Shareholder Rights Directive Disclosure

Shareholder Rights Directive (Directive (EU) 2017/828) Requirements (SRD II)

Under obligations arising from SRD II, as applied in the UK, a firm which trades shares on regulated and comparable markets, is required to either develop and publicly disclose an engagement policy as prescribed in COBS 2.2B.5 of the Financial Conduct Authority's Handbook, or disclose a clear and reasoned explanation of why it has chosen not to do so.

Kedalion Capital Management LLP ("KCM") does not currently have an engagement policy because as a relative value investor it has little basis for monitoring or engaging with investee companies or other stakeholders, as this would be inconsistent with the KCM's strategy and would not, in KCM's opinion, be of value to its client(s).