The Shareholders' Rights Directive ((EU) 2017/828) and Article L. 533-22 of the French Monetary and Financial Code require asset managers to develop and publish an engagement policy describing how they integrate shareholder engagement into their investment strategy and to publish annually how the engagement policy has been implemented. Alternatively, an asset manager must publish a clear and reasoned explanation of why it has chosen not to comply with one or more of these requirements.

CSAM has carefully considered whether it wishes to adopt an engagement policy and proceed with the communications described above and has, for the time being, decided not to do so.

CSAM is an alternative investment fund manager authorised in France under the AIFMD Directive (2011/61/EU). CSAM manages assets as part of the group's multi-strategy and multi-asset approach.

For the time being, CSAM does not trade equity securities. Thus, it has not established any policy to exercise voting rights. For the same reason, CSAM will not publish an annual report on its shareholder engagement policy.

CSAM may review its position and will update this section accordingly in case of any change in its approach.