Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Mulvaney Capital is required to disclose the nature of its compliance with the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative business model. Mulvaney Capital pursues a systematic, quantitative investment strategy that does not invest in single equities. Consequently, the provisions of the Code are not relevant to the type of investment currently undertaken by Mulvaney Capital. If Mulvaney Capital were to change its investment strategy so that the provisions of the Code became relevant then Mulvaney Capital will amend this disclosure.

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