Cerberus European Capital Advisors, LLP

UK Stewardship Code Disclosure
November 2016

In accordance with Rule 2.2.3R of the United Kingdom’s Financial Conduct Authority’s Conduct of Business Sourcebook, Cerberus European Capital Advisors, LLP (“CECA”), as an investment manager, is required to disclose 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 voluntary and sets out a number of principles relating to engagement by investors with listed UK and global equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with certain aspects of the Code, in which case they are required to explain their non-compliance.

CECA provides advisory, and in certain instances, investment management services regarding a number of investment strategies for the various Cerberus Funds and Accounts, subject to oversight from Cerberus Capital Management, L.P. (“CCM”). Such strategies involve investing predominantly in corporate credit, including senior secured and mezzanine loans and high yield, distressed and high grade debt securities, private equity controlled positions, real estate investment and investment in pools of non-performing loans in Europe and Asia. Investment in such products does not usually attract the stewardship responsibilities of an owner of publicly traded equities, although, from time to time, the Cerberus Funds and Accounts may invest in global equities for which the Code is relevant, including UK listed equities.

In following its investment strategies, CCM takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests, and consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction. Consequently, while CECA generally supports the objectives that underlie the Code, CECA has chosen not to commit to the Code.