Shareholders Rights Directive II (‘SRD II’ - 2017/828) – Statement of Engagement

Sanarus Investment Management LLP is a Full-Scope UK AIFM (here forth referred to as “Sanarus”).

This statement sets out the firm’s approach in meeting the requirements (‘Engagement Policy’) set out in SRD II and summarised in the FCA Handbook under COBS 2.2B.6 in relation to investments in shares traded on a regulated market (a term which extends to non-EU markets which are comparable to EU regulated markets and where the financial instruments dealt in are of a quality comparable to those in a UK regulated market).

Integration of shareholder engagement in investment strategy

Sanarus manages passive index tracking equity funds and as such follows the index rules and does not engage with the companies that it invests in.

Monitoring and Dialogue with Investee Companies (Strategy, Financial and Non-Financial Performance Risk, Capital Structure and ESG)

Sanarus does not engage in meetings with investee companies and does not pursue an active trading strategy in listed companies.

Sanarus only trades listed equities within its listed index fund strategies which pursue a passive index tracking trading strategy.

Exercise of Voting Rights

Sanarus does not actively exercise its voting right.

Cooperation with Other Shareholders

Generally, Sanarus does not adopt an activist approach with other shareholders.

Communication with Relevant Stakeholders of Investee Companies

Sanarus does not actively engage with investee companies or stakeholders of investee companies.

Conflicts of Interests

The firm maintains a Conflicts of Interest policy in line with FCA rules and requirements.