The Contrarius Group Companies (“Contrarius”, “us” or “we”), understand that your privacy is important to you. Contrarius may process your personal data in their capacity as ‘data controllers’. We are committed to respecting your privacy and protecting your personal data. This Privacy Notice (“Privacy Notice”) describes how Contrarius collects, uses, discloses and protects your personal data, and your rights in relation to the personal data it holds.

The funds for which CIML is the appointed investment manager may have their own privacy notices, which set out how each fund and its delegates and their affiliates collect, use, disclose and protect the personal data of investors and potential investors in the fund. The relevant funds’ privacy notice can be accessed on the Contrarius website.

Contrarius will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail. We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of it which you may have had sight of.

By submitting your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
• Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.
• All of your representations made when agreeing to the terms of use of the website to establish a user profile for the website are true and correct to the best of your knowledge and belief.

What information do we collect?

You are not required to provide any personal information on the public areas of the website; however, you may choose to do so in order to register a user profile to obtain access to certain parts of the website or when contacting us.

Contrarius may collect a range of information about you. This could include:

• Contact information including first name, last name, telephone and fax numbers, e-mail address;
• Personal characteristics such as date of birth and country of birth;
• Government-issued Identification such as passports, national identity cards or tax identification numbers;
• Where you have been granted access to protected parts of our website, your log in information;
• In addition to the information you knowingly provide, we may collect certain technical information, including your Internet Protocol (IP) address used to connect your computer to our website. An IP address is an assigned number similar to a telephone number, which allows your computer to communicate over the internet.
• Data from third parties during the investment process. This may include fraud and anti-money laundering (“AML”) checks, know your customer (“KYC”) screening and checks required due to sanctions and anti-terrorism laws.

This list is not exhaustive and Contrarius may collect more personal data where it is required.

Sensitive personal data is a subset of personal data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as prescribed by law. We do not seek to obtain such data unless permitted to do so by applicable laws.

Why does Contrarius process personal data?

We collect and use your data in order to provide our services to you, to communicate with you about them, to comply with our legal obligations or when necessary for the purposes of our legitimate interests in effectively managing our business operations.

Who has access to data?

Your personal data may be shared within the Contrarius Group or with certain third parties for the purposes set out above. We maintain processes designed to ensure that any processing of personal data by the Contrarius Group entities or third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data.

In addition, Contrarius and/or the third parties may be required to disclose your personal data to the extent required by relevant regulatory, tax or foreign exchange authorities or law enforcement officials.

We will not sell your personal information or share it with third parties for use in marketing their products and services.

We may transfer your personal data outside the European Economic Area

Contrarius maintains physical, electronic and procedural safeguards to protect your non-public personal information. Even though we have taken significant steps to ensure that your personal information is not misused, you should know that we cannot fully eliminate security risks associated with personal information. The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be processed by individuals operating outside of the EEA who work for the Contrarius Group. This could include transfers of personal data to Jersey, Bermuda, Australia, South Africa, the UK and the USA. Certain countries may have different data protection standards to those which apply in the EEA. Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA in compliance with data protection law.

How does Contrarius protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does Contrarius keep data?

The retention period will be determined by the purpose for which we are using your personal data and any laws or regulation that may set a minimum or maximum period for which we have to keep your personal data.

Your rights

As a data subject, you have a number of rights.

You can:

• access and obtain a copy of your personal data on request;
• require Contrarius to change incorrect or incomplete data;
• require Contrarius to delete of stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You can find out more about your rights under data protection legislation at www.jerseyoic.org.

If you would like further information on how Contrarius uses your personal data, the exercise of any of the rights listed above or have a complaint, you may contact privacy@contrarius.com".

This updated Privacy Notice is effective 30 May 2023. If we change it, we will post a new version to https://www.contrarius.com/InvestWithUs/Policies

Cookies Policy

The use of cookies

We use cookies and similar tools on our website to improve its performance and enhance user experience. Cookies are small text files which a website may put on your computer when you first visit a site or page. The cookie will help our website to recognise your device the next time you visit, thus improving your experience of our website. We use the term "cookies" in this policy to refer to all files that collect information in this way.

