Record Currency Management Limited: investment adviser

Record was founded in 1983 by Neil Record and is a regulated provider of currency management services. Directors and staff have a majority interest in the firm. Record executes trades with counterparty banks in the capacity of agent for the user entity. Record does not receive commission on any trades. The spread between the buy and sell prices obtained from the counterparty bank at the time of trading represents the costs of executing FX transactions. Advisory Services Record is a specialist asset manager delivering best-in-class solutions to large institutional investors. The specific services provided by Record to a particular client depends upon the investment objectives and restrictions, investment instrument limitations and guidelines agreed with the client, as set forth in the documents governing Record’s agreement with the client. Record provides advisory services and implementation through separately managed accounts, and through funds under the laws of a number of jurisdictions. Record operates various types of currency mandates for clients: Risk Management (a)

Passive currency hedging

Passive Hedging aims to reduce portfolio volatility by removing currency risk. This is achieved through symmetrical elimination of currency exposure from clients’ international portfolios. Record’s approach combines investment efficiency with operational excellence. Clients benefit from best execution, custom benchmarks, optimised exposure capture, management of cash flows and a complete reporting suite, including regulatory reporting. (b)

Enhanced passive hedging

Enhanced Passive Hedging and Tenor Management builds on Record’s core offering, aiming to add value by exploiting market inefficiencies without affecting the consistent protection against currency moves. Record’s market-leading approach requires constant monitoring and innovation from a specialist team, using bespoke infrastructure to both identify and capture opportunities within a robust risk management framework (c)

Active currency hedging

Active currency hedging is an attractive alternative to passive hedging and has reduction of currency volatility and generating value as dual objectives. Dynamic Hedging allows user entities to benefit from foreign currency strength whilst protecting from foreign currency weakness relative to the user entities’

base currency. Record also provides an Adaptive Factor Hedging solution, which dynamically adjusts hedge ratios over time using a systematic framework driven by a diverse set of market signals. (d)

Solutions for Asset Managers

Initially developed as an extension of our Passive Hedging experience and expertise, these bespoke solutions are tailored specifically to the individual asset manager’s strategy and structure of their underlying investments with a focus on liquidity management, efficient implementation and granular reporting. Absolute Return (e)

FX Alpha

The FX Alpha product suite is a systematic multi-strategy offering which combines multiple return drivers into a single balanced portfolio that targets consistent returns in a variety of market conditions. FX Alpha targets risk premia and market inefficiencies within the currency markets, combining a mix of fundamental and quantitative models over short to long-term horizons. These portfolios trade in both developed and emerging markets, resulting in a diversified return stream for clients which performs in a variety of market conditions with low correlation to traditional assets. (f)

Multi-Asset Risk Premia

Commodity Risk Premia – The strategy sells straddle options on several commodities and delta hedges the exposures with the respective underlying futures contacts, adding to the client’s diversified risk premia portfolio. Inflation Risk Premia – The strategy receives the fixed leg of Zero-Coupon inflation swaps, targeting the Inflation Risk Premia embedded in market pricing of such inflation instruments. FX Short Volatility – Sells call and put options on FX forward rates and delta hedges the exposures, targeting the risk premia in currency option pricing. Private Markets (g)

EM Local Debt

Record’s FX Alpha offering combines multiple systematic return drivers into a balanced portfolio that targets consistent returns in a variety of market conditions. The strategy is diversified across developed and emerging markets and allocates to each through a mix of fundamental and quantitative signals. The unique sources of return exploited over multiple time horizons and risk regimes aim to deliver a stable return that is uncorrelated with risks elsewhere in client portfolios. Importantly, the strategy can be run unfunded (as an overlay), simply adding to the returns generated elsewhere in the portfolio. A funded implementation (over cash and/or asset) is also available. (h)

Emerging / Frontier markets

During the period, the new CEO has instigated a strategy that includes looking into services aimed at emerging markets. By their nature, these are higher risk and as part of the new product approval process, due diligence and risk assessment are currently underway in order to assess the risks posed before making any final decisions. For the purposes of this risk assessment, I have included some reference to this activity although it remains ongoing. The RCML Board will need to approve the establishment of any new high-risk relationship under our current processes – which will only be done once the risk assessment and due diligence processes have been complete (all Board members are aware of the ongoing processes).

Ancillary services (i)

