UK Stewardship Code

FSA Conduct of Business Rule 2.2.3R requires FSA authorised firms to either disclose their compliance or explain their non-compliance with the principles set out in the UK Financial Reporting Council's Stewardship Code (the "Code"). Clear Alpha Limited (“Clear Alpha” or “the Firm”) is regulated by the FSA in the United Kingdom and therefore subject to the Code.

Clear Alpha manages assets across a number of strategies, but does not take an activist shareholder approach. Accordingly, whilst the Firm supports the Code as a mechanism to promote best practice in the institutional shareholder conduct of UK listed companies, the Firm does not consider the Code or its principles to be appropriate for its investment strategies.