The Contrarius website uses two types of cookies: session cookies and persistent cookies:

• Session cookies that are temporary and expire at the end of a browser session. The session cookie we use allows us to link your actions during a single browser session so you can use our website most efficiently.
• Persistent cookies that are stored on your equipment until deleted. An example is the cookie used to record if you have accepted the use of cookies on the Contrarius website by continuing to browse as normal. This cookie allows you to browse the Contrarius website in future without being shown our cookie notice.

This Cookie Policy applies to our website, mobile applications and emails and forms part of our Privacy Notice.

We reserve the right to update this cookie policy. Any changes will be posted within this page and become effective immediately. Continued use of our website constitutes your agreement to all such updates. If you require any further information about Contrarius’ use of cookies, please contact us at clientservice@contrarius.com.

Third Party Analytics

From time to time, the Contrarius website may use web analytics service providers, for instance Google Analytics, to help Contrarius analyse how users use the website. Third party cookies from Google are used in these instances which allows us to recognise, measure and track users of the website. The information collected includes the number of visitors to the website, where visitors have come to the website from and the pages they have visited. This helps us improve the way the website works, for example, by determining whether visitors can find information easily or by identifying aspects of the website that are of the most interest to them.

More information on “How Google uses data” can be found here: https://policies.google.com/technologies/partner-sites

Information concerning the terms and conditions of use and data privacy can be found here: https://marketingplatform.google.com/about/analytics/terms/gb/

Blocking Cookies

You can choose to accept or decline the usage of cookies by adjusting your browser settings. Cookie settings typically are found in the ‘Options’ or ‘Preferences’ menu of your browser. You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB

However, if you decline the use or prevent the usage of cookies on your browser, you may encounter problems browsing our website.

For more information about cookies and how cookie regulation affects you, please visit: http://ico.org.uk/for_the_public/topic_specific_guides/online/cookies.

This notice sets out how Contrarius ICAV (the “ICAV”) will process your personal information (as a Data Controller).

Where your details are provided to the ICAV as a consequence of your investment in the ICAV, then the ICAV, acting as a data controller may itself or through a third party such as KBA Consulting Management Limited (the “Manager”) acting in its capacity as the Manager of the ICAV, Apex Fund Services (Ireland) Limited (the “Administrator”) acting in its capacity as the ICAV’s administrator, Contrarius Investment Management Limited (the “Investment Manager” and the “Global Distributor") acting in its capacity as the Investment Manager and Global Distributor of the ICAV, and their affiliates process your personal information or that of your directors, officers, employees and/or beneficial owners, and this personal information may constitute personal data within the meaning of Data Protection Legislation (as defined below).

In connection with the above, please note the following:

Purposes of Processing and Legal Basis for Processing

Your personal data will be processed by the ICAV and its appointed processors including the Manager, the Administrator, the Distributor, the Investment Manager and other delegates or duly authorised agents or related, associated or affiliated companies acting as sub-processors on behalf of the ICAV. This processing of personal data will be for any one or more of the following purposes:

