Shareholder Rights Directive Statement

Nickel Digital Asset Management Ltd (“NDAM”) is making this statement in compliance with Rule 2.2B.5R of the FCA’s Conduct of Business Sourcebook (“COBS”).

COBS 2.2B applies to an FCA authorised asset manager to the extent that it invests on behalf of investors in shares admitted to trading on a regulated market. Where it applies, Rule 2.2B.5R requires NDAM to either:

1. develop and publicly disclose an “Engagement Policy” providing details of, among other things, how NDAM’s investment strategies and shareholder engagement activities, including the exercise of voting and other applicable rights and their implementation, contribute towards the performance of the assets of NDAM or of funds managed by NDAM; or2. publicly disclose a clear and reasoned explanation of why NDAM has chosen not to comply with any of the requirements in (1) above.

NDAM pursues investment strategies in digital and crypto assets. Neither NDAM nor the funds or accounts managed by NDAM invest in shares admitted to trading on a regulated market and neither directly nor indirectly exercises voting rights attached to securities falling within the scope of the regulation. Therefore, whilst NDAM supports the general principles of shareholder engagement, it has chosen not to implement an Engagement Policy at this time. Should NDAM’s investment strategies change such that these requirements become relevant, this statement will be amended accordingly.

Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Nickel Digital Asset Management Ltd (“NDAM”), to the extent that it is managing investments for a professional client (as defined by the FCA), is required to include a 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 Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers.

NDAM pursues investment strategies in digital and crypto assets and does not hold shares in listed companies on behalf of the funds or accounts it manages. Consequently, while NDAM supports the general objectives that underlie the Code, NDAM does not commit to the Code and its provisions are not relevant to the type of trading currently undertaken by NDAM. If NDAM’s investment strategy changes in such a manner that the provisions of the Code become relevant, NDAM will amend this disclosure accordingly.