Under Rule 2.2.3R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, Rye Bay Capital LLP (“Rye Bay 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 Stewardship Code (the "Code") or, where it does not commit to the Code, explain its considered choice based on the Firm’s investment approach.

The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies. The Firm pursues a European strategy that includes investing in UK equities. The Code is therefore relevant to some aspects of the Firm's trading. Whilst the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code.

The Firm employs a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

The Firm is considering its position with respect to obligations under the Shareholder Rights Directive and will in due course publish an appropriate disclosure regarding its policy, related processes, and engagement with investee companies (as per Conduct of Business Sourcebook 2.2B.5 R).