Stewardship Code Statement

2012 STEWARDSHIP CODE STATEMENT

Version control: 01/09/2021

1. Stewardship Code Statement

The principles of the UK Stewardship Code (the Code) are:

Principle 1: Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

Principle 2: Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.

Principle 3: Institutional investors should monitor their investee companies.

Principle 4: Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.

Principle 5: Institutional investors should be willing to act collectively with other investors where appropriate.

Principle 6: Institutional investors should have a clear policy on voting and disclosure of voting activity.

Principle 7: Institutional investors should report periodically on their stewardship and voting activities.

 2. Statement of Commitment

Sturgeon Ventures LLP (the “Firm”) pursues a multi-strategy approach to investing that involves investing from time to time in global equities, including UK equities. The Code is therefore relevant to some aspects of the Firm’s trading. The Firm supports the objectives that underlie the Code; the Firm has chosen to commit to the Code. The Firm invests in a variety of asset classes and a variety of jurisdictions globally, not all the funds will have relevance to the code but those that do, will support it.

The trading strategies of the Firm in relation to engagement with issuers and their management are determined per the portfolio manager of each fund and in some cases investment committees. A number of investments at this time are on a quantitative or systematic model and traded on a short term basis as part of a trading strategy; such investments will not be subject to the code.

For the funds managed by some of our portfolio managers which do hold longer term equity positions in the United Kingdom, these funds will partake in shareholder meetings and therefore will therefore be in meetings which may influence the management of the companies.

Sturgeon Ventures LLP

Reg No: OC319614

VAT No: 884562876