UK Stewardship Code Disclosure Statement

Under Rule 2.2.3R of the FCA Conduct of Business Sourcebook, Caius Capital LLP (“Caius Capital” or the “Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include a disclosure about the nature of its commitment to the UK Financial Reporting Council’s (“FRC”) Stewardship Code (the “Code”) or, where it does not commit to the Code, explain its considered choice based on the Caius Capital’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by institutional investors in UK-listed companies. For this purpose, “stewardship” is defined as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries, which leads to sustainable benefits for the economy, the environment and society.

Caius Capital pursues an opportunistic credit strategy which involves investing in predominantly European levered capital structures across a broad range of instrument types. Investing in single name UK equities which formed the focus of the FRC’s original Stewardship Code does not, therefore, form a core part of its strategy. As a result, whilst Caius Capital generally supports the objectives that underlie the Code, it would be impractical to subscribe to voluntary codes of practice within individual jurisdictions given its current strategy. Should the Firm decide to pursue a strategy with an investment focus more directed at single name UK equities, it will review its commitment to the Code at that time and amend this disclosure.