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STEWARDSHIP CODE DISCLOSURE

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook (“COBS”), FM Capital Partners Ltd (the "Company") is required to include on its website 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, its alternative investment strategy.

The Code is a voluntary code and aims to enhance the quality of engagement by investors with UK equity issuers. The UK Financial Reporting Council (“FRC”) recognises that not all parts of the Code will be relevant to all investors, and that firms may either comply with the Code or choose not to comply with certain aspects of the Code, in such case an explanation of non-compliance is required. The Code is primarily directed at institutional investors with equity holdings in UK listed companies.

FM Capital Partners Ltd provides investment management services to a number of funds that utilise a variety of strategies in both equities and fixed income assets on a global basis. The Code is therefore applicable to some aspects of the underlying trading (UK equities), however, this generally represents a small proportion of the invested asset base which is typically across a variety of jurisdictions globally. Although the Company supports the Code's objectives, it has taken the decision not to commit to the principles of the Code. The Company takes a consistent approach to engaging with issuers and their management in all the jurisdictions in which it invests in, and does not therefore consider it appropriate to comply with any voluntary codes of practice in any individual jurisdictions.

For further information, please contact the Compliance Department at FM Capital Partners Ltd.