SRD II Disclosure

East X LLP (“East X” or the “Firm”)

Introduction

The Firm is a Full-Scope Alternative Investment Fund Manager.

SRD II

Article 3g of SRD II, which is summarised in the FCA Handbook under COBS 2.2B, requires a firm such as East X to either:

develop and disclose an engagement policy describing how the firm integrates shareholder engagement in its investment strategy; or
disclose why the firm has chosen not to comply with those requirements.

Such an engagement policy requires a firm to describe how it:

integrates shareholder engagement in 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 dialogues with investee companies;
exercises voting rights and other rights attached to shares;
cooperates with other shareholders;
communicates with relevant stakeholders of the investee companies; and
manages actual and potential conflicts of interests in relation to the firm’s engagement.

The above engagement policy is limited to the extent that a firm invests on behalf of investors in shares traded on a regulated market (or on third country markets that meet comparable requirements and where the shares dealt in are of a quality comparable to those in a regulated market in the UK).

The Firm’s approach to engagement

The Firm’s investment strategy is such that the firm does not invest in shares traded on a regulated market (or comparable market).

While the Firm generally supports the objectives that underlie SRD II, for the above reason the Firm has chosen not to produce an engagement policy at this time.