BOYER ALLAN INVESTMENT MANAGEMENT LLP

THE STEWARDSHIP CODE

Boyer Allan Investment Management LLP (BAIM LLP) acts as discretionary investment manager for a variety of clients on both a segregated basis and at a fund level. We are also regulated by the Financial Services Authority ("FSA") to conduct investment business in the United Kingdom. This statement aims to disclose how BAIM LLP has determined the applicability of the UK Stewardship Code ("the Code") and the FSA rules to its business model.

The Code was published by the Financial Reporting Council (FRC) in July 2010. The aim of the Code is to enhance the quality of engagement between institutional investors and company boards to help improve long term returns to shareholders and the efficient exercise of governance responsibilities. The Code encourages greater transparency about the way in which institutional investors oversee the companies in which they invest. The Stewardship Code contains seven principles which can be accessed here (http://www.swip.com/sc).

The FSA Conduct of Business Sourcebook rule 2.2.3R, requires BAIM LLP to include a disclosure on its website stating the nature of its commitment to the Code. If the firm does not commit to the Code, it must state in general terms its alternative investment strategy. The Code sets out various principles relating to the level of engagement by investors with UK equity investors. Investors may either comply with the Code or choose not to comply with certain aspects of the Code, in such case an explanation of non compliance is required.

BAIM LLP is a specialist investment manager of Asian, EMEA and GEMS equity absolute return funds and as such does not typically invest in UK equities. Therefore, the Code is applicable only to some aspects of the firmÕs trading. Although BAIM LLP supports the CodeÕs objectives, the firm has decided not to commit to the principles of the code.

The firm invests in various asset classes and jurisdictions with an investment philosophy which includes long/short directional stock picking, stock selection driven by bottom-up research, focused on GARP and free cash flow generation, pragmatic risk taking, with full use of balance sheet. The current policy of the firm in engaging with issuers and their management is determined on a global basis. Thereby the firm takes a consistent approach to engaging with the issuers and their management in all the jurisdictions the firm invests in. Hence, it is not deemed appropriate to comply with any voluntary codes of practice in any individual jurisdictions which may not align with policies, procedures or legal requirements in other jurisdictions or could cause conflicts of interests for BAIM LLP when investing on behalf of its investors.