Under COBS 2.2.3R of the FCA Handbook, we are required to make a public disclosure in relation to the nature of our commitment to the Financial Reporting Council's UK Stewardship Code (the "Code"), which was published by the Financial Reporting Council ('FRC'), the latest version of which became effective 1 January 2020.

It sets out good practice on engagement with investee companies and is to be applied by firms on a "comply or explain" basis.

The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases, firms are required to explain why it is not appropriate to comply with a particular principle.

The 12 principles of the Code consist of the following:

1. Purpose, strategy and culture;
2. Governance, resources and incentives;
3. Conflicts of interest;
4. Promoting well-functioning markets;
5. Review and assurance;
6. Client and beneficiary needs;
7. Stewardship, investment and ESG integration;
8. Monitoring managers and service providers;
9. Engagement;
10. Collaboration;
11. Escalation; and
12. Exercising rights and responsibilities

Amersham Investment Management Ltd ("Amersham") monitors all investee companies as part of its general investment policy and approach. The Firm takes action in line with its investment objectives where its research of publicly available information warrants such action. However, given the nature of our chosen investment strategy very much aligns to start-up funding and early stage venture capital, targeting HNW/Sophisticated/Professional investors we have chosen not to comply with the Code. Should any of the above factors change, we will review our commitment to the Code at that time and make appropriate disclosure. Further, Amersham considers the AIFs/SEIS/EIS schemes it manages as its professional client. Further detail around our current strategy may be found in the 'What we do' section of our website.