Interest Rate Hedging – Provide a range of interest risk management solutions for fund managers that can significantly reduce the administrative burden typically associated with bank onboarding. (ii) Cash management - Some user entities retain Record to manage a cash pot which is set aside to service settlements or cover margin calls arising from the main currency product. Cash may be invested in short-term government securities or placed on deposit to target a cash return. (iii) Futures overlay - Record targets enhanced cash return by seeking exposure to the relevant and appropriate markets (e.g. S&P500 or Long Gilts) through the management of exchange traded futures, as agreed with the user entity. (iv) Bespoke / tactical currency assignments - Record is able to construct bespoke currency programs in response to specific client requirements, which can be tactical and relatively short-term in nature. Such assignments can include instruments such as currency options, credit derivatives, and interest rate swaps, in addition to forward foreign exchange contracts. (v) Fiduciary execution services - Record regularly executes spot transactions relating to the underlying purchase or sale of securities by user entities or the underlying managers and simultaneously adjusts the currency hedging program to reduce cost and avoid any slippage between the underlying transaction and the hedge. Some user entities instruct Record to execute spot transactions unrelated to any associated hedging activity, and any such transactions attract a per trade fee. (vi) Collateral and Liquidity Management - Record offers a service to manage and monitor a user entity’s daily margin requirements, either due to a regulatory requirement or to manage counterparty exposure. Record’s liquidity management proposition consists of assessing and monitoring how much liquidity is required to meet the margin requirements associated with the program. As above, Record can implement a strategy (in line with liquidity needs and return objectives) to minimise cash drag by managing any surplus cash to earn a return. (vii) Provision of signals – for the Client to trade (or have traded) on their own or their clients’ accounts. (viii) Partnerships – Record acts as a referral agent for specific third-party investment management strategies. Our advice is limited to the types of investments stated above. AUM Record Currency Management AUM as of March 31, 2026: US$ 114.5 billion. The composition of AUM by product were as follows: Product

USD (bn)

%

Passive Hedging

75.8

66.2%

Dynamic Hedging

17.0

14.8%

Solutions for Asset Managers

17.0

14.8%

FX Alpha

2.6

2.3%

Custom Opportunities

0.8

0.7%

Other

0.3

0.3%

1.0

0.9%

Risk Management

Absolute Return

Private Markets EM Debt

Clients may also be subject to additional fees in relation to services provided by Record but these fees are not controlled or influenced by Record. Typical types of additional fees that clients may face and consider are custodian fees and prime broker fees where applicable. Record has never received any soft commission. Record has third-party introducer arrangements in place with respect to both clients being introduced to Record as well as Record introducing clients to selected partners. This is separately disclosed to any impacted client. Record has a commission structure in place for new segregated mandates where eligible staff may receive a proportion of management fees which is independent of the Group Profit Share & Share Incentive Schemes. Record compensates its affiliate, Record Inc. via a management fee agreement. Record’s US sales executives receive a salary and participate in group profit share schemes. Our only income, hard or soft, is either:

Currency management activity – only fees Record receive are the fees paid to us by our clients. As a result, our execution of client trades is entirely price-driven i.e. to achieve the best possible outcome for our clients, with no other criteria (except for any agreed credit criteria) applied.

Introducer fees – Record receives a percentage fee for clients introduced to selected partners. This is disclosed to any impacted client.

Record’s standard process is to set up a panel of banks with whom to trade on the client’s behalf and this is done via netting agreements. This ensures diversification across a number of counterparties in order to reduce credit risk. Record has a documented Credit Risk Policy which makes this process clear.

Record has Conflicts of Interest and Code of Ethics policies in place.

As per Item 5 above, FX Alpha, Passive, Enhanced Passive, Active Hedging, Solutions for Asset Managers and Multi-Asset Risk Premia fees consist of either a management fee based on the gross value of currency positions managed or a lower management fee on the same terms with an additional performance fee charged on returns above an agreed benchmark. The above combination means that Record operates “side -by-side management” of accounts in that we manage a variety of accounts which may in some instances be the same strategy for a different fee structure. This gives rise to potential conflicts of interests and we discuss below how these potential conflicts are dealt with. Record manages all client accounts in the utmost good faith and our primary aim is to ensure we achieve the best results for our clients. Our dealing policies make our processes clear and adherence to these policies is ensured by management oversight, compliance oversight and both internal and external audit functions. Conflicts of interest relating to performance-based fees when engaging in side-by-side management Record fees are derived from fees paid by clients and this can be on a fixed management fee or a management fee plus performance fee basis. It is standard practice to set management fee plus performance fee scales for clients at a modest premium to a management-only fee structure when viewed over a full cycle, such that Record is compensated for the additional volatility in revenues from performance fees. In other words, Record is indifferent to a management fee only or a management fee plus performance fee because in a full cycle of investment performance, both fee options would, broadly speaking, contribute similarly to shareholder value. This is a deliberate design characteristic to avoid any conflict between different fee structures.

In provision of investment services, conflicts of interest may arise between Record Currency Management Limited (RCML) and clients; between clients and other clients; between RCML clients and Record Inc. (RINC) or Record Asset Management GmbH (RAM) clients; between RCML and RINC/RAM (and any other regulated group entity) and between RCML and Record plc (RPLC). All of these potential conflicts are managed, with further details on four main areas of potential conflicts given below. 1)

