Shareholder Rights Directive II

The Shareholder Rights Directive II (SRD II) is a European Union (EU) directive, and aims to encourage effective stewardship and long term decision making, involving transparency on engagement policies and investment strategies between traded companies and investors. SRD II applies to asset managers including MiFID investment Managers that invest in shares which are traded globally.

The Firm does not trade listed equities as a core strategy. As such, an engagement policy is not applicable to the investment strategies currently pursued.