Chorus Capital Management Limited

COMMITMENT TO THE UK STEWARDSHIP CODE

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Chorus Capital Management Limited (“CCML” 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.

CCML invests in a variety of credit opportunities in Europe and exposure to UK-listed companies is limited. Therefore, whilst CCML generally supports the objectives that underlie the Code, the nature of its investment strategy does not allow it to formally engage with investee companies through voting rights. The Firm has therefore chosen not to commit to the Code at this time.