Client dealing

RCML has Best Execution, Order Allocation and Order Handling policies in place and all orders are executed in accordance with these policies. All orders are generated in compliance with the parameters agreed with each client and documented in the relevant Investment Guidelines. The majority of orders are systematically generated and the nature of the systematic investment process and the instruments that are traded means few conflict issues arise. Timing of order execution Client programs are independently set up within RCML’s systems to spread the daily trading activity across the trading day so that no individual client is always traded at the same time, but that clients participate in trading at different times of the day. Disaggregation of orders Client orders may be disaggregated prior to execution. This may be done to the extent required to achieve normal market size transactions that will be likely to result in the best price. Trades are generally executed in total and the client will receive their full allocation at point of execution. Where trades for a number of clients are disaggregated and executed in tranches, the system ensures that each client participates in each tranche in proportion to their initial order, and hence achieves the same average price. Aggregation of orders Client orders may be aggregated during the execution process; aggregating buy orders, aggregating sell orders or aggregating buys with sells. In all cases, each client will receive the same price. In the example where the net trade is a purchase, the client(s) on the sale side of the trade will benefit by receiving the purchase side of the price, and will have thus crossed the spread. The client(s) on the purchase side of the trade will also receive the purchase price. The client(s) on the purchase side is therefore not disadvantaged by the process of netting the trades; however, the client(s) may benefit from receiving an improved price due to the net size of the trade being smaller. Discretionary decisions RCML client dealing Where discretionary decisions are made (either within the parameters of systematic strategy manuals or for bespoke discretionary currency management services), each decision takes account of any potential conflict. Discretionary decisions are made by members of staff who are not involved in the processing of orders and if any conflict is identified the order would not be processed. Where discretionary override is permitted, the decision-making processes involve more than one individual and record-keeping rules require full documentation of reasons for the decision, taking account of individual client objectives (where the decision is specific to an account rather than across all accounts), base currency, exposure and market conditions at the time.

2) RCML Non-execution services vs orders for clients Hedging signals RCML may provide hedging signals to clients who subsequently execute trades themselves (or through a third party) over a period of time. Before or after providing these signals, RCML may execute orders for other clients generated by similar (or different) signals. The independent and predominantly systematic nature of all signal- and trade-generating processes, and the controls set out above under “Discretionary decisions”, mean that no orders are executed for clients on the basis of any other client activity or orders. Back office services RCML may provide trade booking, confirmation or other back office services to clients. In providing such services, RCML will have access to detailed trade information from the client which RCML would not ordinarily have access to. This information is not taken into account in any way in relation to the ongoing discretionary management of any other client account. 3) Revenue / Income All income arises from fees paid to RCML by clients and partners in accordance with contractual arrangements. RCML and Record Inc. receive no third-party payments for order flow. Management Fees vs Performance Fees RCML fees are derived solely from fees paid by clients and this can be on a fixed management fee or a management fee plus performance fee basis. It is standard practice to set management fee plus performance fee scales for clients at a modest premium to a management-only fee structure when viewed over a full cycle, such that RCML is compensated for the additional volatility in revenues from performance fees. In other words, RCML is indifferent to a management fee only or a management fee plus performance fee because in a full cycle of investment performance, both fee options would, broadly speaking, contribute similarly to shareholder value. This is a deliberate design characteristic to avoid any conflict between different fee structures. Record Inc. fees are paid under a transfer pricing agreement for services provided to RCML. Bespoke Benchmarks RCML will on occasion agree a bespoke benchmark with clients in order to measure performance of specific additional services. In these instances, the benchmark is documented and methodology for constructing the benchmark is agreed. RCML has in place robust procedures to ensure these agreed methodologies are adhered to and if any deviation occurs, these are raised with the relevant client in an open and transparent way. Cash and collateral management In certain circumstances, cash may be provided by clients to service margin requirements and / or service cash settlement arising from activity in one of RCML’s currency strategies. It may also be the case that any cash under management may be hedged by RCML. The appropriate amount of cash required to service margin and settlement is not absolute, and any cash provided by the client will increase and decrease as a result of positive and negative settlements respectively. RCML will review cash under management for each client on a regular basis to ensure it remains appropriate for the purposes of margin and settlement. The amount of cash may be adjusted up or down as required to avoid any conflict with fees charged on cash management assignments, and / or fee income on hedging cash balances.

Directed brokerage RCML does not pay or receive commissions for any orders executed. FX orders executed via bank order handling algorithms have a fixed cost per million. Futures orders have a fixed cost per transaction. Orders via prime brokers will be charged a fixed cost per transaction, subject to the total cost per month exceeding an agreed minimum fee. Clients may elect to trade via a smaller number or via named counterparties with bespoke charging arrangements. This is the client’s choice and RCML will execute orders within such parameters agreed with any client. Discretionary decisions linked to increased fees On some discretionary accounts, RCML has the discretion to amend hedge ratios or add currencies to be hedged which would result in receiving additional fees. This conflict is managed by discretionary decisions requiring multiple approvals together with RCML’s fiduciary obligation to only do what is in the client’s best interest. Management fee added to spread On some discretionary accounts at the client’s request, RCML’s management fee will be taken by a spread added to the traded rate. The panel of counterparty banks used, will then reimburse the accrued management fee to RCML on a regular basis. Each client who selects this payment option confirms this as a contractual term and it is fully disclosed in client reporting that the traded rate will include RCMLs management fee. There is no other management fee payment made by clients who select this payment method. The reimbursement received from counterparty banks, is not a commission as it is a contractual fee agreed by the client which the bank has no discretion over. Employee considerations Incident management Record has in place a Risk Management Framework to ensure all incidents are reported and all incidents are assessed against RCML’s Error Policy. If any incident is deemed an error, then an assessment of any compensation amount that may be due would be carried out. Personal Account Dealing In order to ensure clients’ interests are put before those of any staff at Record there is a Code of Ethics in place which requires that staff provide duplicate contract notes within five days for all reportable transactions which are then reviewed by the Compliance Department. Certain instruments with an inherent conflict with the services we offer clients require prior approval which must also be obtained from Compliance. It is possible for Record staff to invest alongside external clients in Record Funds. If this occurs then (1) staff will be treated pari passu with external clients and (2) dealing in these investments will be covered by the Code of Ethics policy, such dealing also includes strict rules governing when staff can invest in, or divest from, the funds. Inducements There is a Gifts and Entertainment policy in place to ensure that all gifts received or offered are appropriate and do not constitute an inducement of any sort. When provided to or received from a counterparty bank, Record policy allows for the provision of gifts up to £100 and entertainment up to £250. Management may approve individual instances over £250 if this is appropriate. Any entertainment with counterparty banks is always on the basis of enhancing the service we provide to our clients. Compliance is involved in these processes from pre-approval in some instances to ongoing monitoring and record keeping.

