Stewardship Code Commitment

Rule 2.2.3R of the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (“COBS”) requires an FCA authorised firm to disclose the nature of its commitment to the FRC’s UK Stewardship Code (the “Code”) or, where it does not commit to the code. Adherence to the Code is voluntary. While Alphidence Capital Limited (the “company”) generally supports the objectives that underlie the Code, the provisions of the Code are not considered to be relevant to the activities currently undertaken by the company as the investment strategies pursued by the company have a very limited exposure to equities for which there may be an engagement with the issuers. The company has therefore chosen not to commit to the Code at this time.