Investment Policy

Investment Objective

The Company’s investment objective is to invest in the shares of companies, admitted to trading on a market of the London Stock Exchange, and seek to maximise the value of such investments for Shareholders.

Investment Policy

The Company will achieve the investment objective by investing in the shares of closed-ended investment companies, property companies or companies whose valuations are substantially underpinned by real assets, admitted to trading on a market of the London Stock Exchange, with a focus on alternative assets (being assets other than publicly quoted equities) and will seek to maximise returns to Shareholders through the use of constructive activism.

The Company expects to hold a concentrated portfolio of investments and the Company will not seek to reduce concentration risk through diversification. The Company will seek to identify underperforming or undervalued assets and unlock value. The Company will take an active role in engaging with the boards and the investment managers of investment companies within its portfolio. This may include advocating selling the entire company or any or all of its assets, changes in strategy or restructuring.

Investments are expected to be mainly in the form of equity and equity-related instruments such as contracts for difference. The equity interest in any investment may range from a minority position up to 29.99 per cent. ownership.

Where appropriate, the Investment Manager may seek a position on an investee company’s board. The Company may hold cash in its portfolio from time to time to maintain investment flexibility. There is no limit on the amount of cash which may be held by the Company from time to time.

Investment Restrictions

The Company will observe the following investment restrictions:

• there will be no cross-financing between the companies forming part of the portfolio and no operation of a common treasury function between the Company and any of its investee companies;
• the Company will not hold more than 29.99 per cent. of the voting rights of an investee company; and
• the Company will not invest in unquoted companies, however, in order to ensure the maximum realisation of shareholder value, the Company will be permitted to remain invested in an investee company that delists, or its acquiring entity, following a public-to-private transaction.

Each of the restrictions above will be calculated at the time of investment. The Company will not be required to dispose of any asset or to rebalance its portfolio as a result of a change in
the respective valuations of its assets or as a result of any portfolio holding ceasing to be admitted to trading on a market of the London Stock Exchange.

Gearing Policy
The Company does not intend to incur borrowings for investment purposes, although the Company may, from time to time, utilise borrowings over the short term for working capital purposes up to 10 per cent. of Net Asset Value at the time of borrowing. The Company may invest in portfolio companies which themselves employ gearing or incur leverage.

Hedging and Derivatives

The Company may enter into hedging contracts and other derivative contracts for the purposes of efficient portfolio management. No hedging transactions will be undertaken for speculative purposes.

Cash Management

The Company may hold cash on deposit for working capital purposes and while awaiting investment and, as well as cash deposits, may invest in cash equivalent investments, which may include government issued treasury bills, money market collective investment schemes, other money market instruments and short-term investments in money market type funds (“Cash and Cash Equivalents”). There is no restriction on the amount of Cash and Cash Equivalents that the Company may hold and there may be times when it is appropriate for the Company to have a significant Cash and Cash Equivalents position.

Changes to and Compliance with the Investment Policy

Any material change to the Company’s investment policy will require the approval of Shareholders by way of an ordinary resolution at a general meeting. In the event of a breach of the investment guidelines and/or the investment restrictions set out above, the Investment Manager shall inform the Board as soon as practicable upon becoming aware of that breach. If the Board considers the breach to be material, notification will be made through an announcement via a Regulatory Information Service.