Remuneration RCML, RINC and RAM have never received any soft commission. RCML has third-party introducer arrangements in place for clients introduced through specific firms and the nature of the arrangement would be disclosed to any prospective client. General staff remuneration is not linked to specific department or client activity and the profit share scheme is directly related to the total profitability of the company over a given period of time, currently six months together with personal objectives / sales targets. Certain client facing staff may be eligible for commission payments based on a percentage of management fees. Record’s Remuneration Policy is approved by the RPLC Remuneration Committee, which is made up solely of Independent Directors and any change to policy must also be approved by Compliance. Record Group considerations RPLC is listed on the London Stock Exchange and is the parent company of the Record group of companies. Clients contract directly with RCML being the regulated entity which carries out trading on behalf of RCML, RINC and RAM. 1)

Record Asset Management (GmbH)

Record Asset Management (RAM) is the German Asset Management firm which is registered with BaFin. As a group company utilizing group services, confidentiality between group businesses is paramount to the group and Chinese walls have been incorporated into group services provided so that there is no cross contamination of confidential information. Some Senior Managers across the entities have access to data due to the small number of staff but all are regularly reminded of their conflict management obligations and access is restricted as much as possible to a need to know only. RAM submits client orders to RCML for execution. 2) Record Group Dealing RPLC subsidiaries will from time to time convert non-Sterling receivables into Sterling. The direction of the trade is always the same. The order is placed by the Finance department, who are independent of the trading and portfolio management teams, and is passed to the traders for execution. Any such order is executed by the traders and strictly only after all trading for clients is completed. RPLC subsidiaries may also appoint RCML to manage seed strategies in order to establish a track record (see details below). RCML cash reserves are managed in accordance with prudent and efficient treasury management principles. If a decision to use a foreign exchange forward for these purposes is made, this trade will always be executed after client trading has been completed. 3) Transactions where RPLC is involved New strategies may be seeded by RPLC, and / or its Directors, subsidiaries and staff from time to time and at the discretion of the Board of RPLC. Seeded strategies are by their nature small in size relative to client mandates. Any transactions executed in respect of seeded strategies are likely therefore to have minimal market impact. To avoid possible conflicts, seeded strategies will, whenever possible, trade only after all client orders have been completed. However, on occasion a seeded strategy with specific investment objectives will be traded sequentially along with client orders. Any such strategy is only ever to establish a track record as part of new strategy procedures and will be specifically documented and available to any client on request. 1

At the discretion of the Record plc Board, other new strategies may be seeded.

In the event that such seeded strategies attract external investment, then RPLC, Directors and staff are treated pari passu with external clients, and any staff dealing is covered by the Code of Ethics. Conditions for divestment of seed investments are such that no detriment is caused to any clients who have since invested in the strategy. Conditions for divestment are for the funds to have reached a certain size and for there to be a notice period of not less than one week between the decision to divest and the execution of that decision. Any subscription or redemption by staff is covered by the Code of Ethics and requires pre-approval by Compliance. 4) Record plc, Record Currency Management Limited and Record Currency Management (US) Inc. Should any situation occur when a conflict of interest arose between the interests of the client of RCML or RINC/RAM against the interests of the Shareholders of RPLC then such matters must be escalated to, and any decisions ratified by, the Audit Committee. The income of RPLC is based on dividends supported by RCML, Record Inc. and RAM fees, advisory, management and performance based (as well as income from unregulated group businesses). The financial success of RPLC is therefore directly correlated with investor returns and AuME. In addition, the success of RPLC depends on maintaining strong long-term relationships with clients and a strong reputation in the market to attract new clients. Given the alignment of interests and the long term nature of the business model, a conflict between RPLC, RCML, RINC and RAM would be considered to be a rare occurrence. Executive Directors are also shareholders of RPLC and their financial interests are therefore aligned to the development of the share price. A conflict could arise if management decisions were taken that favoured the short-term share price performance (prior to a large sale of shares) over long-term share price considerations. Given the long term nature of the underlying client relationships there is little opportunity for such a conflict to arise. Where management action is likely to affect the short-term share price performance the Board has the obligation and the power to manage that process, and where necessary, may limit the ability of the individuals, particularly those PDMRs or Investment Committee or Emerging Markets & Fronter Committee members recommending the measures, to trade for a period of time.

