Disclaimer

LEGAL INFORMATION

This page advises you of the terms of use of this website https://www.antarcticaam.com (the “Website”). Please read these terms of use carefully before you start to use the Website. By using the Website, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using the Website.

1. Accessing the Website

Access to certain areas of the Website requires possession of a valid password provided by us. No user who is provided a password should disclose that password to any other person or allow any other person to gain access to restricted areas of the Website using that password. Users are accountable for the storage and use of their passwords. If a password becomes lost or stolen users must contact us to cancel the password and be issued a replacement. No unauthorised person should attempt to gain access to any restricted area of the Website. We disclaim all liability for any loss a user may suffer from access to the Website by an unauthorised person.

2. Recipients of Communication

This Website is established by Antarctica Asset Management Ltd. (“AAM”, “we” or “us”) for and on behalf of various investment vehicles managed by it (the “Funds”) and is not directed to any person in any jurisdiction who does not meet the the investment restrictions set out in the relevant Funds’ documents or where (by reason of that person’s nationality, residence or otherwise) we would become subject to license or registration regulations of the jurisdiction, or the publication or availability of this Website is prohibited. Persons in respect of whom such prohibitions apply must not access this Website.

3. Risk Considerations

Past performance of the Funds and investments described herein cannot be relied upon as a guide to future performance. No representation or warranty, express or implied, is made regarding future performance. Opinions and/or estimates reflect a judgement at the original date of publication and are subject to change without notice. The price, value and income from any of the investments mentioned in this Website may fall as well as rise and we cannot guarantee that any capital invested will maintain or increase in value. Users of this Website should seek independent financial advice prior to making any investment decision and no information herein shall constitute general or specific investment, legal, tax or accounting advice of any kind.

4. Accuracy of Information

No representation, warranty or undertaking is given by us that the information contained in this Website is accurate, complete, comprehensive, or up to date, and no liability is accepted by us for such information. In particular, we shall not be obliged to remove any out-dated information from this Website or to expressly mark it as out-dated. In no event will we be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the information contained on this Website, or on any other hyper-linked website, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment, or otherwise, even if we are expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that we have under any regulatory system where to do so would breach law or regulation.

5. No Offer or Advice

No representation, warranty or undertaking is given by us that the information contained in this Website is accurate, complete, comprehensive, or up to date, and no liability is accepted by us for such information. In particular, we shall not be obliged to remove any out-dated information from this Website or to expressly mark it as out-dated. In no event will we be liable to any person for any direct, indirect, special or consequential damages arising out of any use of the information contained on this Website, or on any other hyper-linked website, including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment, or otherwise, even if we are expressly advised of the possibility or likelihood of such damages. This does not exclude or restrict any duty or liability that we have under any regulatory system where to do so would breach law or regulation.

6. General Selling Restrictions

The Funds’ shares have not been and will not be registered under the US Securities Act of 1933, as amended (the “US Securities Act”) or any other applicable law of the United States. The Funds have not been registered under the US Investment Company Act of 1940, as amended. Shares in the Funds may not be offered, sold, transferred, distributed or otherwise delivered directly or indirectly in the United States or to or for the account of any US Person (as defined in Regulation S under the US Securities Act). Subject to certain exceptions, the securities referred to herein and on the pages that follow may not be offered, sold, resold, taken up, exercised, renounced, transferred, delivered or distributed, directly or indirectly, in Australia, Canada, or Japan or to any resident or citizen of Australia, Canada, or Japan. The offer and sale of the securities referred to herein and on the pages that follow have not been and will not be registered under the applicable securities laws of Australia, Canada, or Japan.

7. Important Information for Residents in Switzerland

Persons who access information in this Website agree to the following terms and conditions. Any special agreements with respect to individual services or products shall be complementary to these terms and conditions, although in the event of any conflict, the provisions contained in any such special agreement shall prevail. The Funds mentioned on this Website have not been registered with the Swiss Financial Market Supervisory Authority FINMA as foreign collective investment schemes pursuant to Article 120 of the Swiss Collective Investment Schemes Act (“CISA”). Accordingly, the interests in the Funds may not be publicly offered in or from Switzerland, and no offering or marketing materials relating to the interests in the Funds may be made available through a public offering in or from Switzerland. The interests in the Funds may only be offered and any offering or marketing materials may only be distributed, or otherwise made available, in or from Switzerland exclusively to qualified investors as such term is defined in the CISA and its implementing rules and regulations and in accordance to CISA rules and regulations.

