Shareholder rights directive II

As a quantitative investment manager investing in as many as 8,000 stocks globally, Winton does not typically hold concentrated equity positions or invest in a company with a view to actively intervening in its management.

As a result, Winton does not have direct contact with the companies in which its strategies invest. Consequently, whilst Winton recognises the importance of playing an active role in corporate governance for the purposes of long-term shareholder value, the features of its investment strategies are such that most of the elements of an engagement policy are not directly relevant. Therefore, Winton has chosen not to adopt such a policy at this time.

Winton’s approach to corporate governance is set out in its responsible investment policy and stewardship disclosure. For example, Winton has partnered with a leading corporate governance research service, ISS Europe (ISS), to provide proxy voting guidelines and to vote proxies on its behalf, whilst retaining the right to exercise discretion. Winton has instructed ISS to conduct its proxy voting activity based on a sustainability framework that generally takes its frame of reference from internationally recognised sustainability initiatives.

Winton’s proxy voting policy and a record of all proxy votes cast on behalf of its clients are available to investors and potential investors on request.