Shareholder Rights Directive (“SRD II”)

While Rondine supports the objectives of the Shareholder Rights Directive (“SRD II”), it has chosen not to comply with its requirements at this time. This is because Rondine considers that its requirements are not commensurate with the Firm’s investment strategy. Moreover, the Firm ensures that its clients are regularly apprised of the investment strategies employed by Rondine. As such, it is felt that clients understand the Firm’s position regarding shareholder engagement.