Gladstone

UK Stewardship Code

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Gladstone Capital Management LLP’s commitment to the UK Stewardship Code

Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA”) Conduct of Business Sourcebook, Gladstone Capital Management LLP (“Gladstone” 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 relation to engagement by investors in UK-listed companies.

Gladstone invests in a variety of asset classes in a variety of jurisdictions globally and exposure to UK-Listed companies is relatively limited. Therefore, whilst Gladstone generally supports the objectives that underlie the Code, the nature of its investment strategy do not allow it to formally engage with investee companies through voting rights. The Firm has therefore chosen not to commit to the Code at this time.

For further information on the Firm’s approach contact: Justine Ayling-Kenrick – jak@gladstone-management.com