Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, CDAM (UK) Limited (“CDAM”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include 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, explain its considered choice based on its investment approach.

The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.

CDAM’s investment strategy is opportunistic and follows a fundamental, value-oriented approach. CDAM has acquired and liquidated investments across a wide spectrum of asset types, investment strategies, market sectors, market cycles and industries.

This spectrum includes, but is not limited to, UK-listed companies and therefore the Code is relevant to some aspects of CDAM’s investment activity.

While CDAM generally supports the objectives that underlie the Code, CDAM has chosen not to commit to the Code. CDAM invests in a variety of asset classes and in a variety of jurisdictions globally. CDAM’s approach in relation to engagement with issuers and their management in all of the jurisdictions in which investments are made is determined on a case-by-case basis.

Consequently, CDAM does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.