Shareholder Rights Directive II

Haven Cove Capital Management Limited (the “Firm”) does not comply with the requirements of the Shareholder Rights Directive (“SRD II”), as it considers that it has an investment strategy that is not commensurate with outcomes sought thereunder. Moreover, the Firm ensures that its clients are regularly and routinely appraised of the investment strategies employed by it. As such, it is felt the clients would not expect the Firm to achieve compliance with the core requirements of the SRD II.

The Firm manages a global macro investment strategy, and therefore, listed equities are unlikely to be held for long periods of time as a proxy to the market or a sector. As such we do not consider that it would be constructive for the Firm or its investee companies if it were to actively engage with them on a consistent basis.