Northlander Commodity Advisors LLP UK Stewardship Code Disclosure 
Under the Financial Conduct Authority’s (“FCA”) Conduct of Business Rules 2.2A.5R, Northlander is required to make a public disclosure on its website in relation to the nature of its commitment to the Financial Reporting Council’s (“FRC”) Stewardship Code (the “Code”), first published by the FRC in July 2010 and, the updated version of the Code, becoming effective in January 2020. The Code consists of the 12 Principles for asset managers set out below. 
The 2020 Code Principles are: 
1. Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society. 
 
2. Signatories’ governance, resources and incentives support stewardship. 
 
3. Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first. 
 
4. Signatories identify and respond to market-wide and systemic risks to promote a well-functioning financial system. 
5. Signatories review their policies, assure their processes and assess the effectiveness of their activities. 
 
6. Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.  
 
7. Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities. 
 
8. Signatories monitor and hold to account managers and/or service providers. 
9. Signatories engage with issuers to maintain or enhance the value of assets. 
 
10. Signatories, where necessary, participate in collaborative engagement to influence issuers. 
 
11. Signatories, where necessary, escalate stewardship activities to influence issuers. 
 
12. Signatories actively exercise their rights and responsibilities. 
Northlander’s investment strategy invests in commodity derivatives and not listed equities, which the Code covers. Consequently, while the Firm supports the Codes objectives, its provisions 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:  
 
January 2021 
 
 
 
 
 
 
 
Northlander Commodity Advisors LLP - SRD II Disclosure 
Shareholder Rights Directive II (“SRD II”) came into effect on 10 June 2019, promoting effective stewardship and long-term investment decision making, in respect of shares traded on EEA regulated markets and comparable regulated markets outside the EEA. 
 
The rules require asset managers, who invest in shares traded on a regulated market detailed above, to: 
 
• Publish their shareholder engagement policy (or explain why they don't have one) – COBS 2.2B.5R. 
 
• Make annual public disclosures relating to the implementation of their shareholder engagement policy, from 10 June 2020 – COBS 2.2B.5R. 
 
• Make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R. 
Northlander does not manage investments in shares traded on an EEA regulated market, or on a comparable regulated market outside the EEA, and so the SRD II rules do not apply to it. We have therefore not developed a shareholder engagement policy and nor are we required to make the disclosures outlined above. 
 
If the Firm's investment strategy changes in such a manner that the provisions of SRD II become relevant, the Firm may amend this disclosure accordingly. 
For further information on the Firm’s approach contact: 
 
January 2021 
 
 
 
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