Shareholders Rights Directive (SRD II)

We are required by the Revised Shareholder Rights Directive (SRD II) to explain whether or not we have an engagement policy in relation to the companies we invest in, where the companies’ shares are admitted to trading on a regulated market. As the proportion of shares we hold in investee companies is much lower than those held by large institutional investors, we are not able to engage with investee companies to the extent envisaged by SRDII. Therefore, we do not have a formal engagement policy.

Stewardship Code

We have regard to the Stewardship Code when managing investments for professional clients. It is our policy to review the performance of investee companies and take appropriate action where necessary. Our policy on conflicts of interest, and on voting rights for professional clients, is available on request.