LACM Global, Ltd.

UK Stewardship Code

Under Rule 2.2.3R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, LACM Global, Ltd (“LACM” 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 relating to engagement by investors in UK-listed companies.

Currently LACM does not undertake investment management activities, however should it do so in the future, the Firm plans to delegate the majority (if not all) of its investment management duties to its U.S. parent, Los Angeles Capital Management and Equity Research, Inc. (“Los Angeles Capital”), an SEC registered investment adviser. As a result LACM will not being involved in the investment of UK listed companies on behalf of its clients and will not formally engage with investee companies. Los Angeles Capital runs a global equity strategy funds and takes a consistent global approach in all of the jurisdictions in which it invests. Consequently, LACM does not consider it appropriate to commit to commit to the Code at this time.

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