Bivouac Capital Investment Management

UK Stewardship Code

Under COBS 2.2 of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the above Code, which was published by the Financial Reporting Council ('FRC') in July 2010.

The Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on a "comply or explain" basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

Bivouac Capital LLP supports the objectives that underlie the Code, but does not currently comply with the Code since our investment strategy involves only Futures and as such we do not currently invest in listed companies in the UK. Should any of these factors change, we will review our commitment to the Code at that time and make an appropriate disclosure. For further details please contact Richard Adams.