At Eisler Capital (“Eisler”) we understand that our ability to create and protect long-term value for our investors relies on how we operate as a business.

Our philosophy, which is one of collaboration, integrity, transparency and meritocracy, defines our purpose and the values and behaviors we expect from each other every day. It underpins all our actions and interactions – both internal and external – and informs our decision-making. This statement is a discussion of topics relevant to responsibility at Eisler Capital.

Governance

Eisler believes that operating with transparency and adhering to all applicable laws and regulations is critical to our reputation as a trustworthy and fair partner. We are committed to the highest standards of corporate governance, business integrity and professionalism in all our activities. We take an integrated approach to governance, ensuring material factors are appropriately embedded within our existing corporate governance framework, processes and structures.

Governance Model

Our governance model is structured and agile by design. This is overseen by our active and engaged personnel who have the skill and experience to properly supervise our policies and protocols and to enhance transparency and good governance. In addition, several entities within our corporate structure, have majority independent board of directors.

We keep an evolving view of those areas that are at risk and maintain an open and transparent view of incident management. We seek to identify and resolve or remediate all issues as soon as possible after they come to light. Our whistleblowing policy and hotline is a key function to ensuring this happens.

Regulation and Ethics

Eisler hardwires sound governance principles through our organisation with compliance with both the Code of Ethics and Compliance Manual and by leveraging our annual compliance training. The training program includes code of ethics and other internal policies, data protection and privacy laws, fiduciary duties and conflicts of interest, amongst others, in addition to an initial on-boarding training when an employee joins Eisler.

Eisler also undertakes a quarterly attestation program during which employees must attest to having read and understood key elements of the Code of Ethics and other additional attestations as applicable. The annual appraisal process also forms a key point at which adherence to standards of conduct are assessed and Compliance’s monitoring, testing and surveillance also assess adherence by staff to conduct obligations.

We believe in transparent and open communication with investors and stakeholders, and maintain an open and constructive dialogue with regulators globally. We endeavor to respond to all queries raised with honesty and integrity and in a comprehensive and timely manner, and ensure any concerns are raised with our regulators on a proactive basis. Eisler is also a member of industry groups including the Alternative Investment Management Association (AIMA) and the Managed Funds Association (MFA) in order to improve industry practices and promote high standards.

Social

Eisler believes that the personal and professional growth of our people is the ultimate driver of our success and the reason we value collaboration and continuous development. We have a results-driven and collegial culture that rewards transforming ideas into actions and succeeding with integrity.

Diversity, Equity & Inclusion (DE&I)

Eisler sees tremendous value in having a well-rounded, inclusive workplace — one that is reflective of the investors we serve, the businesses and other stakeholders with whom we engage, and the communities in which we live and conduct business. We believe that it leads to more innovative thinking and better problem-solving that aligns to our philosophy and allows us to create value across our organization.

Embracing the diversity of backgrounds, perspectives, and experiences of our employees is a business priority at Eisler. Eisler’s Equal Opportunities and Anti-Harassment policies are included in the Employee Handbook and are designed to enable us to identify and prevent discrimination and harassment and to develop and maintain good employment practices Anti-harassment training is mandatory for all staff globally.

We also strive to ensure diversity, equity and inclusion are front of mind at every stage of the recruitment process. We utilise a diverse internal recruitment panel to help bring diversity, challenge, and an objective lens to our decision-making around new hires. We also work closely with our recruitment partners to ensure that the best candidates regardless of background are highlighted to us.

We recognise the boundaries to progression and entry into our industry and focus our efforts on addressing this where possible. We are developing important partnerships with third party organisations aimed at gaining access to diverse talent and support efforts to mentor under-represented groups. We recognise that access issues prohibit many from gaining experience in what we do which has caused us to offer a salaried intern program designed to provide insight to those from the broadest possible backgrounds.

Supporting our Employees

Delivering long term, sustainable performance means recognising the skills and knowledge needed in the future will be different from today. We aim to provide our colleagues with the capabilities and opportunities that will allow them to succeed in the long term. Our focus on growth and development enables our team to pursue opportunities both in and around the business that furthers their careers.

A workforce that is confident and resilient in its physical, mental, and financial wellbeing is key to our ongoing success as an organisation. The focus of our benefits package is on preventive care in order to help our staff navigate the myriad of challenges they and their families may face.

Environment

Eisler continues to explore our commitments in this space. We aim to contribute to this through sustainable procurement, and we have begun the process of collecting GHG emissions data from our own operations. As we set up offices in new locations, we seek further opportunities to advance our efforts and implement environmentally sustainable practices globally.

Ed Eisler | Sam Wisnia | Chris Milner

January 2024