1. to facilitate the opening of your account with the ICAV and to manage and administer your holding in the ICAV and any related accounts on an on-going basis. The processing of your personal data is necessary for the performance of your contract with the ICAV, including without limitation the processing of redemption, switch, transfer and additional subscription requests, the payment of distributions, tax and other reporting to you or your representatives by email, and the provision of access to the www.contrarius.com website to view transactions and the valuation of your account;
2. to carry out anti-money laundering checks and related actions which the ICAV considers appropriate. This processing of your personal data is necessary to meet any legal obligations imposed on the ICAV and to pursue the ICAV and the Manager’s legitimate interests (and those of the Administrator) in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions. This processing is done in accordance with the ICAV's, the Manager’s and/or the Administrator's anti-money laundering procedures;
3. to report tax related information to tax authorities. This processing of your personal data is necessary in order to comply with legal obligations to which the ICAV and the Manager are subject;
4. to disclose information to public and Government authorities that regulate or have jurisdiction over the ICAV, the Manager, the Administrator, the Global Distributor, the Investment Manager and their delegates, agents or affiliates, so as to comply with legal, tax and regulatory obligations applicable to you and/or the ICAV and/or the Manager, the Administrator, the Global Distributor, the Investment Manager and their delegates, agents or affiliates;
5. to disclose information to third parties who provide services that assist the ICAV to manage and administer your holding in the ICAV and related accounts, including without limitation service providers of the ICAV, financial advisers, auditors, tax advisers, technology providers or to delegates of the ICAV and its or their duly appointed agents and any of their respective related, associated or affiliated companies. This processing of personal data is necessary: (i) for the performance of your contract with the ICAV; (ii) in order to comply with legal obligations to which the ICAV is subject; and (iii) to pursue the ICAV’s legitimate interests (including for the operations of the ICAV, network and data security and the prevention of fraud);
6. to monitor and record calls and electronic communications. This processing of personal data is necessary for: (i) the performance of your contract with the ICAV (e.g. this processing allows us to verify your instructions); (ii) the ICAV’s legitimate interest to detect, prevent, investigate and facilitate the prosecution of crime including without limitation fraud; (iii) the ICAV’s and/or the Administrator’s legitimate interest to improve service delivery (e.g. for quality, business analysis, training and related purposes); (iv) compliance with a legal obligation to which the ICAV is subject, to enforce or defend the ICAV and its affiliates, either itself or through third parties to whom it delegates such responsibilities or rights in order to comply with any legal obligation imposed on the ICAV; and (v) to pursue the ICAV's legitimate interests, including minimizing the risk of error and potential for disputes in relation to calls and electronic communications;
7. to carry out statistical analysis and market research in order to pursue the legitimate interests of the ICAV of improving our service to you;
8. to retain your anti money laundering and other records to assist with the subsequent screening of them by the Administrator, in pursuance of the ICAV’s and the Administrator's legitimate interests; and
9. for any other specific purposes where you give your specific consent.

Recipients of Data and International Transfer of Data

The ICAV and/or any of its delegates (including the service providers to the ICAV) and their affiliates may disclose or transfer personal data whether in Ireland, the European Economic Area (“EEA”) or to countries outside the EEA, including but not limited to Jersey, South Africa, Bermuda, Australia, the United States and the United Kingdom, in accordance with the requirements of Data Protection Legislation. Such countries may not have the same data protection laws as your jurisdiction. The ICAV and/or any of its delegates will not transfer personal data to a country outside of the EEA unless that country ensures an adequate level of protection or appropriate safeguards are in place or you have explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers to you due to the absence of an adequacy decision and appropriate safeguards, or the transfer is necessary for the performance of a contract between you and the ICAV or the implementation of pre-contractual measures taken at your request. The European Commission publishes a list of countries outside of the European Union ("EU") that are deemed to provide an adequate level of data protection. If a third country does not provide an adequate level of data protection, the ICAV will authorise its delegates, including the Manager, the Administrator, the Global Distributor and the Investment Manager to put in place the relevant contractual clauses concerning data protection with relevant parties outside the EEA to whom personal data will be transferred. Where applicable, you are entitled upon request to receive a copy of the relevant safeguard (for example, EC model contractual clauses) that have been taken to protect personal data during such transfer. Please contact the Administrator if you wish to obtain a copy of the relevant safeguard.

Data Subject Rights

You have the following rights, as a data subject, pursuant to Data Protection Legislation:

1. Right to be informed by the ICAV as data controller of the personal data it holds concerning you and the right to access such personal data. The ICAV will provide you with a copy of the personal data held by it as data controller as soon as practicable and in any event not more than one month after receipt of a valid written request. Generally, the ICAV will not charge you to access such personal data, except where a request is manifestly unfounded or excessive. The ICAV may also request proof of identification to verify an access request.
2. Right to request that the ICAV amend or rectify your personal information.
3. Right to request that your personal information be erased (in certain specific circumstances).
4. Right to restrict the use of your personal information (in certain specific circumstances).
5. Right to data portability in order to transfer your personal data to another data controller in a structured, commonly used, and machine readable format where this is technically feasible, subject to certain conditions.
6. Right to object to the processing of your personal data by the ICAV in certain circumstances.

