United Kingdom Stewardship Code

Last Updated: April 24, 2023

The UK's Financial Reporting Council's Stewardship Code (the “Code”) is a voluntary code that defines stewardship as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.” The Code proposes measures to increase the level of transparency surrounding institutional investors' activities as shareholders for the benefit of the investors' underlying clients. The Code is expected to be applied on a comply or explain basis.

Further, Rule 2.3R of the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (“COBS”) requires an FCA authorized firm to disclosure the nature of its commitment to the Financial Reporting Council's (“FRC”) Code.

The Code comprises twelve Principles that can be summarized as follows:

Purpose and governance

1. Purpose, strategy and governance

2. Governance, resources and incentives

3. Conflicts of interest

4. Promoting well-functioning markets

5. Review and assurance

Investment approach

6. Client and beneficiary needs

7. Stewardship, investment and ESG integration

8. Monitoring managers and service providers

Engagement

9. Engagement

10. Collaboration

11. Escalation

Rights and Responsibilities

12. Exercising rights and responsibilities

Greyhound Capital Management LLP’s Position on the Code

Greyhound Capital Management LLP (“Greyhound” or the “Firm”) primarily pursues a strategy that involves private market investments. Although Greyhound supports the objectives that underly the Code, the provisions of the Code are not considered to be proportionate to the activities undertaken by the Firm and we do not believe that it is in our investors best interest for Greyhound to take on the additional burden associated with compliance with the Code.

This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm's position change we will review our commitment to the Code and make appropriate disclosure at that time.