Passive Hedging The Passive Hedging strategy is non-discretionary hedging of a proportion of the client’s international assets. Passive hedging involves the symmetrical elimination of currency volatility, whether beneficial or adverse. Record’s passive hedging programs are designed to minimize transaction costs, to make the resultant cash flows easier to manage and to add opportunistic value through active tenor management. Active Hedging The Dynamic Hedging strategy allows discretion around the extent of hedging in place and is systematically applied to remove foreign currency exposure during periods where those currencies are observed to be weakening against the base currency. Dynamic Hedging imposes a systematic process seeking to protect clients from adverse currency movements, whilst allowing clients to benefit from positive movements. This is therefore an asymmetric process, which is designed to provide downside protection. The Signal Hedging strategy uses rule-based and quantitative methods (based on interest rate differentials, momentum and value) that seek greater exposure to hedges that are expected to be profitable, and reduced exposure to hedges that are expected to be loss-making. The quantitative signals are used to determine the hedge ratios on each exposure currency on a periodic basis. FX Alpha The FX Alpha strategies use largely systematically applied proprietary investment approaches which seek to add excess return over an agreed benchmark. Record has a range of return-seeking strategies. These take advantage of key return opportunities in the currency markets, in particular currency carry and emerging markets. Carry Carry is the observation that higher interest rate currencies tend to outperform lower interest rate currencies. At Record we regard Carry as a fundamental and independent risk premium. Returns vary according to the risk budget applied. Programs can be structured to meet a wide variety of risk/return objectives.

Emerging Markets Long/Short (EMLS) EMLS targets return from investment in EM and select DM currencies via exploitation of currency risk premia factors with no directional EM view taken: real exchange rate appreciation due to stronger productivity growth, reversion back to fair value, and carry risk premia. We have a range of strategies that are intended to exploit the long-term appreciation potential of emerging market currencies and Record offers both passive and active strategies through either pooled fund structures (pooled funds are not currently publicly marketed in the US) or segregated accounts. Opportunities also exist for optimizing existing emerging market currency exposure in underlying equity and bond portfolios. Financial Fair Value (FFV) FFV targets return from medium-term currency misvaluations by analysing non-FX asset classes (equities, commodities, interest rates). The evolution of these asset classes can explain some of the movements allowing the residual unexplained misvaluations to be exploited. Value Record’s research suggests that purchasing power parity (PPP) valuation models are relatively good predictors of the long-term direction of spot movements. For example, if a currency deviates too much from its equilibrium value (as indicated by PPP), then this deviation will correct. The more significant the deviation, the more pressure on the exchange rate to revert to fair value and, consequently, the more rapid the reversion. Currency value strategies exploit this insight, buying currencies that are undervalued relative to PPP and selling currencies that appear overvalued. Range-Trading Range-Trading in currency is the observation that short-term FX volatility overpredicts the drift of currencies over the longer term, on average. In markets where there is short-term excess supply versus demand, the price must move to incite the entry of liquidity providers to clear the mismatch. Once the imbalance is cleared, prices will likely revert towards their previous level. Range-Trading seeks to profit by selling (buying) currencies as they appreciate (depreciate) and buying (selling) them back was they revert. Positions are taken based on the delta of a hypothetical option position. Developed Market Classification (DMC) Developed Market Classification uses a quantitative machine learning model to systematically allocate to various currency factor groups based on their perceived ability to explain outturn G10 vs. USD currency moves. Emerging Market Classification (EMC) Emerging Market Classification uses a quantitative machine learning model to systematically allocate to various currency factor groups according to their perceived ability to explain outturn EM vs USD currency moves. Multi-Strategy The product consists of seven standalone strategies – Carry, Value, Financial Fair Value, Emerging Markets Long/Short, Range Trading, DMC and EMC – that aim to exploit a diverse range of FX market risk premia. These strategies have low or negative correlation with one another and, when combined, with major equity and bond universes. The product is designed to target attractive risk-adjusted returns over a full market cycle and under a variety of market conditions.

Counterparty exposure Due to the primary use of over-the-counter (OTC) instruments, clients have exposure to different counterparties. Record is conscious of this exposure and has in place a Credit Risk Policy designed to mitigate this risk (amongst others). This policy is overseen by the Risk Management Committee and counterparties credit ratings are reviewed daily. Additionally, variation margin may also be used or in some cases prescribed by regulation to mitigate and reduce counterparty exposure. Record also promotes the investment strategy provided by selected partners. For completeness: Record’s selected partner, Teres International, provides bespoke return -seeking strategies designed for individual clients or within pooled funds. Each bespoke strategy would be agreed between the relevant Teres International Company and the Client.

Record has partnered to provide investment services and marketing for a selection of Teres International Group entities or clients, based in multiple jurisdictions for example Luxembourg. Teres International is an investment firm that specializes in identifying investment opportunities at the juncture of technological advancement and the financial world. They work with their clients and partners to deliver bespoke structured financial and fintech solutions. Inte Securities LLC (CRD#47107 & SEC#8-51667) - a non-exclusive arrangement for the introduction of Prospective Clients.

