SOTHIC CAPITAL MANAGEMENT LLP

††††† Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FSA's Conduct of Business Sourcebook, Sothic Capital Management LLP (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 is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers.  Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.

The Firm pursues a event driven strategy that involves it investing in European equities, including UK equities. The Firmís strategy is active and involves a wide variety of investment products and timeframes. Therefore, while the Company supports the principles of the Code, it does not consider it appropriate to conform to the Code at this time. The Firm invests in a variety of asset classes and in a variety of jurisdictions across Europe.††††††††††