Stewardship Code Compliance Statement

Petrus Advisers is an investment management company established in 2009. The UK Stewardship Code (‘the Code‘) is relevant to certain key aspects of our business. In keeping with the aims of the Code, we seek to monitor the quality of our engagement with the companies in which we invest to help improve long-term returns for our clients. We generally support the aims and principles of the Code. If you have any questions regarding this statement of our policy or our approach to the Code, please contact our Compliance Officer.

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

This policy is published so that clients and investee companies are aware of the way in which we integrate stewardship activities into our investment process. We have outlined below each of the principles of the Code and how we comply with them.

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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.

We maintain a strict policy on managing conflicts of interest in order to ensure that our decisions are taken wholly and solely in the interests of our clients. In compliance with FCA rules, we have procedures designed to ensure that all potential and actual conflicts are identified, evaluated, managed, monitored and recorded. All reasonable steps are taken to prevent conflicts of interest. A copy of our Conflict of Interest Policy is available upon request from our Compliance Officer and forms part of our Employee Manual.

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Principle 3: Institutional investors should monitor their investee companies.

Comprehensive ongoing fundamental research and monitoring of investee companies is essential to our investment process. We utilise various research, monitoring and support tools to meet this principle. We have regular contact with the companies in which we invest and aim to frequently interact with the relevant management teams, in addition to reviewing press releases, industry information, research reports and other relevant sources of information. We do not wish to be made insiders as it would restrict us from any transactions in the stocks of relevant companies. We expect investee companies and their advisers not to convey information to us that could affect our ability to deal in the shares of the company concerned, without prior agreement. We maintain a log on insider relevant information and ensure timely blacklisting of all trading activities in case of the receipt of insider information, whether intended and subject to a non-disclosure agreement or if provided unintended or by mistake by the company during our due diligence.

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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.

Our investment strategy is to build effective relationships with the companies in which we invest. When requested, we share our opinion on strategic or tactical options a management may be considering. Nevertheless, we may hold meetings from time to time with companies to discuss issues and will always share our view on strategy.

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

We consider each vote on an individual basis. We may communicate with other shareholders regarding a specific proposal but will not agree to vote in concert with another shareholder without approval from our Compliance Officer, nor do we wish to be made insiders in relation to the intentions of other investors. However, there are instances where Petrus Advisers may be willing to be approached by other investors. For example, we will consider working with like-minded investors with regard to a specific situation, where we believe that coordinated action would be beneficial to shareholders and our clients.

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

All our clients accept our discretion with regard to voting decisions. As such we will not vote proxies in investee companies. It is not our usual policy to attend General Meetings in case that we support management´s strategies entirely. When voting, we consider the recommendation of management but will not support this position if we believe that it is not in the best interests of the company’s shareholders. Due to underlying client confidentiality and for investment strategy reasons, we will not normally publicly disclose voting actions at a detailed level. Upon request from a client or as required by law or regulation, we will disclose how we exercised voting rights.

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

This Stewardship Code Disclosure will be reviewed and updated when appropriate. As stated above, upon request from a client or as required by law or regulation, we will disclose how we exercised voting rights on behalf of the client in relation to specific companies.Petrus Advisers is an investment management company established in 2009. The UK Stewardship Code (‘the Code‘) is relevant to certain key aspects of our business. In keeping with the aims of the Code, we seek to monitor the quality of our engagement with the companies in which we invest to help improve long-term returns for our clients. We generally support the aims and principles of the Code. If you have any questions regarding this statement of our policy or our approach to the Code, please contact our Compliance Officer.