UK Stewardship Code Statement

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Odin Capital Management Ltd. (“Odin”) 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 several principles relating to engagement by investors in listed companies.

Odin supports the general principles of the Stewardship Code but applies investment strategies that are not centred on actively engaging with listed companies and may not align with the long-term engagement focus of the Stewardship Code. Odin uses a diverse set of investment strategies with the objective of achieving consistently high risk-adjusted rates of return which may involve short-term trades in listed securities. Odin has therefore at this time chosen not to commit to Stewardship code and make the related disclosures.