Engagement Policy

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business sourcebook, Russell Clark Investment Management Limited (the "Firm", “RCIM”) is required to publicly disclose 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 set 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.

The Firm pursues long/short equity strategies that involve investment in global equities. Investment strategies and trading decisions are based on macro events, investment themes, publicly available information about the company, and market conditions. The Firm does not pursue an activist strategy; it predominantly employs a short strategy and where it does take long positions, these investments are typically less than 1% of the listed company’s shares. RCIM does not actively engage in dialogue with the companies it invests in or their stakeholders, it does not try to actively influence management decisions through voting strategies, nor does it coordinate with other shareholders. Therefore, whilst RCIM generally supports the objectives that underlie the Code and the Directive, it has determined that compliance with the Code is not relevant because of the investment strategies it employs on behalf of its clients.

Commitment to the Shareholder Rights Directive

Under Rule 2.2b.5R of the FCA’s Conduct of Business sourcebook, RCIM is required to publicly develop and disclose an engagement policy in accordance with the Shareholder Rights Directive (“SRD II”) or disclose a clear and reasoned explanation of why it has chosen not to comply with the SRD II.

RCIM has considered carefully whether it wishes to adopt an engagement policy and to make the disclosures required under SRD II and has decided not to comply with the SRD II. RCIM pursues long/short equities strategies in listed global equities and invests via equity and derivative positions, the latter of which may not infer voting rights. RCIM has a global macro investment strategy and does not take sufficiently material positions in companies in terms of size or voting power for RCIM to actively engage with the investee companies. The Firm’s investment strategy and execution of the strategy do not embrace significant engagement with investee companies, and RCIM does not consider that its Clients expect such engagement. On that basis, whilst the Firm generally supports the objectives of SRD II, it has decided not to adopt a separate engagement policy under SRD II as it does not consider it appropriate, or practicable, to adopt an approach solely relating to a specific region or jurisdiction.