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Under Rule 2.2.3R of the Conduct of Business Sourcebook of the Financial Conduct Authority (“FCA”), Aethel Partners LLP (“Aethel Partners” or “the Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to include 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, explain its considered choice based on the Firm’s investment approach.  The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.
Aethel Partners LLP is a global alternative investment firm.  Its investment approach does not focus on UK-listed companies.  As such, whilst Aethel Partners generally supports the objectives that underlie the Code, its investment strategy is not one to which the aims of the Code apply. The Firm has therefore chosen not to commit to the Code at this time.
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