Disclosure

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Edale Capital LLP (“Edale” or the “Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, explain its considered choice based on the firm’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.

Part of the Firm’s investment strategy involves investing in UK listed equities on behalf of clients and Edale generally supports the objectives that underlie the Code, the Firm does not engage with investee companies, or act collectively with other shareholders. Nor does the Firm comment upon the corporate governance of UK listed companies or exercise voting rights. The Firm has therefore has chosen not to commit to the Code at this time.