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UK Stewardship Code and UK Shareholder Engagement Disclosure

Eisler Capital (UK) Limited (“Eisler Capital”) is regulated by the Financial Conduct Authority (the “FCA”) in the United Kingdom. As such, it is required by the FCA Conduct of Business rule 2.2.3R to disclose its compliance 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 is a voluntary code that sets out a number of principles relating to engagement by investors with UK equity issuers.

Additionally, in accordance with the UK’s implementation of the EU’s 2nd Shareholder Rights Directive, Eisler Capital is required by the FCA Conduct of Business rule 2.2B (the “Shareholder Engagement Rules”) to develop and publicly disclose its shareholder engagement policy; alternatively, it must provide a clear and reasoned explanation of why it has chosen not to adopt such a policy.

Eisler Capital allocates capital to multiple strategies across global asset classes, investing in a diversified portfolio including, but not limited to, global interest rate and fixed-income instruments, credit instruments, currencies, commodities, equities, and their associated derivatives. Single-name equity investments made by Eisler Capital are not taken with a view to engage actively with, or influence, the company’s management. For this reason, while Eisler Capital supports the objectives that underlie the Code, it does not consider the Code to be applicable to its investment strategy, and as such, does not consider it appropriate to commit to the Code.

Eisler Capital has also considered the requirements of the Shareholder Engagement Rules carefully and has concluded that it would not be appropriate for it to develop a shareholder engagement policy at this time for the reasons stated above. Accordingly, Eisler Capital does not consider shareholder engagement to be an integral part of its investment process or its investment strategy. Eisler Capital will continue to evaluate any future developments in its approach and its investment strategy, and may update this statement from time to time.