Strix Asset Management Limited
(the “Firm”)
Shareholder Rights Directive Engagement Policy

Dated: 1 May 2025

1. Introduction

1.1 Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC (together with the European Union (Shareholders’ Rights) Regulations 2020 (S.I. No. 81/2020) implementing regulations in Ireland, the “SRD”) requires asset managers to develop and publicly disclose an engagement policy that describes how they integrate shareholder engagement in their investment strategy. As an investment firm authorised under MiFID, the Firm is an “asset manager” for the purposes of the SRD and has adopted this policy in accordance with the SRD.

1.2 This policy seeks to describe how the Firm integrates shareholder engagement in its investment strategy. It applies to the Firm’s investments in companies which: (i) have their registered office in a European Union member state (a “Member State”) and (ii) the shares of which are admitted to trading on a regulated market situated or operating in a Member State (“investee companies”).

1.3 This policy describes how the Firm monitors investee companies in respect of the matters set out in section 2 below.

1.4 This policy will be made available free of charge on the Firm’s website at https://strixam.com/legal-and-regulatory-notices

2 Monitoring of relevant matters affecting investee companies

2.1 The Firm shall, to the extent determined appropriate by the Firm and having regard to, among other things, the Firm’s investment strategy and the nature and size of its exposure to the relevant investee company, monitor the investee company’s approach towards matters such as its business strategy, financial and non-financial performance and risk, capital structure, and social, environmental impact and corporate governance.

2.2 In any particular case, the Firm may monitor the investee companies’ approach towards only some of the matters listed above.

2.3 The Firm may base such monitoring on a variety of sources and mechanisms including, without limitation:

• reviewing financial and non-financial information such as annual reports, financial statements and public announcements released on the relevant regulated market by the investee company; and
• engaging in dialogue with the board of directors and management of the investee company;
• considering third party analysis of the investee company, wider market developments and competitors of the investee company; and

2.4 For the avoidance of doubt, the Firm does not assume any responsibility for the investee company’s conduct of its business or compliance with its legal, regulatory, corporate governance and other obligations.

3. Engagement with investee companies

3.1 The Firm may, at its discretion and having regard to its investment strategy, engage with the investee company when the Firm has concerns about any of the matters referred to in section 2.1 above.

3.2 In such cases, the Firm may seek to engage with the investee company by way of dialogue with its board of directors or management and/or take any one or more of the following actions:

• express concerns with the investee company’s advisors;
• meet with the chairman or other board members of the investee company;
• submit resolutions and speak at shareholder meetings or vote against, or abstain from voting on, resolutions at shareholder meetings;
• reduce, or dispose of its holding in, or otherwise adjust its exposure to, the investee company; or
• undertake such other engagement as it determines to be appropriate in the circumstances.

4. Exercise of voting rights and other rights attached to shares

4.1 The Firm has adopted a strategy in relation to the exercise of voting rights.

4.2 The Firm intends to exercise rights attaching to shares in investee companies in a manner consistent with the Firm’s investment strategy.

5. Cooperation and communication with other shareholders and stakeholders in investee companies

5.1 The Firm may, at its discretion and having regard to its investment strategy, enter into dialogue and/or collaborate with shareholders and other stakeholders in investee companies (e.g. employees, suppliers, customers, creditors, etc.).

5.2 Any such collaboration must be carried out in accordance with the applicable law and regulation and the Firm’s policy on conflicts of interest.

6. Management of actual and potential conflicts of interest

6.1 The Firm has adopted a conflicts of interest policy which identifies, with reference to the portfolio management activities carried out by or on behalf of the Firm, the circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of the Firm and sets out procedures to be followed and measures to be adopted to manage such conflicts.

7. Annual disclosure on implementation of this policy and review of policy

7.1 The Firm votes in line with management recommendations. On that basis and given the limited number of holdings in scope for the SRD, the Firm does not consider it appropriate or necessary to disclose all votes cast.

7.2 This policy is reviewed on at least an annual basis or earlier in the case of a significant change to operations or in case of regulatory change.