8. Important Information for Residents in the UK

In the UK, this Website is directed only at persons who (i) have professional experience in matters relating to investments who fall within Article 19(1) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (“FPO”), (ii) are high net worth companies, unincorporated associations, etc. within Article 49 FPO or (iii) are persons to whom it otherwise lawfully may be communicated. All persons who fall within the above categories are deemed “Relevant Persons”. Any investment or investment activity to which this Website relates is available only to, and will be engaged in only with, Relevant Persons. Any person who is not a Relevant Person should not act or rely on this Website or any of its content.

9. Important Information for Residents in the European Economic Area

In the European Economic Area, the information on this Website is not to be issued or distributed to, nor directed at, persons other than “Qualified Investors” within the meaning of Article 3(2)(a) of Directive 2003/71/EC (the “Prospectus Directive”). The information contained on this Website must not be accessed by, acted on, or relied on by persons in the European Economic Area who are not Qualified Investors. Within the European Economic Area, any investment or investment activity to which the information on this Website relates is only available to Qualified Investors and will be engaged in only with Qualified Investors.

10. Important Information for Residents in Hong Kong

In Hong Kong, this Website is directed only at persons who qualify as “professional investors” as defined in the Securities and Futures Ordinance (the “SFO”) and the Securities and Futures (Professional Investor) Rules made under the SFO. The information contained in this Website does not constitute an “offer to the public” within the meaning of the Companies Ordinance, and is not an advertisement, invitation or document relating to any securities or collective investment schemes or any other investment under the SFO. None of the funds and/or products described in this Website have been authorized by any regulatory authority in Hong Kong. Any investment or investment activity to which this Website relates is available only to, and will be engaged in only with, professional investors. Any person who is not a professional investor should not act or rely on this Website or any of its content.

11. Copyright, Trademarks and Other Rights

AAM owns the copyright in the content of this Website, unless otherwise stated. You may use the information on this Website and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed or transmitted to any other person or incorporated in any way into another database, document or other materials without our permission. Nothing on this Website should be considered as granting any license or right under any trademark of us, our associates, or any third party.

12. Hyperlinks

This Website may provide addresses or hyperlinks which lead you out of the Website. Except to the extent to which the Website refers to our own website material, we have not reviewed any such websites which link to this Website or to which this Website links, and are not responsible for the content of any other websites or pages linked to or linking from this Website. Such addresses or hyperlinks are provided solely for your convenience and information and are completely beyond our control. Accessing such websites or following such links to any other websites or pages shall be at your own risk. We do not assume any responsibility for the accuracy, completeness or legality of the contents of such websites, or for any offers or services contained therein.

13. Privacy and Cookies

We are concerned about the privacy of any personal information you may provide to us through this Website. A “cookie” is a piece of information that is saved to your computer’s hard disk by the web server. Confirmation of your reading and accepting these terms and conditions will place a cookie on your computer’s hard disk. This will ease your navigation around this Website by not popping up these terms and conditions again during this browser session. The cookie is temporary and will be removed when you close your browser. The cookie is not used for any other reason. You are not obliged to accept a cookie that we send you, and you can modify your browser so that it will not accept cookies.

14. Data Protection

We may collect certain personal information about you such as your name, address, telephone number, email address details and other information that you voluntarily submit to us on this Website, including in connection with our customer registration procedures. We use such information solely for the purpose of ensuring compliance with our regulatory obligations and other restrictions set out in the Funds’ governing documents and for our own internal purposes. Please note that by voluntarily submitting personal information you are consenting to such information being processed for the purposes referred to above. You also agree that we have the right to use and store such data on our internal systems and to transfer it to our related entities, whether inside or outside the European Union, for the purpose of providing services to you. You should also be aware that the level of protection in relation to the processing of personal data may not be the same in countries outside the European Union as in those within the European Union. If you have any questions on our use of your information, please contact us. Further information is provided in the GDPR section below.

15. Jurisdiction

Use of this Website shall be governed in accordance with the laws of England and Wales and the courts of England and Wales shall have exclusive jurisdiction over any dispute arising out of your use of this Website.

16. Changes to the Website

The information on this Website, including these terms and conditions, are subject to change without notice. We have the right to suspend or withdraw the provision of all or any of the information on the Website without prior notice at any time. You agree to review these terms of use regularly and your continued use of the Website will mean you agree to any changes.

17. Severability of Provisions

Any provision of these terms of use that is prohibited or unenforceable in any jurisdiction is ineffective as to that jurisdiction to the extent of the prohibition or unenforceability. That does not invalidate the remaining provisions of these terms of use nor affect the validity or enforceability of that provision in another jurisdiction.

