Investment & Portfolio Consultants Limited

UK Stewardship Code Disclosure

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Investment & Portfolio Consultants Limited (the "Firm") is required to include a public disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy.

The Firm pursues an investment strategy to which the aims of the Code are not relevant. Over 95% of the portfolios managed by the Firm are in fixed income investments with the remainder covering convertibles, preferences shares and a limited number of direct equity holdings.

Consequently, while the Firm supports the general objectives that underlie the Code, the provisions of the Code are not relevant to the type of trading currently undertaken by the Firm.If the Firm's investment strategy changes in such a manner that the provisions of the Code become relevant, the Firm will amend this disclosure accordingly.

For further information on the Firm’s approach contact:

David Crystal at ipc@investmentandportfolioconsultants.com