Other transactions must be declared on a quarterly basis. For itself, the only financial market transactions that Record undertakes are spot and forward foreign exchange contracts as well as cash management activities. The sole reason for this is to ensure the foreign exchange receivables are fixed in Sterling terms i.e. a transaction hedge and efficient cash management. A copy of Record’s Code of Ethics is available on request.

after the potential downgrade) will apply; Notwithstanding a long-term credit rating at or above the minimum threshold set out below, the Credit Committee may still decide not to include a counterparty on the relevant Approved Counterparty List. A variety of factors will be taken into account including, but not limited to credit rating history, both long and short term, credit default swap daily price movement, and the regulatory regime covering the counterparty; Counterparties with a long-term credit rating of BBB/Baa2 and above may be included on either Approved Counterparty List, at the discretion of the Credit Committee, after careful consideration of factors including, but not limited to credit rating, credit default swap levels, the regulatory regime covering the counterparty and their capital adequacy rules, size and standing of the counterparty in the particular region and the status of any government backing; Any downgrades below the relevant threshold will require the Credit Committee to re-affirm the inclusion of the counterparty on either Approved Counterparty List; The removal of a counterparty from either Approved Counterparty List will result in: (i) no new transactions, except to reduce risk; and (ii) run-off of existing transactions. In some circumstances, the Credit Committee may instruct outstanding positions to be closed and realised in a prudent, but timely manner, as approved under Section 5 Discretionary Decisions Tier 1 criteria (e.g. pensions schemes, foundations, etc.): The minimum threshold for a counterparty to be included on the Tier 1 Approved Counterparty List is a long-term rating of A+/A1 for uncollateralised trading and a long-term rating of BBB/Baa2 for collateralised trading Tier 2 criteria (e.g. unregulated funds, special purpose vehicles, etc.): The minimum threshold for a counterparty to be included on the Tier 2 Approved Counterparty List is a long-term rating of BBB/Baa2 (regardless of the collateralisation status). By default all clients will adopt the Tier 1 Approved Counterparty List, unless the Record and the client agrees that counterparties are selected from the Tier 2 Approved Counterparty List.

Client specific requirements Subject to agreement by Record Currency Management Limited, a client may elect to opt out of this policy in its entirety or stipulate their own credit criteria, approved counterparties or bespoke counterparty panel which may include counterparties that are not on the Approved Counterparty List. Collateralization In order to mitigate credit risk, Record will look at various options that may include collateralization. In some jurisdictions, this may be driven by regulatory obligations. As there are various types of collateralized arrangements on offer, which may include an external party providing the collateralization

services, each solution will be assessed on its merits. It is acknowledged that collateralization does not remove all credit risk. There is a risk that the collateral received from a counterparty does not cover the valuation of the position, for example where there is a minimum transfer amount, while any haircuts have an element of credit risk by their nature. Best Execution Policy This Policy describes how Record achieves best execution for its clients. At the outset the following factors should be borne in mind when reading this policy:

The Foreign Exchange Market (where the vast majority of Record trading takes place) is one of the most liquid and sizeable markets in the world with many competing market makers and with prices moving within milliseconds. As soon as a trade is struck the price will have moved. Transactions in the wholesale Foreign Exchange Market attract no direct fees; the bid/ask spread determines the price for participation. Record does not earn commission on its trades and there are no conflicting entities within the Record Group.

1.1 Purpose The purpose of this policy is to document Record Currency Management’s approach to Best Execution. 1.2 Regulatory background The FCA requires investment firms to provide their clients with Best Execution. This is set out in their Rulebook and states “A firm must take all sufficient steps to obtain, when executing orders, the best possible result for their clients taking into account the execution factors”. 1.3 Overview of Record’s approach Record operates under discretionary management agreements with each of their clients, which describe the Investment Guidelines within which Record can act. Record acts as agent for all client orders that are executed. Record is not the counterparty to any of the orders executed; the counterparties to the order are the client and the counterparty bank with whom the order is executed. Record has no ties to any counterparty banks, does not earn commission on the orders it executes and there are no conflicting execution venues or counterparties within the Record plc Group. Record has a Conflicts of Interest Policy that is provided to all clients. 1.4 Scope of instruments covered Record executes orders across multiple asset classes and, as at the date of this policy, the following are covered:

Foreign Exchange (spot, deliverable forwards, non-deliverable forwards, options) Exchange Traded Derivatives (index futures, rate futures, bond futures) Regulated Trades (MAT Rate Swaps) Fixed Income (Treasury Bills, Treasury Inflation Protected Securities (TIPS), Bonds) Other OTC derivatives (Inflation, Interest rate, Credit, Fixed Income and Equity OTC derivatives)

In any other circumstances, Traders will make an assessment on a case by case basis, using their experience to select the most appropriate execution methods, and in selecting the most appropriate counterparty with whom to transact, in order that the best overall result for the client is achieved.

