UK Stewardship Code

FCA Conduct of Business Rule 2.2.3R requires FCA authorised firms to either disclose their compliance or explain their non-compliance with the principles set out in the UK Financial Reporting Council’s Stewardship Code (the “Code”). Kvasir Technologies Ltd (“Kvasir” or “the Firm”) is operating as an Appointed Representative acting under the permissions of a Principal Firm, G10 Capital Limited which is authorised and regulated by the FCA in the United Kingdom and therefore subject to the Code. Kvasir is a systematic and quantitative asset manager which executes predominately using Direct Market Access (DMA). Accordingly, whilst the Firm supports the Code as a mechanism to promote best practice in the institutional shareholder conduct of UK listed companies, the Firm does not consider the Code or its principles to be appropriate for the funds’ investment strategy.