The revised Shareholder Rights Directive ((EU)2017/828) (“SRD II”) is an amendment to Directive 2007/36 (“the Directive”) which is implemented in the United Kingdom under rule 2.2B of the Financial Conduct Authority’s Conduct of Business Sourcebook (“COBS”). The amended Directive applies to asset managers, including MiFID investment firms, Full Scope Alternative Investment Fund Managers (“AIFMs”) and UCITS where those firms invest in shares in companies listed on regulated EEA markets. The amended Directive aims to promote effective stewardship and encourage long- term shareholder engagement, increasing transparency between companies and investors. Kryger Capital Limited (“the Firm”), as a Full Scope AIFM, is required to disclose publicly a policy on shareholder engagement with respect to companies listed in Europe or provide a clear and reasoned explanation of why it has chosen not to adopt an engagement policy.

An effective engagement policy should explain how the Firm:

• Integrates shareholder engagement into its investment strategy;

• Monitors investee companies on relevant matters including strategy, financial and non- financial performance and risk, capital structure, social and environmental impact and corporate governance;

• Conducts dialogue with investee companies;

• Exercises voting rights and other rights attached to the shares;

• Cooperates with shareholders;

• Communicates with relevant shareholders of the investee companies; and

• Manages actual and potential conflicts of interest in relation to its engagement.

The Firm has carefully reviewed and considered the requirements under SRD II and although the Firm supports the principles and objectives of the directive, it has concluded that due to the nature of the investment strategy it pursues, there will be instances where publicly disclosing a policy could be disadvantageous to the Firm’s investors.

The Firm manages a global event-driven strategy, achieved through transactions including, but not limited to merger arbitrage, special purpose acquisition companies and other significant corporate events. The Firm holds exposure across physical equity shareholding and swap positions. The opportunities for shareholder engagement on swap positions are limited as a swap holder is not entitled to vote nor attend meetings of the issuer. Where the Firm does have the authority to exercise voting rights, it will do so by acting in the best interest of its investors.

The Firm may occasionally engage with company management or cooperate with other stakeholders where the Firm deems this to be in the best interest of its investors. This engagement is on a case- by-case basis as part of the investment process.

The Firm has a Proxy Voting Policy which is available to investors upon request.

The Firm will keep its position in regards to SRD II under review and should its approach change, it will update this section of the website accordingly.