Item 2. Foreign Exchange 2.1

Background

This section covers the majority of orders executed by Record. The Foreign Exchange Market is one of the most liquid and sizeable markets in the world; there are many competing market makers and fast-moving rates and prices, while a ‘bid/offer spread’ ordinarily determines the price for par ticipation. 2.2

FX Global Code of Conduct

The FX Global Code of Conduct is a set of principles of good practice for foreign exchange market participants covering ethics, governance, execution, information sharing, risk management and compliance, and confirmation and settlement processes. Record has signed a Statement of Commitment to the FX Global Code, and Record will conduct all aspects of its business in a manner consistent with the Code, in particular with respect to execution, but equally with respect to the other principles. 2.3

Counterparty Banks Selection

Record maintains trading relationships with a range of counterparty banks, in order to access a wide amount of the market’s liquidity. For each individual client, Record will seek to put in place a diverse counterparty list, taking into account certain factors which will determine the makeup of each individual list: 2.4

Counterparties are on the Approved Counterparty List (ACL); the criteria for inclusion on the ACL are documented in Record’s Credit Risk Policy Counterparties are willing to grant the client an FX credit line Clients specific requirements Number of counterparties each client is willing to exchange collateral with (where applicable) Suitable netting agreement in place Execution Factors and Process

Record takes into account the following execution factors when executing an order for any particular client: 1.

Counterparty Limits

2.

Market Conditions

3.

Price

4.

Speed

When executing an order Record will first take into account any client specific counterparty limits documented in the Investment Guidelines. Record’s traders will examine the order to be carried out bearing in mind the prevailing market conditions (e.g. volatility, data releases); the trader will look to execute orders in the most liquid part of the day, taking into account the currencies involved in the order. The trader will decide whether the order is best carried out aggregated with other orders or disaggregated into several smaller orders to ensure a “market size” order, i.e. an order of a size that can be absorbed by the market under prevailing conditions. The policy for aggregating transactions is detailed in the separate Order Allocation Policy. Subject to any counterparty limits and the trader’s assessment of the market, the most important execution factor is price (which can be a function of market spreads, credit costs, or a combination of both). In order to ensure the quotes received are in line with the market, the traders will compare them to market price feeds, and prices from these feeds are captured automatically at the point of execution. Where

appropriate we will ask for quotes from multiple counterparty banks. The winning and losing quotes are stored for analysis referenced in Section 8. Speed will only be taken into account when a counterparty is deemed to have taken an excessive amount of time to quote for an order, such that the market is likely to have moved significantly from the point at which it was observed originally. The trader may execute any order either electronically via a multibank system or recorded communication channel, via an algorithm, or by telephone. The method of execution is at the discretion of the Trading Team, and is influenced by the execution factors detailed in 2.4. Automated workflow-based execution, feeding into these methods of execution, may also be used at the discretion of the Trading team. In some cases, order execution may target an agreed benchmark rate. Record will monitor the benchmark rate price offerings from the available counterparties and choose the counterparty which offers the best all in price.

Item 3. Exchange Traded Derivatives 3.1

Background

All exchange traded derivative (ETD) orders are executed on a Recognised Market/Investment Exchange. The relevant exchange is consistent with the contract being transacted. 3.2

Counterparty Broker Selection

Record’s clients do not have direct membership to any exchange. Record passes orders to futures brokers who execute the orders on Record’s clients’ behalf on the exchange. Futures brokers do not take market risk from the orders received by Record and thus are financially remunerated by clearing and execution fees. These fees are pre-agreed with each futures broker on a contract by contract basis. Record will engage with various brokers in order to ensure fees are reasonable and fair. In many circumstances a client will only have access to one futures broker; this is primarily due to the relatively low volume of exchange traded derivative orders executed and minimum fee clauses. 3.3

Execution Factors and Execution Process

Record takes into account the following execution factors when executing an ETD order: 1.

Costs

2.

Price

Record instructs the broker to undertake the transactions by telephone, electronically or recorded communication channel. The futures broker is obliged to complete the order in accordance with their own policies and procedures relating to Best Execution. Alternatively Record may execute orders via Direct Market Access; in this case the role of the broker is to give Record direct access to the exchange via their membership. In order to achieve the best result for the client with respect to the investment objectives, Record may instruct the broker to carry out the order at a particular time of day. This may be, as examples, the cash close or the futures close. This will be dependent on the contract being traded and the liquidity conditions. This practice seeks to maintain a low tracking error vs the client’s benchmark. Record may also execute orders at other times, subject to investment objectives and any specific instructions from Record’s Investment Management Group, individual client or Portfolio Manager. Futures orders may be aggregated, and the policy for aggregating transactions is detailed in the separate Order Allocation Policy.

Item 4. Fixed Income 4.1

Background

All fixed income orders are executed via a counterparty bank. The instruments which are bought and sold are debt instruments issued by national governments or supranational entities. 4.2

Counterparty Broker Selection

Record maintains trading relationships with a range of counterparty banks. For each individual client, Record will seek to put in place a list of eligible counterparties, taking into account the fixed income instruments the client wants to execute. 4.3

Execution Factors and Process

Record takes into account the following execution factors when executing any order: 1.

Exposure limits

2.

Liquidity

3.

Cost

4.

