Public Disclosures

STATEMENT ON THE UK STEWARDSHIP CODE

Eighteen48 Partners Limited’s (the “Company”) approach in relation to engagement with issuers and their management, is determined on a global basis.A consistent global approach is taken to engagement with issuers and their management in all of the jurisdictions in which the Company invests and, consequently, the Company does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction and feels that the Code is not appropriate to the Company’s business model.

However, whilst the Company has not made a formal commitment of compliance with the Code, its alternative investment strategy, is generally supportive of the spirit and aims of good stewardship as contained within the Code. As such, in practice, the Company would take into consideration the principles as set out in the Code.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice.Should the Company’s position change we will review our commitment to the Code and make appropriate disclosure at that time.For further details on any of the above information please contact the Company’s Compliance Officer.

STATEMENT IN RELATION TO THE SHAREHOLDER RIGHTS DIRECTIVE II

The Second Shareholder Rights Directive (“SRD”), which took effect in the UK on 10 June 2019, aims to improve shareholder engagement and increase transparency around stewardship. The Company invests in listed equities and as such we are required to disclose and make publicly available our policies on how we engage with other shareholders and the companies that we invest in, and how our strategies create long-term value.

The Company invests for the long term across all asset classes, both through funds and directly in public and private markets. We serve professional investors, sophisticated families, and institutions.

As a multi-strategy investment manager, the Company does not deal in listed equities as an integral part of its core investment strategy.  However, when holding listed equities generally the Company’s approach is to proxy vote in line with management recommendations except in exceptional circumstances. The Company considers this sufficient considering the low volume of business involving listed equities and does not otherwise consider shareholder engagement in its investment strategy.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Company’s position change we will review our commitment to SRD and make appropriate disclosure at that time.

TOP 5 EXECUTION VENUES (RTS FOR 2020)

 

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