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FCA  authorised firms are required to make a public disclosure in
relation to the nature of their commitment to the Stewardship Code
("Code") published by the Financial Reporting Council ("FRC") in July
2010. The Code aims to enhance the quality of engagement between
institutional investors and the companies they invest in with the
intention of improving long term returns for shareholders and the
efficient exercise of governance responsibilities. The FRC recognises
that not all parts of the Code will be relevant to all institutional
investors and that smaller institutions may judge some of the principles
and guidance to be disproportionate. Where firms choose not to comply
with certain aspects of the Code it must state explain why not and, in
general terms, its alternative investment strategy.

Platinum Capital Management Ltd ("the Firm") provides investment
management services to a number of funds that utilise a variety of
strategies. The Firm is involved in investing, on behalf of these funds,
in equities issued in, but not limited to, the following jurisdictions:
EU, Asia, and North America. The Code is therefore applicable to some
aspects of the Firm's trading (UK equities), however, this represents a
small proportion. Although the Firm supports the Code's objectives, it
has taken the decision not to commit to all the principles of the Code.