UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Asperatus Capital LLP (the "Firm") is required to include on this website 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, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance. We have detailed below the reasons why the firm has chosen not to commit to the Code.

The Firm pursues a multi-strat strategy that involves it investing in global equities, including UK equities. The Code is therefore relevant to some aspects of the Firm's trading. While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The Firm invests in a variety of asset classes and in a variety of jurisdictions globally. The approach of the Firm in relation to engagement with issuers and their management is determined globally. The Firm takes a global approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

For further information on the Firm’s approach contact: compliance@asperatuscapital.com

UK Shareholder Rights Directive (SRD II)

SRD II aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on a regulated market. For these purposes a regulated market isa UK RIE (or a market outside the United Kingdom which meets comparable requirements and where the financial instruments dealt in are of a quality comparable to those in a regulated market in the United Kingdom). It came into effect on 10 June 2019.

The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:

• Publish their shareholder engagement policy (or explain why they don't have one) – COBS 2.2B.5R.
• Make annual public disclosures relating to the implementation of their shareholder engagement policy– COBS 2.2B.5R.
• Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R

Asperatus Capital LLP (the “Firm”) generally adopts a systematic quantitative approach to trading strategies. The Firm does not engage in proxy voting, and the ability to exercise voting rights in relation to any instruments plays no part in and has no bearing on the Firm’s strategies. While the Firm supports the general objectives of SRD II, it pursues investment strategies to which the aims of SRD II are not relevant. Therefore, the Firm has chosen not to implement an engagement policy. If the investment strategies change so that the provisions of SRD II become relevant, the Firm will amend this disclosure accordingly.

Asperatus Capital