Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook (“COBS”), Skerryvore Asset Management, the trading name of BennBridge Ltd the "Firm", to the extent that it is managing investments for a professional client (as defined by the FCA), is required to disclose on its website 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 the rationale for this choice based on the Firm’s investment approach.

The Code is a voluntary code aimed at enhancing the quality of engagement by asset managers and owners with corporate issuers and sets out 12 principles relating to how investment and stewardship is integrated, including environmental, social and governance (collectively, “ESG”) issues.

The UK Stewardship Code sets out, through 12 principles, the best practice in engaging with investee companies which the Financial Reporting Council (“FRC”) believes institutional investors, by which is meant asset owners and asset managers with equity holding in UK listed companies, should use as guidance. The principles can be summarised as follows:

Purpose and governance

01. Purpose, strategy and governance

02. Governance, resources and incentives

03. Conflicts of interest

04. Promoting well-functioning markets

05. Review and assurance

Investment approach

06. Client and beneficiary needs

07. Stewardship, investment and ESG integration

08. Monitoring managers and service providers

Engagement

09. Engagement

10. Collaboration

11. Escalation

Rights and responsibilities

12. Exercising rights and responsibilities

Consequently, while the Firm generally supports the objectives that underlie the Code, the provisions of the Code are not considered to be appropriate to the activities currently undertaken by the Firm. The Firm has therefore chosen not to commit to the Code at this time. If the Firm’s activities change in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.

Shareholder Rights Directive II

Under COBS 2.2B.5R, the Firm is required to either develop and publicly disclose an engagement policy that meets the requirements of the Shareholder Rights Directive (“SRD II”) or to publicly disclose a clear and reasoned explanation of why it has chosen not to develop an engagement policy that meets the SRD II requirements.

The Firm’s engagement & proxy voting policy and guidelines are set out here.

This policy document summaries the approach taken by the Firm with regards to investee engagement and how the requirements of SRDII are met, and covers all client funds and segregated accounts, collectively the ‘clients’, for which the Firm service as investment manager or adviser and had voting discretion over the client’s assets.

As long-term investors with a fiduciary duty to be responsible stewards of its clients’ capital the Firm looks to maximise returns and in doing so address any sustainability risks to overall performance from investee companies.

Please click here to access Skerryvore’s 2024 Sustainability Review, which provides greater insight into how the investment team have been thinking about and assessing sustainability issues for the businesses that have been considered, invested in, and engaged with during the 12 months to 30 June 2024 (the “period”). Page 22 of the 2024 Sustainability Review sets out the corporate engagements during the period.

For further details on any of the above information please contact either clients@skerryvoream.com or compliance@skerryvoream.com

Accessing Website as an Institutional Investor The information on this website is exclusively made available to and directed at professional investors, as defined by the UK Financial Conduct Authority (FCA), including ‘investment professionals’ within the meaning of Article 19(5) of the Financial Services and Markets Act (Financial Promotion) Order 2005 or Article 14(5) of the Investment Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001(“Professional Investors”) who are located in the United Kingdom. Professional Investors include financial institutions authorised and regulated by the FCA, such as credit institutions and investment firms, as well as certain other categories of investor, set out in full in COBS 3.5 of the Conduct of Business Sourcebook in the FCA Handbook. The information on this website is not intended for and should not be relied on by retail investors or investors located outside of the United Kingdom. By electing to submit you are confirming you are a Professional Investor located in the United Kingdom and you agree to the Terms and Conditions of Use. Use of Cookies This website uses cookies. By clicking submit you consent to the storing of cookies on your device to enhance the navigation, analyse site usage, and assist in our marketing efforts. Read our Cookies Policy to find out more. Disclaimer Effective August 1, 2024, following regulatory approval, from the UK’s Financial Conduct Authority, BennBridge Ltd (“BennBridge”) (Company Number: 10480050) became a wholly owned subsidiary of Skerryvore AM LLP (“Skerryvore”). Collectively, BennBridge and Skerryvore are referred herein as the Firm. The Firm is based at 45 Charlotte Square, Edinburgh EH2 4HQ in the United Kingdom. The registered office of the Firm is Windsor House, Station Court, Station Road, Great Shelford, Cambridge CB22 5NE. Skerryvore Asset Management, the new trading name of BennBridge, is an investment manager authorised and regulated by the Financial Conduct Authority in the UK (FRN: 769109) and is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”) (registration of an investment adviser does not imply any level of skill or training). The information on this website has not been approved or verified by the FCA, the SEC or by any US state securities authority. The value of investments will fluctuate, which will cause fund prices to fall as well as rise and you may not get your original investment back; the products on this website carry a degree of risk. Specific risks are highlighted on the respective investment pages within the site. The information provided herein is provided in good faith and without any warranty or, representation as to accuracy or completeness. Information and opinions presented in this material have been obtained or derived from sources believed by the Firm to be reliable and the Firm has reasonable grounds to believe that all factual information herein is true as of the date indicated. Nothing on this website constitutes investment advice, recommendation, or an offer of any services or products for sale and it is not intended to provide a sufficient basis on which to make an investment decision. The information contained on this website may not be treated as an offer or solicitation:

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