ABOUT US OUR OFFICES PEOPLE CULTURE CONTACT US JOIN US DISCLOSURE Shareholder Rights Directive II The disclosure below is pursuant to the FCA’s Conduct of Business Sourcebook, in relation to the Shareholder Rights Directive II (EU) 2017/828 (“SRD II”). SRD II applies to firms which manage shares traded on a regulated market – which includes OxFORD Asset Management (“OxFORD”) – and is concerned with how shareholder engagement is integrated within their investment strategy. OxFORD’s trading strategies are predominantly systematic, and are managed by proprietary algorithms and software, with a de minimis number of exceptions. The Firm applies computational models to financial markets, analysing a range of data and information, and exploiting relationships among financial instruments such as stocks, futures, and currencies. OxFORD has authority to vote its client’s securities and has adopted proxy voting policies and procedures. In deciding whether and how to vote, OxFORD will act in the best interests of its client. Given the nature of the firm’s trading strategies, it is OxFORD’s policy not to vote on administrative or governance matters. OxFORD is not required to vote every proxy and will exercise its right to vote proxies only where it believes the results of the vote may materially affect the value of the relevant securities. The firm does not vote in the vast majority of cases. While OxFORD supports the general objectives of SRD II, it pursues an investment strategy to which the aims of SRD II are not relevant. If the investment strategy changes so that the provisions of SRD II become relevant, OxFORD will update this disclosure accordingly. UK Financial Reporting Council’s Stewardship Code The disclosure below is pursuant to the FCA’s Conduct of Business Sourcebook, in relation to the UK Financial Reporting Council’s Stewardship Code (the “Code”). The Code sets out a number of principles relating to shareholder engagement by firms managing equity holdings in UK listed companies. OxFORD’s alternative investment strategy is described in the section titled ‘Shareholder Rights Directive II’ (above). While OxFORD supports the general objectives of the Code, it pursues an investment strategy to which the aims of the Code are not relevant. If the investment strategy changes so that the provisions of the Code become relevant, OxFORD will update this disclosure accordingly. Contact For further information on the Firm’s approach in relation to SRD II or the Code, please contact: Chief Compliance Officer +44 (0)1865 248 248 June 2019 LEGAL NOTICES PRIVACY & COOKIES MODERN SLAVERY STATEMENT DISCLOSURE © 2021 OXFORD ASSET MANAGEMENT |