclosure standards in relation to proprietary market activity.
Regulation S
Offshore transactions, where applicable, are structured in accordance with established Regulation S principles governing non-U.S. offerings and transactions.
These standards are referenced for governance purposes only and do not imply the provision of sales, trading, advisory, or promotional services to third parties.
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