Davide Leone and Partners Investment Company LTD

General

The information on this website is not intended to influence any party in making any investment decision and should not be considered as advice or a recommendation to make any investment. Investors must make their own investment decisions, taking into account their specific financial situation and investment objectives, based on the information in the relevant offering memorandum. Income from an investment may fluctuate and the price or value of any financial instruments may rise or fall. Past performance is not necessarily indicative of future results. Davide Leone and Partners Investment Company Ltd (the "Firm") assumes no responsibility or liability for the fairness, reasonableness, timeliness, accuracy or completeness of the information, for any viruses contained in, or attached to, this website or for any loss, damage or lost opportunities resulting from any use of this website. Any information, views, opinions or assumptions may be subject to change without notice.

Davide Leone and Partners Investment Company Ltd is authorised and regulated by the UK Financial Conduct Authority. Incorporated in England and Wales with company registration number 07523186. Registered address 9-10 Savile Row, London, W1S 3PF.

Electronic Communications

Any e-mail message you receive from the Firm (or any of its members, employees or affiliates) and/or any attachments thereto (“Message”) is confidential and intended solely for the person to whom the Message is addressed. Any use, disclosure, reproduction, modification or distribution of any such Message is strictly prohibited. If you are not the intended recipient or have received a Message in error, please notify the Firm immediately by return e-mail and destroy the Message. You should not copy, forward, distribute or otherwise use any such Message in any way. No legal privilege or confidentiality is waived or lost by any mistransmission. No representation or warranty is made, expressed or implied, by the sender or by the Firm, its members, employees or affiliates as to the fairness, reasonableness, accuracy or completeness of the information or any opinions contained in any Message. The content of any Message is provided by the individual sender and may differ from, or be inconsistent with, the views of the Firm. No reliance should be placed on any Message for any purpose. Information provided in any Message may be subject to change without notice and the Firm has no obligation to update you. Any liability for viruses is excluded to the fullest extent permitted by law. No Message shall constitute an offer to sell or the solicitation of an offer to purchase any security or investment product. Any such offer or solicitation may only be made by means of delivery of, inter alia, an approved offering memorandum. In particular, no Message is intended as marketing of any fund in any jurisdiction (including in the UK or in any other member state of the European Economic Area for the purposes of the Directive 2011/61/EU on Alternative Investment Fund Managers). Accordingly, no person in receipt of a Message or copy thereof may treat it as constituting an offer or invitation to buy or sell any investments. Messages do not constitute investment research and should not be construed as such within or outside the United Kingdom. The value of investments and any income generated may go down as well as up and is not guaranteed. Any past performance information contained in any Message is not a reliable indicator of future performance.

Privacy

In connection with correspondence and interactions with the Firm you may provide your contact details and certain other personal information. The Firm will retain and use such information to respond to your enquiry or request and, depending on the nature of your enquiry or request, may also use it to take other steps pursuant to or in connection with your enquiry or request, or use and retain it to comply with applicable legal obligations. The Firm will not disclose your personal information to third parties, save for third party IT service providers engaged to store information on its behalf, third party service providers and professional advisers where appropriate in the context of your enquiry or request, or where disclosure is required by law or regulation. The Firm will retain your information for up to seven years, save where retention is required for a longer period for legal or compliance purposes. You have the right to ask the Firm for access to and rectification or erasure of personal information or restriction of processing concerning you and the right to object to processing. You have the right to complain to the Information Commissioner about the use of your personal information

Market Soundings

Should you wish to approach the Firm in relation to a market sounding, please contact compliance@dlpartners.com

UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, an FCA authorised firm managing investments for a professional client is required to disclose a statement about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code is a voluntary code and sets out a number of principles relating to investor engagement. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their approach. The Firm, on behalf of its clients, seeks global investment opportunities pursuant to a variety of investment strategies. Investments may be made in a variety of asset classes and in a variety of jurisdictions globally. The Code may therefore be relevant to some aspects of the Firm’s business. Depending on the investment strategy, security or instrument type, corporate governance can be an important factor to take into account in the investment process. The Firm’s general approach is to exercise underlying clients’ rights as a shareholder in a manner that seeks to serve clients’ best interests, as determined by the Firm in its discretion, taking into account relevant factors, including, but not limited to, the impact on the value of the securities and the anticipated costs and benefits associated with any proposal to be put to a vote. The Firm takes a global approach to investing and, while the Firm generally supports the objectives that underlie the Code, it is not considered appropriate to commit to a particular voluntary code of practice relating to a specific jurisdiction.

Shareholder Rights Directive II

Under Rule 2.2B.5R of the FCA’s Conduct of Business Sourcebook, an FCA authorised firm investing in shares on behalf of investors is required to:

• Develop and publicly disclose on its website, an engagement policy that meets the requirements specified in the amended EU Shareholder Rights Directive (Directive 2007/36/EC); and

• Publicly disclose on an annual basis how its engagement policy has been implemented, including a general description of its voting behaviour, an explanation of its most significant votes and details of its use of the services of proxy advisors,

or, in either case, to publicly disclose a clear and reasoned explanation of why it has chosen not to comply with those requirements.

The Firm, on behalf of its clients, seeks global investment opportunities pursuant to a variety of investment strategies, and a significant part of its business may involve investments in instruments other than shares, including investments in swap positions. In these cases, opportunities for shareholder engagement are more limited than physical shareholdings (for example, a swap holder is not entitled to vote at general meetings of the issuer) and the Firm accordingly does not consider it appropriate to commit to a formal engagement policy or to publicly disclose voting behaviour or related matters. The Firm nonetheless supports the general principles of shareholder engagement and, where it is considered to be in the best interests of its investors, engages with investee companies to provide feedback on matters that are believed to impact investment performance, including on environmental, social and governance issues. Such engagement is typically conducted in the form of calls or meetings with company representatives, correspondence with company management and voting. The Firm’s position remains under review and appropriate updates to this disclosure will be made in the event of a material change in approach.

Pillar 3

Disclosures pursuant to BIPRU 11.3 are set out here.