UK STEWARDSHIP CODE

FCA Conduct of Business Rule 2.2.3R requires FCA authorised firms to either disclose their compliance or explain their non-compliance with the principles set out in the UK Financial Reporting Council's Stewardship Code (the "Code"). Graticule Asset Management Asia (UK) Limited (“GAMA” ) is authorised and regulated by the FCA in the United Kingdom and therefore subject to the Code. 

GAMA, along with its affiliates, manages assets across a number of global alternative strategies, but does not take an activist shareholder approach. Accordingly, although GAMA supports the Code as a mechanism to promote best practice in the institutional shareholder conduct of UK listed companies, it does not consider the Code or its principles to be appropriate or relevant for the funds’ investment strategies.