18. Indemnity

You shall be liable to us for any loss, liability or cost we suffer as a result of your use of the Website or any breach of these terms. You agree to indemnify, defend and hold harmless us and our agents, employees and third party sources from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including properly incurred attorneys’ fees) that arise from or relate to: (a) your use of the Website; (b) your breach of these terms; or (c) your violation of any applicable law, statute, ordinance, regulation or of any third party’s rights.

19. Antarctica Asset Management (Europe) Limited – UK Regulatory Disclaimers

UK Stewardship Code Disclosure Statement

Pursuant to Rule 2.2.3R / 2.2A.5R of the FCA’s Conduct of Business Sourcebook Antarctica Asset Management (Europe) Limited (“Antarctica Europe” / the “Firm”) is required to make a public disclosure about the nature of its commitment to the UK Financial Reporting Council’s (“FRC”’) Stewardship Code (the “Code”). In particular, these requirements set out to strengthen the position of shareholders and to ensure that decisions are made for the long-term stability of companies and apply to the extent that a firm is investing on behalf of investors in shares traded on a regulated market.

The Code is a voluntary code and sets out a number of principles and disclosures relating to engagement by investors with UK equity issuers. Effective from 1 January 2026, the Code introduces a streamlined structure for reporting and is divided into two parts: Policy and Context Disclosure and Activities and Outcomes Report. In the 2026 version, the Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries”.

There are six Principles of the Code that apply to asset owners and asset managers. These are:

1. Integrating stewardship and investment
2. Promoting well-functioning markets
3. Engagement
4. Exercising rights and responsibilities
5. Selection and oversight of managers
6. Monitoring service providers

There are five Disclosures of the Code that apply to asset owners and asset managers. These are:

1. Describe your organisation, your investment beliefs, your clients or beneficiaries and how that informs your approach to stewardship.
2. Describe how your resources enable effective stewardship.
3. Describe your stewardship policies and processes and how you review them.
4. Describe how you manage stewardship related conflicts of interest to put the best interests of clients and beneficiaries first.
5. Describe how you maintain a dialogue with clients and or beneficiaries.

Investors that commit to the Code can either comply with it in full or choose not to comply with certain aspects of the Code, in which case they are required to explain their non-compliance and state in general terms its alternative investment strategy.

Although the Firm recognises the aims and benefits of the Code the Firm’s investment strategy is such that it does not engage directly with companies and therefore the Code in the context of Firm’s investment strategy does not apply and the Firm does not consider that its clients expect such engagement. It is however important to note that the Firm’s investment strategy is specifically structured to maximise investment gains and enhance shareholder value and that it constantly monitors investments, would act collectively with other institutional investors where appropriate and has developed internal policies and procedures for managing conflicts of interest. This non commit disclosure fully encompasses the Firm’s regulatory obligations in complying with the FRC’s Stewardship Code and the FCA’s regulatory requirements.

MIFIDPRU 8 DISCLOSURES – 31st DECEMBER 2025

Scope and application

The Financial Conduct Authority (“FCA”) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Antarctica Asset Management (Europe) Limited (“Antarctica Europe” / the “Firm”), and specifically MIFIDPRU 8 which sets out the public disclosure obligations regarding the Firm’s remuneration policy and practices with which the Firm must comply.

Antarctica Europe is authorised and regulated in the UK by the Financial Conduct Authority (the ‘FCA’) as a full-scope Alternative Investment Fund Manager (‘AIFM’) with legacy MiFID permissions, and is therefore classified as a Collective Portfolio Management Investment Firm (“CPMI”). As an AIFM with MiFID permissions, the Company has to maintain regulatory capital and liquidity at all times in compliance with both the FCA’s Interim Prudential sourcebook for Investment Businesses Regulation’s (‘IPRU-INV’) and the FCA’s Prudential Sourcebook for MiFID Investment Firms (‘MIFIDPRU’). There is a general overlap between these two sets of prudential rules, however as appropriate Antarctica Europe will apply the most stringent requirements.

Given the firm’s size, internal organisation, and the nature, the scope and the complexity of its activities, the firm is classified as a below threshold firm for AIFM purposes and as a Small Non-Interconnected (‘SNI’) firm under MIFIDPRU and is therefore required to comply in a way that is proportionate. In applying the FCA’s proportionality approach as a below threshold AIFM firm the Firm has elected not to apply the FCA’s specific regulatory requirements in relation to the Pay-out Process Rules including the payment of variable remuneration through retained shares or other instruments; and the deferral of these payments or performance adjustments.

