London

Acadian Asset Management (UK) Limited (“Acadian UK”) has implemented a complaints handing policy to ensure that Acadian UK is able to handle client or potential client complaints promptly, easily and in a transparent manner.

This policy applies to all complaints (as defined below) originating from any type of client, including both retail and professional clients. Consideration has been given to the Financial Conducts Authority’s (FCA) sourcebook on Dispute Resolution: Complaints (DISP), which applies to complaints received from retail clients and complaints in respect of MiFID business.

Definition of a Complaint
Under UK MiFID II a complaint can be made by a client or a potential client. A complaint is any oral or written expression of dissatisfaction, whether justified or not (a “Complaint”).

Scope of Policy
The Policy applies to all employees of Acadian UK and will govern all complaints made by clients or potential clients. All complaints should be immediately directed to the compliance department.

Procedure
It is Acadian UK’s policy to assess all Complaints fairly and promptly and to take appropriate remedial measures on the basis of such assessment. Clients and potential clients may submit complaints free of charge. All Complaints will be treated as strictly confidential and we will communicate clearly with clients or potential clients in plain language. We shall reply to the Complaint without undue delay.

We will investigate any Complaints effectively, impartially, competently and diligently and will assess whether any remedial action or redress is appropriate, if we uphold the Complaint.

Additional requirements for Eligible Complainants (is defined in DISP 2.7.3R)

An Eligible Complainant may refer the complaint to the Financial Ombudsman Service (FOS) if they are dissatisfied, provided the complaint falls within its jurisdiction and the Complaint is referred within six months of receipt of a final notice or where a resolution is not reached within eight weeks.

Acadian UK will also provide the complainant with the FOS standard leaflet, found here: http://www.financial-ombudsman.org.uk/publications/consumer-leaflet.htm).

Please refer any questions to:

Acadian Asset Management (UK) Limited
Legal & Compliance
24 King William Street, 6th Floor
London
EC4R 9AT

Acadian Asset Management (UK) Limited is authorized and regulated by the Financial Conduct Authority ('the FCA'), registration number 460224. A private limited liability company incorporated in England and Wales with company registration number 05644066. It is not registered with or authorized by the U.S. Securities and Exchange Commission. Acadian Asset Management (UK) Limited is a wholly-owned affiliate of Acadian Asset Management LLC.

Acadian Asset Management LLC is registered as an investment adviser with the U.S. Securities and Exchange Commission. It is not registered with or authorized by the UK Financial Services Authority. Pursuant to the terms of service level agreements in place with Acadian Asset Management (UK) Limited, employees of Acadian Asset Management LLC may provide certain services on behalf of Acadian Asset Management (UK) Limited and employees of Acadian Asset Management (UK) Limited may provide certain administrative services, including marketing and client service, on behalf of Acadian Asset Management LLC.

Acadian UK provides investment management services to clients located in Europe and client service and support to clients located throughout the UK and Europe. Acadian UK has been authorized and regulated by the UK financial authorities since 2007 and is currently authorized and regulated by the Financial Conduct Authority. (Reg No 460224) (Private limited company Reg No 05644066).

Acadian Asset Management (UK) Limited’s Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Acadian Asset Management (UK) Limited (the "Firm") is required to include on this website 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.  Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance. We have detailed below the reasons why the firm has chosen not to commit to the Code.

The Firm pursues a quantitative strategy that involves investing in global equities, including UK equities.  The Code is therefore relevant to some aspects of the Firm's trading.  While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code.  The Firm invests in a variety of asset classes and in a variety of jurisdictions globally.  The approach of the Firm in relation to engagement with investee companies is determined globally, on a groupwide basis. The Firm and its affiliates take a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, is selective when considering committing to voluntary codes of practice.

The Firm notes the recent updates to the UK Stewardship Code in 2026 and is currently assessing the potential to become a signatory in due course.

For further information on the Firm’s approach contact:  information@acadian-asset.com.

Shareholder Rights Directive (SRD II)

SRD II aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on a regulated market. For these purposes, a regulated market is a Regulated Investment Exchange in the United Kingdom (UK RIE) that is recognised and supervised by the Financial Conduct Authority (FCA). Additionally, it can be an equivalent market outside the UK which meets comparable requirements and where the financial instruments dealt in are of a quality comparable to those in a regulated market in the UK. In the UK, it came into effect on 10 June 2019.

Acadian Asset Management (UK) Limited provides discretionary investment management services to a variety of clients, including institutional investors. In doing so, the Firm makes investment decisions on behalf of clients, including investments in shares admitted to trading on regulated markets (as outlined above). Therefore, the Firm is subject to the requirements of the SRD II as implemented in 2.2B Conduct of Business Sourcebook of the FCA Handbook (COBS 2.2B).

Under COBS 2.2B we are required to publicly disclose our shareholder engagement policy and on an annual basis, how this policy has been implemented. This includes describing how shareholder engagement is integrated into our investment strategy, how we monitor investee companies, exercise voting rights and manage actual or potential conflicts of interest. The Firm’s shareholder engagement activities are undertaken by Acadian Asset Management LLC.  The shareholder engagement policy can be found within the Annual Stewardship Report which is located here: https://www.acadian-asset.com/contact-us/london.This policy is reviewed regularly by the Firm to ensure that it continues to align with the requirements outlined in COBS 2.2B.

MIFIDPRU Disclosure

Acadian Asset Management (UK) Limited - Remuneration Disclosure

Stewardship Report