Where the ICAV, the Manager, the Administrator or other delegates require your personal information to comply with anti-money laundering or other legal requirements, failure to provide this information means that the ICAV may not be able to accept/retain you as an investor in the ICAV.

You have the right to complain to the Data Protection Commission with respect to how the ICAV processes your personal data.

Retention Period

The ICAV, as a data controller within the meaning of Data Protection Legislation, undertakes to hold any personal information provided by you in confidence and in accordance with applicable Data Protection Legislation. The Administrator and the Manager may and will hold all or part of your personal data in accordance with applicable laws even after you have fully redeemed from the ICAV. Your personal data will be kept for no longer than is necessary for the purpose(s) for which it was obtained. In determining appropriate retention periods, the ICAV shall have regard to the Statute of Limitations, 1957 (as amended), and any statutory or regulatory obligations to retain information, including anti money laundering, counter-terrorism, revenue and tax legislation.

It is important that the personal data we hold about you is accurate and current. Please keep us informed, using the Contact Us details below if any of your personal data changes during your relationship with us.

Defined Terms

For the purpose of this notice, “Data Protection Legislation” means the Data Protection Acts 1988 to 2018 (as amended, extended or replaced from time to time) and the General Data Protection Regulation (Regulation (EU) 2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC and any implementing legislation and all amendments, extensions or re-enactments thereto. The terms "controller”; “data subject”; “personal data”; “processor”; and “processing” (and any derivations of this term) shall each have the meaning given to them under the Data Protection Legislation.

We may amend this privacy notice from time to time, to reflect any changes in the way that we process your personal data.

Contact Us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us via the Administrator at administrator@contrarius.com.

1. Introduction

   At Contrarius our objective is to create long-term wealth for our investors through superior long-term investment performance. We believe that long-term performance is driven by the consistent application of a sound investment philosophy. The key characteristics of our investment philosophy are that it is contrarian, valuation based, long-term and based on proprietary fundamental research.

   When investing on behalf of our fund investors, our overriding objective is to act in the best interest of the Funds. A prerequisite for a sound investment philosophy is that it is sustainable. As long-term investors, it is critical for us to understand the full range of factors that might affect a company’s business and share price performance. While there is scope for investors to have diverse views about ESG-related matters, we believe there is a broad consensus that a company that acts in a way that damages the environment or is morally or socially irresponsible will eventually undermine its own profitability. We believe that by performing rigorous, fact-based research that carefully seeks to consider risks, including relevant ESG-related risks, we are able to maximise the chances that we can successfully implement our contrarian, valuation-based and long-term investment philosophy in a sustainable manner.

   Contrarius is a signatory to the United Nations-supported Principles for Responsible Investment (‘PRI’). We have employed the PRI as a guiding framework for developing our Responsible Investing Policy.

   This Policy provides an overview of our approach to responsible investing for the Contrarius Funds and covers how we deal with issues and risks relating to environmental, social, and governance (‘ESG’) matters.

2. Integration of Responsible Investing

   Investment Process

   As part of our investment philosophy and process, we select investments following detailed proprietary research. Our research efforts are directed to uncover companies that are trading below their underlying intrinsic values. The focus is on the long-term value of a business rather than short-term sentiment and earnings outlook. As part of our bottom-up research process, we consider a range of factors that might affect a company’s intrinsic value. These factors include environmental, social and governance (‘ESG’) issues.

   Investment policy group meetings are where a fundamental investment policy group report is presented by the investment analyst for a company. The investment policy group report also addresses various risks considered relevant to the investment case (including ESG related risks). The investment policy group meeting discusses the investment merits of individual companies and then votes on the companies’ attractiveness versus the market and assigns an overall risk rating to the company.

