STEWARDSHIP CODE - DISCLOSURE STATEMENT

Under Rule 2.2.3R of the FSA's Conduct of Business Sourcebook regulated firms that manage investments for institutional clients are required to disclose by a statement on their website the nature of their commitment to The Stewardship Code ("the Code"). The Code, which has been published by the Financial Reporting Council, sets out principles for institutional investors in relation to their engagement with the companies in which they have invested. The FSA's regulations oblige any firm subject to the rules to publicly disclose the nature of its commitment to the Code, or where it does not commit to the Code, its alternative approach.

Walker Crips Asset Managers Limited's investment strategy is, in general, such that the firm does not consider it to be appropriate for it to engage directly with companies in which it invests or to actively vote on resolutions at meetings of shareholders. The basis on which the firm manages investments for institutional clients is such that engagement would not be beneficial for those clients and the firm does not consider that engagement with management is expected by our institutional clients.