Ashlee Steinnerd
About Ashlee Steinnerd
Ashlee Steinnerd serves as Chief Legal Officer of Barings Corporate Investors (MCI) and Barings Participation Investors (MPV), having been appointed in February 2023 after serving as Secretary of the Trusts since 2020; she is 43 years old as reflected in the 2025 proxy and has held senior legal and regulatory leadership roles across multiple Barings-affiliated investment vehicles . Her background includes Senior Counsel at the U.S. Securities and Exchange Commission from 2011 to 2019, and at Barings she progressed from Director (2019–2022) to Head of Regulatory (since 2021) and Managing Director (since 2022) before becoming Chief Legal Officer at the Trusts and several affiliated funds . The Trusts’ proxies do not disclose executive-specific performance metrics (e.g., TSR, revenue, EBITDA) tied to officer compensation, and officers’ compensation is paid by Barings rather than the Trusts, limiting pay-for-performance analysis using Trust filings .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| U.S. Securities and Exchange Commission | Senior Counsel | 2011–2019 | Federal securities law and regulatory enforcement experience supporting legal risk management |
| Barings | Director; Head of Regulatory; Managing Director | Director 2019–2022; Head of Regulatory since 2021; Managing Director since 2022 | Led regulatory function and advanced to managing director, underpinning compliance governance |
| Barings Corporate Investors / Barings Participation Investors | Secretary | Since 2020 (through 2023) | Corporate secretary responsibilities across board governance and disclosure |
External Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Barings BDC, Inc. | Chief Legal Officer; Secretary (until 2023) | Chief Legal Officer since 2023; Secretary 2020–2023 | Legal leadership for a business development company advised by Barings |
| Barings Capital Investment Corporation | Chief Legal Officer; Secretary (until 2023) | Chief Legal Officer since 2023; Secretary 2020–2023 | Legal oversight for affiliated BDC |
| Barings Private Credit Corporation | Chief Legal Officer; Secretary (until 2023/2021) | Chief Legal Officer since 2023; Secretary 2021–2023 | Private credit legal governance |
| Barings Global Short Duration High Yield Fund | Chief Legal Officer; Secretary (until 2023/2021) | Chief Legal Officer since 2023; Secretary 2021–2023 | Closed-end fund legal oversight |
| Barings Private Equity Opportunities & Commitments Fund | Chief Legal Officer (2023–2024); Secretary (2022–2023) | 2023–2024 CLO; 2022–2023 Secretary | Legal oversight until adviser termination in Feb 2024 |
Fixed Compensation
- Officers of the Trusts (including the Chief Legal Officer) are compensated and have expenses paid by Barings under the Investment Services/Advisory Contracts; the Trusts do not disclose officer-level base salary, bonus targets, or equity grants in the proxy statements .
- Independent Trustees receive fixed quarterly fees and stipends (not applicable to officers); no pension or retirement benefits are provided by the Trusts .
Performance Compensation
- The proxies do not disclose any executive-specific incentive metrics (e.g., revenue growth, EBITDA, TSR percentile) or performance-based stock awards for Trust officers; officers’ pay is handled by Barings and not itemized at the Trust level .
- No disclosures of RSUs/PSUs, option grants, vesting schedules, or clawbacks for Trust officers appear in the proxies; trustee compensation is flat-fee and separate from officers .
Equity Ownership & Alignment
| Metric | FY 2024 | FY 2025 |
|---|---|---|
| Trustees and Officers group beneficial ownership (% of MCI outstanding shares) | 2.17% | 1.95% |
| Barings beneficial ownership (% of MCI outstanding shares) | 1.08% | 1.07% |
- Beneficial ownership is determined under Exchange Act Rule 16a-1(a)(2); proxies provide trustee dollar ranges and group ownership, but do not itemize officer-specific holdings for Ashlee Steinnerd by share count or dollar range .
- Section 16(a) compliance disclosures for FY 2023 noted late filings for certain individuals (Christina Emery Form 4; David Mihalick and Joseph Evanchick Form 3s), with no exceptions reported for Ashlee Steinnerd .
- The proxies do not disclose officer hedging/pledging policies or stock ownership guidelines applicable to officers; a separate investment requirement applies to Independent Trustees (one year’s worth of trustee fees invested) and is not an officer guideline .
Employment Terms
- Role and tenure: Chief Legal Officer since February 2023; previously Secretary of the Trusts since 2020 .
- Officers hold their positions until a successor is duly elected and qualified; proxies do not disclose contract term lengths, severance, change-of-control triggers, non-compete/non-solicit, garden leave, or consulting arrangements for officers .
- Meeting administration and governance disclosures reflect her secretary responsibilities in prior years’ meeting notices .
Investment Implications
- Compensation alignment and incentive levers: Because officer compensation is paid by Barings and not disclosed at the Trust level, traditional pay-for-performance analysis (salary, bonus, equity metrics, vesting) cannot be evaluated from Trust proxies; this limits insight into near-term selling pressure or vesting-related trading signals specific to Ashlee Steinnerd .
- Retention risk: Tenure and leadership across multiple Barings-affiliated vehicles, coupled with prior SEC experience, suggest institutional anchoring of the role; absence of disclosed severance/change-of-control terms at the Trust level implies retention and mobility are driven by Barings employment policies rather than Trust charters .
- Ownership alignment and red flags: Group-level officer/trustee ownership in MCI is modest (sub-2.2% across 2024–2025), Barings beneficial ownership is ~1.07–1.08%; no specific pledging/hedging disclosures or officer-level positions for Ashlee are provided, and no Section 16 exceptions were noted for her, reducing immediate governance red flags from Trust filings .
- Trading signals: Without Form 4 detail for Ashlee in Trust filings and no officer-specific vesting schedules or equity grants disclosed, there are limited officer-driven trading catalysts observable from proxies; monitoring Barings-wide insider filings and fund-level disclosures would be necessary for actionable signals beyond Trust-level documents .