Shareholder Rights Directive II

Under Rule 2.2B of the FCAs Conduct of Business Sourcebook, ShadowFall is required to include on this website a disclosure about the nature of its commitment to the Shareholder Rights Directive (SRD II) or disclose why we have chosen not to comply. Whilst ShadowFall fully supports the general objectives that underlie the SRD II and observes high standards of corporate governance and due diligence in respect of its investments, ShadowFall believes that the Principles are not currently applicable due to the nature of its investment strategy as ShadowFall does not engage with investee companies through voting rights. The Firm will review this position annually and update this disclosure accordingly if the provisions of the SRD II become relevant.