Rule 2.2.3R of the FCA's Conduct of Business Sourcebook requires an authorised firm to include on its website a disclosure about 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 and sets out a number of principles relating to engagement by investors with UK equity issuers.

Pharo Management (UK) LLP (the ‘Firm’) manages assets across a number of emerging markets strategies. The Firm does not however take an activist shareholder approach. Consequently, while the Firm supports the general objectives that underlie the Code, the provisions of the Code are not relevant to the type of trading currently undertaken by the Firm. If the Firm's investment strategy changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.