Under Rule 2.2B of the Financial Conduct Authority’s Conduct of Business Sourcebook, Orion Resource Partners (UK) LLP (“ORP UK” or the “Firm”) is required to develop and disclose an engagement policy as described in the Shareholders Rights Directive (“SRD II”) or provide a clear and reasoned explanation of why it has chosen not to develop and adopt a shareholder engagement policy.

ORP UK has chosen not to adopt a policy in line with the requirements of the SRD II, as it considers that it has an investment strategy that is not commensurate with the outcomes sought thereunder. Moreover, the Firm ensures that its clients are regularly and routinely apprised of the investment strategies employed by ORP UK. As such, it is felt that its clients would not expect the Firm to achieve compliance with the core requirements of SRD II.

ORP UK provides investment management services to clients which pursue strategies involving a diversified portfolio of investments on a global basis with a variety of timeframes. ORP UK may, in certain instances, engage with representatives of the companies in which funds are invested, through calls, correspondence and meetings. These interactions allow for fundamental research, due diligence and ongoing financial monitoring of investments. However, ORP UK does not seek active policy engagement as part of its fundamental investment strategy. Although ORP UK supports the objectives of SRD II, it has determined that its fundamental investment strategy is not compatible with shareholder engagement activities.