Shareholder Rights Directive II (“SRD II”)

Alphidence Capital Limited  (the “company”) is making this statement of Compliance Rule 2.2B.5R of the FCA’s Conduct of Business Sourcebook (“COBS”). COBS requires every FCA authorised investment manager that invests in listed equities to:

(1) develop and publicly disclose on its website, a copy of its engagement policy which includes the content specified in the amended EU Shareholder Rights Directive (Directive 2007/36/EC); and
(2) publicly disclose on an annual basis how its engagement policy has been implemented, including a general description of its voting behaviour, an explanation of its most significant votes and details of its use of the services of proxy advisors,

Alphidence Capital Limited (the “company”) considers that an engagement policy is not appropriate to the investment strategies pursued to which we provide investment services. The company has chosen not to comply on the basis that the company and its strategies do not invest directly in equities at the present time. The company will keep its position under review and will update its statement accordingly, if required.