Price

Record may purchase fixed income securities on behalf of its clients as an alternative to other money market instruments which have direct credit exposure to the counterparty bank. The primary objective is to diversify and reduce credit risk for the client. Record may purchase fixed income securities on behalf of its clients on the primary market or on the secondary market. When executing an order, Record will first take into account any client specific limits documented in the Investment Guidelines. Given that fixed income instruments are bought as an alternative to other cash instruments, it is also important to make an assessment of market liquidity to be able to sell the instrument back when the liquidity is required by the client. Subject to any limits and the liquidity of the instrument, separate considerations are then taken into account for orders executed on the primary or secondary market. Primary market orders involve Record placing a bid for a specific fixed income instrument with a bank. Record monitors any charge levied by each bank for accepting primary market orders, and seeks to place the orders with the bank which charges the lowest fee. Other than the fee, the achieved price will be identical irrespective of which bank the order was placed with, and consistent with the bid made. For orders executed on the secondary market, price is the primary execution factor. There can be significant differences in the fixed income inventories held by different fixed income banks, which can lead to different banks quoting different prices. Where possible, Record obtains more than one quote for a desired order. Record will execute at the best price from the available counterparties. The trader may execute any order either by telephone, or electronically via a multibank system or recorded communication channel. Fixed income orders may be aggregated; the policy for aggregating transactions is detailed in the separate Order Allocation Policy.

Item 5. Regulated trades 5.1

Background

All financial instrument that are mandated to be traded on a regulated venue must be traded via a Multilateral Trading Facility or Swap Execution Facility as applicable. 5.2

MTF/SEF Selection

Record maintains trading relationships with FXall, 360T and Tradeweb (who offer UK and EU MTFs and SEF venues). 5.3

Counterparty Banks Selection

Record maintains trading relationships with a range of counterparty banks, in order to access a wide amount of the market’s liquidity. For each individual client, Record will seek to put in place a diverse counterparty list, taking into account certain factors which will determine the makeup of each individual list: 5.4

Counterparties are on the Approved Counterparty List (ACL); the criteria for inclusion on the ACL are documented in Record’s Credit Risk Policy Counterparties are willing to grant the client an FX line Clients specific requirements Number of counterparties each client is willing to exchange collateral with (where applicable) Suitable netting agreement in place Execution Factors and Process

Record takes into account the following execution factors when executing any order: 1.

Client location

2.

Instrument parameters

The trader may only execute orders electronically via the applicable MTF/SEF.

Item 6. Other OTC Derivatives 6.1

Background

All OTC derivative orders are executed via a counterparty bank. These include inflation, interest rate, credit, fixed income and equity derivatives. 6.2

Counterparty Broker Selection

Record maintains trading relationships with a range of counterparty banks. For each individual client, Record will seek to put in place a list of eligible counterparties, taking into account the OTC derivative instruments the client wants to execute. In many circumstances, a client will only have access to a limited amount of counterparties; this is primarily due to the relatively low volume of other OTC derivative orders executed and the reduced coverage of these derivatives by the counterparty banks.

6.3

Execution Factors and Execution Process

Record takes into account the following execution factors when executing an OTC derivative: 1.

Counterparty Limits

2.

State of Market

3.

Price

4.

Speed

When executing an order Record will first take into account any client specific counterparty limits documented in the Investment Guidelines. Record traders will examine the order to be carried out bearing in mind the “state” of the market (volatility, acti vity, current news, etc.). This will also take into account the timing of key data releases. Subject to any counterparty limits, and the trader’s assessment of the market, the most important execution factor is price. In order to ensure the quotes received are in line with the market, the Traders monitor market price feeds, where available, showing current market prices/quotes currently available in the market. Where appropriate we will ask for quotes from multiple counterparty banks. The winning and losing quotes are stored for analysis referenced in Section 8. Speed will only be taken into account when a counterparty is deemed to have taken an excessive amount of time to quote for an order, such that the market is likely to have moved significantly from the point at which it was observed originally. The trader will execute any orders by telephone, recorded communication channel or electronically via order execution facility.

Item 7. Client Specific Instructions Individual clients may give Record certain execution parameters which we need to follow. This may limit the full spectrum of execution options available to the traders and they will execute under the specific criteria set for each order. For example, if a client requires Historic Rate Rollovers (HRR) as an option for their account, then this would become a primary execution factor and would mean the bank panel available would be based on banks who offer this as an option. Execution Factors and Process Record takes into account the following execution factors when executing an order for any particular client: 1.

Client bespoke requirements

2.

Counterparty Limits

3.

Market Conditions

4.

Price

5.

Speed

In some instances, clients may instruct Record to carry out transactions on their behalf. The traders will follow standard processes in carrying out any such transaction, bearing in mind any specific instructions from the individual client.

Item 8. Best Execution Monitoring and Reporting Best Execution monitoring is undertaken by the Traders, and is reported to Compliance, who review on an ongoing basis as part of the Compliance Monitoring Plan. Record utilizes a wide array of tools to monitor the Best Execution of all of the instruments traded. The monitoring is split into two main components:

Comparison of the achieved traded rate vs an independent “market” rate Comparison of the achieved traded rate vs the alternative quotes received at the time of the quote

All quotes for all executed trades, whether traded on or not, are stored and allow Record to assess the quality of the pricing from the counterparties. This analysis is fed back to the counterparties themselves, which engenders a more effective dialogue with the counterparties and illustrates where they need to improve in order to continue being requested to quote for trades.

Item 9. Best Execution Policy Review The Best Execution Policy is reviewed and approved by the Board on an at least annual basis.