UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Marine Capital Limited, to the extent it is managing investments for a professional client (as defined by the FCA), is required to include 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, explain its considered choice based on the Company’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.

Marine Capital Limited invests directly in shipping assets and therefore it has no exposure to UK listed companies. Therefore, while the Firm generally supports the objectives that underlie the Code, the nature of its investment strategy makes it impractical and unnecessary to engage with investee companies through voting rights. The Firm has therefore chosen not to commit to the Code at this time.