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”). Kyma Capital Limited (“Kyma” or “the Firm”) is authorised and regulated by the FCA in the United Kingdom and therefore subject to the Code. Kyma manages assets in an interventionist manner and may occasionally take an activist shareholder approach. 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.