Business Strategy

The remuneration policy is designed to be aligned with the business strategy, long-term objectives and the values and interests of the Company and its clients within a framework of sound and well-controlled risk management.

As an investment manager / adviser, Antarctica Europe’s overall objective is to achieve consistent performance for the Firm’s clients. Antarctica Europe’s income is dependent upon clients’ advisory assets / funds’ under management and therefore the profit available for distribution under this Policy is dependent upon Antarctica Europe’s overall performance and, as such, the fulfilment of our objectives is interlinked with the best interests of our clients, which in turn is in line with this Policy.

Risk Appetite

The Firm as an SNI firm has a low risk appetite which is evidenced by the fact that: all of its clients are institutional, i.e. professional clients; no client money nor assets are held by the Firm; it has no ability to proprietary trade, so does not take principal positions with its own capital; and senior management are experienced industry professionals who are actively involved in the Firm’s day to day activity.

The main categories of risk for Antarctica Europe are market, operational, reputational, conduct, regulatory and people risk which are accounted for in the design of the remuneration structure.

Remuneration Policy and Practices

Antarctica Europe is committed to excellence, teamwork, ethical behaviour and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude and results. Antarctica Europe is committed to encouraging equality, diversity and inclusion among our workforce and eliminating unlawful discrimination. We aim to create a diverse environment that allows each employee to be respected and supported. This extends to equality of pay.

Governance and Oversight

The Firm has not established a remuneration committee on the basis that this would be disproportionate for such a small, owner managed business that has no external investors or stakeholders. Nevertheless, the Firm’s remuneration arrangements are formally considered on an annual basis by the Firm’s management body without external consultants engaged to advise on our remuneration matters. The Firm’s Senior Managers fully acknowledge their responsibilities under the Code including their overriding responsibility to ensure that the Firm’s remuneration policies and practices:

• are in line with the business strategy, objectives and long-term interests and values of the Firm;
• are consistent with and promote sound and effective risk management and do not encourage risk-taking that exceeds the level of tolerated risk of the Firm;
• are appropriate to attract, motivate and retain suitable staff;
• are representative of the underlying performance of the business and do not reward individuals for poor performance;
• include measures to avoid conflicts of interest.

In addition, Antarctica Europe recognises that remuneration is a key component in how the Firm attracts, motivates and retains quality staff and sustains consistently high levels of performance, productivity and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and greatest competitive advantage.

Assessment of performance

All employees are assessed annually using a standard performance appraisal process, including consideration to a range of non-financial and financial criteria ranging from compliance and conduct risks to the performance of business activities. Any performance being assessed is based entirely on professional ability and the process does not allow for any subjectivity or determination based on any protected characteristic, as defined in the 2010 Equality Act i.e., age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

Characteristics of the remuneration policy and practices

Remuneration at Antarctica Europe is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance, and the financial and non-financial performance of the individual in contributing to the Firm’s success. All staff members are eligible to receive variable remuneration.

The fixed and variable components of remuneration are appropriately balanced, and the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.

Quantitative Remuneration Disclosures / MIFIDPRU & AIFM

MIFIDPRU – Although Antarctica Europe as a CPMI firm to permitted undertake MiFID regulatory activities it has not utilised these regulatory activities during the period under review and therefore aggregate total remuneration paid to all staff under MIFIDPRU for the year was £0K (Zero).

AIFM - The requirements of the AIFM remuneration code and disclosures (subject to proportionality) apply to those persons in the firm whose professional activities have a material impact on its risk profile, which are known under AIFMD as ‘Code Staff. Code staff includes senior management, risk takers, staff engaged in control functions and any employees receiving total remuneration that takes them into the same remuneration bracket as senior management and risk takers, whose professional activities have a material impact on the Firm’s risk profile.

At the Firm, Code Staff comprise all those individuals who carry out the Firm’s Controlled Functions; however, as disclosure under these requirements would lead to the identification of the code staff the Firm therefore has not disclose this specific detailed information but has relied on the FCA’s proportionality approach, and a regulatory exemption, to present the Firm’s remuneration disclosure on an aggregated basis.

Details of aggregate remuneration paid to all staff during the year 1st January to 31st December 2025 are £2,275,414 of fixed remuneration and £2,354,559 of variable remuneration making the total remuneration paid for the year of £4,629,973. All variable remuneration is delivered in cash, and performance adjustment is not applied.