Stewardship Code Statement

Version control: Last Reviewed December 2023.

1. Stewardship Code Statement

The principles of the UK Stewardship Code (the Code) are:

1. Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
2. Signatories’ governance, resources and incentives support stewardship.
3. Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first
4. Signatories identify and respond to market-wide and systemic risks to promote a well-functioning financial system.
5. Signatories review their policies, assure their processes and assess the effectiveness of their activities.
6. Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.
7. Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.
8. Signatories monitor and hold to account managers and/or service providers.
9. Signatories engage with issuers to maintain or enhance the value of assets.
10. Signatories, where necessary, participate in collaborative engagement to influence issuers.
11. Signatories, where necessary, escalate stewardship activities to influence issuers.
12. Signatories actively exercise their rights and responsibilities.

2. Statement of Commitment

The Firm pursues a multi-strategy approach to investing that involves investing from time to time in global equities, including UK equities. The Code is therefore relevant to some aspects of the Firm’s trading. The Firm supports the objectives that underlie the Code; the Firm has chosen to commit to the Code. The Firm invests in a variety of asset classes and a variety of jurisdictions globally, not all the funds will have relevance to the code but those that do, will support it.

The trading strategies of the Firm in relation to engagement with issuers and their management are determined per the portfolio manager of each fund and in some cases investment committees. A number of investments at this time are on a quantitative or systematic model and traded on a short term basis as part of a trading strategy; such investments will not be subject to the code.

For the funds managed by some of our portfolio managers which do hold longer term equity positions in the United Kingdom, these funds will partake in shareholder meetings and will therefore be in meetings which may influence the management of the companies.

Sturgeon Ventures LLP

Reg No: OC319614

VAT No: 884562876