Shareholder Rights (SRD II).

Shareholder Rights Directive Disclosure

Nanook Energy Advisors LLP

(“Nanook” / the “Firm”)

In accordance with rule COBS 2.2B.5R of the Financial Conduct Authority's (“FCA”) Handbook, Nanook is required to either develop and publicly disclose an engagement policy that meets the requirements of the Shareholder Rights Directive (Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement as on-shored by virtue of the European Union (Withdrawal) Act 2018, or “SRD II”), or to publicly disclose a clear and reasoned explanation of why it has chosen not to develop an engagement policy that meets the requirements of SRD II.

Nanook has chosen not to develop an engagement policy that complies with SRD II. Our investment strategy, which focuses on commodities derivatives, agricultural derivatives and equities indices, is not aligned with the outcomes intended by SRD II. The financial instruments that the Firm trades in do not foster investor engagement with investee companies and these investments do not carry voting rights. Consequently, the requirements for shareholder engagement and disclosure of information are not relevant to our activities.

Nanook Energy Advisors LLP
17 December 2024

Disclaimer: This disclosure is for informational purposes only and does not constitute investment advice or an offer to sell or a solicitation of an offer to buy any securities or other financial instruments.