Square Mile Investment Services Limited Disclosures

Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Square Mile Investment Services Limited (the "Firm") is required to include on this website 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, its alternative investment strategy. The Code sets out a number of principles relating to engagement by investors with UK equity issuers, as follows:

The seven principles of the Code are that institutional investors should:

• Publicly disclose their policy on how they will discharge their stewardship responsibilities;
• Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
• Monitor their investee companies;
• Establish clear guidelines on when and how they will escalate their activities;
• Be willing to act collectively with other investors where appropriate;
• Have a clear policy on voting and disclosure of voting activity; and
• Report periodically on their stewardship and voting activities.

The firm is only involved in the reallocation of portfolios of collective investment schemes and as such this is not relevant.

Last reviewed December 2019.

Shareholder Rights Directive

SRD II aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on EEA regulated markets and comparable regulated markets outside the EEA. It came into effect on 10 June 2019.

The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:

• Publish their shareholder engagement policy (or explain why they don't have one) – COBS 2.2B.5R.
• Make annual public disclosures relating to the implementation of their shareholder engagement policy, from 10 June 2020 – COBS 2.2B.5R.
• Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R.

Square Mile Investment Services Limited does not manage investments in shares which are traded on an EEA regulated market, or on a comparable regulated market outside the EEA, and so the SRD II rules do not apply to it. Therefore, we have not developed a shareholder engagement policy and nor are we required to make the disclosures outlined above.

Last reviewed December 2019.

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