Under the Financial Conduct Authority (“FCA”) Conduct of Business Sourcebook (COBS) rule 2.2.3R, Hilbert Investment Solutions Limited (“Hilbert”) is required to disclose whether it adheres to the UK Stewardship Code, published by the Financial Reporting Council (“FRC”). If the firm does not apply the Code, it must outline its alternative approach.The UK Stewardship Code is a voluntary framework promoting responsible investment and active engagement between institutional investors and UK-listed companies to enhance long-term value creation.Hilbert does not apply the UK Stewardship Code, as it does not hold voting rights in UK-listed companies. However, the firm recognises the importance of good stewardship and responsible investment. If its business activities change to include relevant holdings, Hilbert will review its position and consider adopting the Code’s principles.