Stewardship Code Disclosure

Under Rule 2.2.3R of the Financial Conduct Authority’s Conduct of Business Sourcebook, XHE Capital is required to disclose whether or not it commits to the UK Financial Reporting Council’s Stewardship Code (the Code). The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. XHE Capital’s engagement with UK equity issuers is extremely limited and typically indirect. The Code is therefore not materially relevant to XHE Capital’s investment activities. While XHE Capital generally supports the objectives that underlie the Code, XHE Capital has chosen not to commit to it at this time.