Stewardship Code Statement

STEWARDSHIP CODE STATEMENT

Last Updated: December 2025

1. Introduction

Karl Finance LLP (“Karl Finance“, “we“, “us“, or “our“) is the Sponsor and Investment Advisor to The Amplitude Fund. This statement sets out our approach to stewardship and explains how we consider the UK Stewardship Code 2020 in the context of our investment strategy.

2. What Is Stewardship?

The Financial Reporting Council (FRC) defines stewardship as:

“The responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.”

The UK Stewardship Code 2020 sets out 12 Principles for asset owners and asset managers, covering purpose, governance, investment approach, engagement, and reporting.

3. Our Investment Strategy

The Amplitude Fund employs a systematic, volatility-focused trading strategy using liquid, exchange-traded derivatives and ETFs. Our approach is characterised by:

We do not take long-term equity stakes in individual companies. Our strategy is based on market positioning and volatility capture, not corporate ownership.

4. Application of the Stewardship Code

The UK Stewardship Code is primarily designed for investors who hold equity or debt positions in companies and can exercise ownership rights (e.g., voting, engagement with management).

Given the nature of our strategy, many of the Code’s Principles do not directly apply to our activities:

5. How We Apply Relevant Principles

Purpose, Strategy and Culture (Principle 1)
Our purpose is to generate risk-adjusted returns for Professional Investors by systematically capturing opportunities in volatile markets. We operate with integrity, transparency, and a commitment to robust risk management.

Governance, Resources and Incentives (Principle 2)

• Karl Finance operates under the regulatory oversight of Falcon Investment Management Ltd (FCA FRN: 673552)
• Our portfolio manager is an FCA Approved Person
• Remuneration is aligned with investor outcomes through performance fee structures with a high-water mark

Conflicts of Interest (Principle 3)
We maintain a Conflicts of Interest Policy to identify, manage, and disclose conflicts. See our [Conflicts of Interest Policy] for details.

Promoting Well-Functioning Markets (Principle 4)

• We trade only on regulated, liquid exchanges
• Our algorithmic execution is designed to minimise market impact
• We do not engage in manipulative trading practices
• We support market integrity through compliance with all applicable regulations (MAR, MiFID II, exchange rules)

Review and Assurance (Principle 5)
Our policies and procedures are reviewed at least annually. Falcon’s Compliance team provides independent oversight of our investment activities.

Client and Beneficiary Needs (Principle 6)
The Fund is designed for Professional Investors seeking volatility-driven returns with robust risk controls. We communicate clearly about our strategy, risks, and performance.

ESG Integration (Principle 7)
Our strategy trades derivatives and ETFs on indices and commodities rather than individual company securities. Traditional ESG integration (screening, scoring, engagement) is not directly applicable.

However, we recognise that:

• Volatility events can be driven by ESG-related factors (e.g., climate events, geopolitical instability, regulatory changes)
• Our VISOR system incorporates macroeconomic and geopolitical signals, which may include ESG-adjacent considerations
• We do not knowingly invest in instruments designed to circumvent sanctions or facilitate harmful activities

Monitoring Service Providers (Principle 8)
We conduct due diligence on all key service providers (brokers, administrators, technology vendors) and monitor their performance on an ongoing basis.

6. Why We Have Not Sought Signatory Status

We have not applied to become a signatory to the UK Stewardship Code because:

• Our strategy does not involve holding equity or debt in companies
• We do not exercise voting rights or engage with corporate management
• The majority of the Code’s engagement and escalation Principles are not applicable to our activities

This is a considered position, not a lack of commitment to responsible investment. We keep this under review and will reconsider if our strategy evolves.

7. Commitment to Responsible Practices

Although formal stewardship activities are limited by our strategy, we are committed to:

• Operating with integrity and transparency
• Maintaining robust governance and risk management
• Treating investors fairly
• Supporting well-functioning, liquid markets
• Complying with all applicable laws and regulations

8. Review

This statement is reviewed annually and updated to reflect any changes in our strategy, activities, or regulatory expectations.

9. Contact Us

If you have any questions about our approach to stewardship, please contact:

Karl Finance LLP
Email: info@karl.finance