   We have a designated ESG analyst (with the necessary back-up resources) who prepares and presents an ESG report for each company discussed at investment policy group meetings. These separate ESG reports are presented and discussed prior to voting on a share. Incorporation of ESG-related risks and opportunities in both investment policy group reports by investment analysts and separate ESG reports prepared by a designated ESG analyst provides for the identification and assessment of these factors to be considered as part of the vote by the policy group meeting and, among other considerations, are incorporated into the risk rating assigned to the company and the resulting maximum position size of that share that may be purchased by the Funds.

   ESG information is held within centralised databases or tools, and accessible by all relevant staff for ongoing analysis of investments.

   Screening and Exclusions

   Negative screens and broad ESG-related exclusions do not form part of our investment philosophy or fundamental research process. Contrarius believes that screening out investments purely on the basis of ESG-related metrics are not in the best interest of the Funds’ investors.

   Contrarius’ approach to responsible investment includes the integration of ESG considerations into the investment process, and the Contrarius Funds may invest in securities with potentially higher exposure to ESG risks where it is believed the potential return outweighs the risks identified.

   Review and Monitoring

   Our investment analysts conduct ongoing monitoring of individual securities within the investable universe. This ongoing monitoring includes the consideration of relevant ESG-related matters that may impact our assessment of a security’s fair value. A designated ESG analyst collaborates closely with investment analysts and regularly monitors securities within the investable universe utilising third-party ESG data in addition to ongoing internal ESG research, providing an additional input that assists with investment decisions.

   In addition to the monitoring of individual securities, the Funds’ portfolio exposures are monitored on an ongoing basis. This portfolio review includes an assessment of exposures to material ESG-related risks and assists in informing the overall portfolio construction process.

3. Proxy Voting

   The incorporation of responsible investing in our research effort extends to our voting at shareholder meetings. Contrarius considers the exercise of proxy voting as central to its stewardship responsibilities. Our Proxy Voting Policy details how proxy voting is directed at Contrarius and sets out the process and procedures taken in relation to resolutions put forward at annual general meetings and extraordinary general meetings. This section of the Responsible Investing Policy should be read in conjunction with the Proxy Voting Policy, available on our website.

   Our overriding objective is to act in the best interests of the Funds by voting in support of proposals that will further the longterm value of the companies that the Funds are invested in. We aim to vote on all resolutions wherever possible and practical, taking into consideration local market and operational requirements. We use our own research and make voting decisions without the use of external service providers.

   When voting at shareholder meetings, we consider all the aspects of a proposal being put to the vote, including relevant ESG issues. We are mindful to not follow a prescriptive set of rules for proxy voting as this could restrict our ability to act in the Funds’ best interests.

   All voting actions are recorded in an internal register and proxy voting details are reported publicly on a quarterly basis.

4. Engagement

   Our fundamental research process does not typically include engagement with management or other representatives of our investee companies. We generally believe that managements’ actions speak louder than words when assessing the merits of an investment and the quality of management. We are also cognisant that engagement may, on occasion, place the Funds in a position where they may be restricted in trading a share, sometimes for lengthy periods. Furthermore, given the publicly available information on companies today (including transcripts and recordings of results, conferences, presentations, investor Q&A’s and detailed filings and company reports), engaging with investee companies does not typically add particular value to the investment decision. However, as part of our approach to responsible investing, we recognise our responsibility as stewards of our investors’ capital and that engagement on ESG-related matters is, on occasion, an effective component of our investment process.

   Our engagement activities are guided by our consideration of what is in the best interests of the Funds we manage for investors and subject to applicable laws and regulations in the relevant jurisdiction. Our engagement on ESG-related matters includes complying with the engagement requirements of the EU Shareholder Rights Directive.

   Where we conduct engagement activities with our investee companies, we prioritise our efforts and resources generally on areas that we believe may provide the most positive impact on the Funds. We generally conduct our engagement activities privately, but may consider public engagement, where appropriate, among other methods of escalation. Our engagement activities with investee companies may be for various reasons, including influencing corporate practice on ESG-related issues, encouraging improved ESG disclosure or gaining a better understanding of ESG strategy.

   We track our engagements in an internal register to facilitate monitoring, review and reporting on our engagement efforts.

