Disclosures

Commitment to the Financial Reporting Council’s Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, JJJ Capital Management LLP ( “JJJ Capital”) is required to disclose the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code that sets out a number of principles relating to engagement by investors with UK equity issuers. 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 non-compliance.

While JJJ Capital generally supports the objectives that underlie the Code, JJJ Capital has chosen not to commit to the Code because we do not consider it to be relevant JJJ Capital’s trading strategies.

Statement on modern slavery and human trafficking

Introduction

This statement is made by JJJ Capital Management LLP (“JJJ Capital”) pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”) and in respect of the current financial year.

Business and Organisational Structure

JJJ Capital is an alternative investment fund manager which pursues a global macro strategy investment approach and strategies underpinned by a forensic understanding of inflation drivers and their broader impact on risk assets. JJJ Capital’s registered address is JJJ Capital Management LLP, 6th Floor, 1 Curzon Street, London, W1J 5HA, United Kingdom. JJJ Capital is a UK limited liability partnership that is authorised and regulated by the UK Financial Conduct Authority to carry on investment management activities ( Reference number 991146).

Supply Chain

JJJ Capital’s business is operated by a highly skilled workforce with a limited supply chain. Accordingly, JJJ Capital considers that there is a low risk of slavery and human trafficking within its business when compared, for example, to a business that manufactures or sells goods.

JJJ Capital expects all third-party providers to adhere to all applicable laws in conducting their businesses and to operate a fair and ethical workplace for their staff. JJJ Capital will contact its key suppliers from time-to-time to reinforce JJJ Capital’s position that it will not tolerate modern slavery or human trafficking within its supply chain.