Shareholder Rights Directive II (SRD II) Disclosure

Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”), a firm which trades shares on regulated and comparable markets, is required to either develop and publicly disclose an engagement policy as prescribed in COBS 2.2B.6R of the Financial Conduct Authority “FCA” Handbook, or disclose a clear and reasoned explanation of why it has chosen not to do so.

Disclosure by Carrhae Capital LLP on SRD II

Carrhae Capital LLP (“Carrhae” or the “Firm”) does not comply with the requirements of the Shareholder Rights Directive (“SRD II”).

Carrhae invests predominantly in publicly listed companies operating in Emerging Markets. The Firm’s investment strategy and means employed in the execution of the strategy do not embrace significant engagement with investee companies, and the Firm does not consider that its clients expect such engagement. On that basis, whilst Carrhae generally supports the objectives of SRD II, it has decided not to adopt a separate engagement policy under SRD II as it does not consider it appropriate, or practicable, to adopt an approach solely relating to a specific region or jurisdiction.