5. Reporting

   As a signatory to the PRI, we have made a commitment to transparency and recognise its importance in creating higher standards for responsible investment practices and for the wider financial market. We will make the PRI’s Transparency Report and the PRI Assessment Report available to investors upon request.

   We report our proxy voting activity on a quarterly basis. These reports provide a summary of our voting activity during the period in addition to individual details of how we voted on each resolution. These reports are made available on our website and on request.

   Our annual Responsible Investing and Stewardship Report constitutes the annual reporting on Contrarius’ engagement and voting activities, as required by the Shareholder Rights Directive II (Directive (EU) 2017/828). As part of this report, we disclose information and examples of our engagement activity together with a summary of our proxy voting activity and a description of the most significant votes during the period. In this report we also make available relevant climate-related disclosures for the benefit of current and prospective investors in the Contrarius Funds. This report is made available on our website and on request.

6. Related Policies and Documents

   The following documents, as well as this Policy, are available on our website (www.contrarius.com):

   • Shareholder Rights Engagement Policy;
   • Conflicts of Interest Policy;
   • Proxy Voting Policy;
   • Quarterly Summary and Detailed Proxy Voting Records; and,
   • Responsible Investing and Stewardship Report.

1. Introduction

The Shareholder Rights Directive 2017/828 (“SRD II”) amends Directive 2007/36 (SRD I) and promotes long-term shareholder engagement and enhances the transparency between EEA-listed companies and their investors. SRD II applies to, amongst other, UCITS investment companies which invest into EEA listed equities of EEA companies.

Contrarius ICAV, an Irish UCITS fund with two sub-funds (the Funds), has the ability to invest in equities listed in various EEA markets and is therefore within the scope of SRD II.

As the portfolio management of Contrarius ICAV (the “ICAV”) has been delegated to Contrarius Investment Management Limited (“CIML”) as the Investment Manager of the Funds, the ICAV and its sub-funds have relied on CIML to implement a policy outlining how CIML complies with the requirements of SRD II.

This document comprises CIML’s Shareholder Rights Directive II (SRD II) Engagement policy, which complies with the principles of the SRD II.

2. Requirements of the Shareholder Rights Directive II

2.1. Engagement policy disclosure

Under the SRD II, in-scope companies are required to disclose a shareholder engagement policy or publish a statement setting out why they have chosen not to do so.

In accordance with such companies’ disclosure obligations, the policy should provide information on how the in-scope company:

1. Monitors investee companies on relevant matters, including:
   1. Strategy;
   2. Financial and non-financial performance and risk;
   3. Capital structure; and
   4. Social and environmental impact and corporate governance.
2. Conducts dialogues with investee companies;
3. Exercises voting rights;
4. Cooperates with other shareholders and other stakeholders of the investee companies;
5. Manages the actual and potential conflicts of interests in respect of its engagement.

2.2. Annual disclosure obligations

As part of the SRD II’s disclosure requirements, in-scope companies must disclose annually the following information regarding the engagement policy’s implementation:

• General description of voting behaviour;
• How the company has cast votes in the AGMs of investee companies (unless these votes are considered insignificant due to the subject matter of the vote or the size of the holding in the company);
• Explanation of the most significant votes; and
• The use, if any, of the services of proxy advisors.

2.3. Annual disclosure on behalf of SRD institutional investors

In-scope companies must disclose the following information, where applicable, annually where they invest on behalf of SRD institutional investors:

• The key material medium to long-term risks associated with the investments;
• Portfolio composition;
• Turnover and turnover costs;
• The use, if any, of proxy advisors for the purpose of engagement activities;
• The policy on securities lending and how that policy is applied to support the company’s engagement activities, if applicable, particularly at the time of the financial performance;
• Whether and how the company makes investment decisions based on evaluation of medium to long-term performance of an investee company, including non-financial performance; and
• Whether conflicts of interests have arisen in connection with engagement activities and how the company has dealt with these conflicts.

