UK Regulatory Disclosure

Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Aperture Investors UK, Ltd (“Aperture UK”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s UK Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code published in July 2010 and updated in September 2012, and sets out a number of principles relating to engagement by investors with UK equity issuer to exercise their stewardship responsibilities. The Code is applied on a “comply or explain” basis.

Aperture UK pursues a number of different investment strategies which have a very limited exposure to UK equities for which there is not any engagement with issuers in which the funds invest and their management. As a consequence the Code is not perceived as relevant to Aperture UK’s trading and therefore Aperture UK has chosen not to commit to the Code. We are considering Stewardship issues on a case-by-case basis when and if relevant, making bespoke decisions in the best interests of investors. Should an investment strategy change in such a manner that the provisions of the Code become relevant, Aperture UK will reconsider its position under the Code.

Shareholder Engagement Disclosure

Aperture UK is reviewing the final requirements under the FCA Shareholder Engagement rules which came into force on 10 June 2019 and is considering whether it will develop and publicly disclose an Engagement Policy or will publicly provide an explanation as to why Aperture UK has chosen not to comply with the requirements. Full details will be made available on this website once finalised.

Pillar III disclosures

As part of the Capital Requirements Directive, introduced by the European Union in 2007, regulated firms have a requirement to publish a document describing the risks they face in their normal course of business, alongside a description of the capital held to support the business.

Pillar 3 complements the minimum capital requirements (Pillar 1) and the supervisory review process (Pillar 2), and its aim is to encourage market discipline by developing a set of disclosure requirements. These allow market participants to assess key pieces of information on a firm’s capital, risk exposures and risk assessment processes. The third pillar greatly increases transparency and the disclosures firms must make, and is designed to allow the market and investors to have a better understanding of the overall firm risk.

A copy of the Pillar III document will be made available on the website.

RTS28 Best Execution Report

The recast MIFID and Regulation (together, “MiFID2”), and Regulatory Technical Standard 28 (“RTS 28”) (Delegated Regulation (EU) 2017/576), as implemented in the UK, requires Aperture UK to publish on its website on an annual basis:

• a list of the firm’s top 5 execution venues (including brokers) in terms of trading volumes for all executed client orders per class of financial instruments;

• a list of the firm’s top 5 execution venues (including brokers) in terms of trading volumes for all executed client orders in securities financing transactions per class of financial instruments; and

• for each class of financial instrument, a summary of the analysis and conclusions the firm draws from monitoring the quality of execution obtained on execution venues (including brokers) where Aperture UK executed all client orders in the previous year.

A copy of the RTS28 Report will be made available on the website.