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Stewardship Code

Momentum Global Investment Management (“MGIM”) offers multi-manager investment solutions via European UCITS funds, Luxembourg SICAV-SIFs and Guernsey Incorporated Cell Companies.

It also provides advisory services to institutional clients.

As a result of its investment approach, MGIM does not research or directly invest in listed UK equities. MGIM researches the investment styles and performance of other fund managers, and purchases shares or units in their collective investment schemes to construct bespoke portfolios for clients. This investment approach is referred to as “multi-manager” within the financial industry.

As well as investing in funds, MGIM identifies and selects sub-investment managers which it employs to manage segregated portfolios, as a component with our funds. The Investment Management Agreement between the parties stipulates that the sub-investment manager must disclose all voting to MGIM, and vote in what it believes to be the best interests of the portfolio. MGIM reserves the right to instruct the sub-investment manager to vote for the preference it necessitates.

MGIM is committed to responsible ownership of listed equities and stewardship in the exercise of proxy voting decisions. However, the requirements of the Stewardship Code are not directly relevant to MGIM due to the nature of the multi-manager investment approach, as it is not able to influence the decisions of UK corporate equities to which the Stewardship Code applies.