Conduct of Business Sourcebook rule 2.2.3R, requires Coupland Cardiff Asset Management LLP ("the Firm") to include a disclosure on its website stating the nature of its commitment to the UK Stewardship Code ("the Code") issued by the Financial Reporting Council. If a firm does not commit to the Code, it must state in general terms its alternative investment strategy. The Code sets out various principles relating to the level of engagement by investors with UK equity investors.

The Firm's investment strategies are multiple across a number of different funds. The Firm trades principally in Asian, including Japanese, equities and related products across all strategies employed (event driven, long/short and long only). These strategies are designed to be highly flexible to market conditions/opportunities and as such result in the Firm trading non-UK single equities and their related products.

In addition, due to the nature of all the investment strategies, the Firm does not employ a hard policy for proxy voting. Whilst the Firm takes the fiduciary responsibility of managing assets for clients very seriously, we will only vote where we believe that it is in our underlying investors’ interests to do so. The current policy of the Firm in engaging with issuers and their management is consistently applied across its international equity holdings. Therefore, although the Firm supports the objectives set out within the Code, the provisions are not deemed to be relevant to the type of investment strategies and trading currently undertaken by the Firm. Should any material change occur to the investment strategies which would make the Code relevant, the Firm will amend its policy and this disclosure in a timely manner.

December 2019