Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, the Firm is required to disclose 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, its alternative investment strategy.

The Firm pursues systematic, quantitative investment strategies that do not invest in companies with the intention of taking any activist role or any form of controlling interest, nor does the Firm consider that investors in its strategies would expect such engagement. Consequently, while the Firm supports the objectives that underlie the Code, the provisions of the Code are not relevant to the type of investment currently undertaken by the Firm.

If the Firm's investment strategies change in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.

For further details, please contact: 

Giles McClelland

Chief Operating Officer
Markham Rae LLP
London