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Shareholder Rights Directive

Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”), 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.6R of the Financial Conduct Authority “FCA” Handbook, or disclose a clear and reasoned explanation of why it has chosen not to do so.

UK Stewardship Code

COBS 2.2.3R of the FCA Handbook requires an FCA authorised firm to disclose the nature of its commitment to the Financial Reporting Council’s (“FRC”) UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. Adherence to the Code is voluntary.

Disclosure by KLI Asset Management LLP (“KLI”) on SRD II and the Stewardship Code

KLI does not maintain an engagement policy nor does it commit to the Code. KLI is a multi-commodity investment manager with an emphasis on directional trading and portfolio diversification. As such has no basis for monitoring, engaging with, or otherwise acting in a stewardship capacity with investee companies or other investment assets. It considers that any such activity would be inconsistent with the Firm’s investment strategy and would not, in the Firm’s opinion, benefit its clients.

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