SRD II Disclosure

September 2023
Palliser Capital (UK) Ltd
(“Palliser” / the “Firm”)

Palliser has chosen not to comply with the requirements of the Shareholder Rights Directive (“SRD II”) regarding the adoption and maintenance of an engagement policy, as it considers that it has an investment strategy that is not commensurate with outcomes sought thereunder. Moreover, the Firm ensures that its clients are regularly and routinely apprised of the investment strategies employed by Palliser. As such, it is felt the clients would not expect the Firm to achieve compliance with the core requirements of the SRD II.

Given the Firm’s investment strategy, there would be circumstances under which it would be disadvantageous to the Firm’s investors to publicly disclose its policy in relation to shareholder engagement. The Firm does maintain a proxy voting policy which is available to all investors upon request. More generally, it should be noted that the Firm takes a value-based, diligent approach to event-driven investing, meeting with the management of companies routinely as part of its investment process in order to attempt to maximise value on behalf of the Firm’s investors. Further, the Firm’s exercise of voting (or other) rights forms part of the investment process of each portfolio and such votes are considered on a case-by-case basis.