Three Rock Capital Management has elected not to implement a SEP – Shareholder Engagement Policy- as permitted under the Shareholder Rights Directive. The rationale for this decision is that the funds are distributed to individual investors rather institutional investors. There is no requirement to have an SEP in place for individual investors and there is no demand from our fund investors for this service. Three Rock will continue to monitor its activities and may at some point in the future elect to implement an SEP if deemed appropriate.