3. How CIML meets the requirements of the Shareholder Rights Directive II

SRD II seeks to encourage investment managers to implement strategies that contribute to the medium- to long-term performance of the assets of their investors and to consider the key material medium- to long-term risks associated with the portfolio investments, including corporate governance matters and other risks. As these risks are likely to impact the returns of investors, more effective integration of those matters into investment processes may be crucial for investors. Contrarius’ approach, as set out below, is long term in nature.

3.1 Monitoring Investee Companies on relevant matters, including strategy, financial and non-financial performance and risk, capital structure and social and environmental impact and corporate governance.

Contrarius believes that long-term performance is driven by the consistent application of a sound investment philosophy. The key characteristics of our investment philosophy, as set out at https://www.contrarius.com/About/Philosophy, are summarised below:

• Long-term Approach

  We take a long-term approach to investing, with a typical investment horizon of four years. We believe that long-term outperformance is largely determined by focusing on the long-term, intrinsic value of a business. In the short-term, stock prices tend to be primarily driven by market sentiment and the immediate earnings outlook, rather than the intrinsic value of the business.

• Fundamental Research

  Fund investments are made following detailed proprietary research. Our research seeks to determine the underlying intrinsic value of the investment.

• Valuation based

  We seek to buy stocks that we believe are trading below their underlying intrinsic value and which we consider to be attractive relative to other available opportunities. The larger the discount to underlying intrinsic value, the more attractive the stock. We seek to sell stocks that we believe have reached their underlying intrinsic value or which we consider to be less attractive than other opportunities we have evaluated.

• Consistency

  We believe that the consistent application of this approach is essential in achieving our objective of creating long-term wealth for our clients.

The fundamental research that we undertake seeks to determine whether a company should be included in the universe of shares from which the portfolio is constructed. In determining the underlying intrinsic value of a security, our analysts seek to consider various factors that may impact on the long-term earnings power of the business. These typically include operational, management and industry factors. Operational considerations typically include the business model and the capital structure of the firm. Management considerations typically include the long-term strategy, historic capital allocation decisions, remuneration and incentives, as well as environmental, social and governance (ESG) issues. Industry considerations typically include the competitive dynamics of the industry and barriers to entry. This analysis takes place not only prior to making an investment, but also on an on-going basis, in order to determine whether the long-term earnings power of the business remains intact.

Since relevant ESG considerations may have a considerable bearing on the underlying intrinsic value of a business, they are evaluated as part of the fundamental, bottom-up research process. We have a designated ESG analyst (with the necessary backup resources) who prepares and presents an ESG report at policy group meetings. The investment policy group report also addresses various risks considered relevant to the investment case, including ESG related risks.

3.2 Engagement with Investee Companies

Other than as referred to below, our fundamental research process does not typically include engagement with management or other representatives of our investee companies. We generally believe that managements’ actions typically speak louder than words when assessing the merits of an investment and the quality of management. Shareholder engagement may, on occasion, also place the Fund in a position where it would not be able to trade in a share, sometimes for lengthy periods. Furthermore, given the publicly available information on companies today (including transcripts and recordings of results, conferences, presentations, investor Q&A’s and detailed filings and company reports), engaging with investee companies does not typically add particular value to the investment decision. However, as part of our approach to responsible investing, there are occasions where we engage with companies that the Funds are invested in with regards to ESG related matters. Such engagements may be for various reasons, including influencing corporate practice on ESG issues, encouraging improved ESG disclosure or gaining a better understanding of ESG strategy. Our engagement is based on a consideration of what is in the best interests of the Funds we manage for investors and subject to applicable laws and regulations in the relevant jurisdiction. Our engagement on ESG related matters includes complying with the engagement requirements of the EU Shareholder Rights Directive.

3.3 Proxy Voting Policy

CIML’s Proxy Voting Policy is set out on our website www.contrarius.com, which is available to all ICAV’s investors. Contrarius considers resolutions put by companies to investors in terms of its Proxy Voting Policy. Should CIML exercise its discretion to vote on any shares held by the Funds, it will do so in the exclusive interests of the relevant Funds. Details of the action taken in accordance with our voting rights is publicly available on our website www.contrarius.com. Records of how we voted in shareholder meetings in the previous two quarters are available on our website at www.contrarius.com.

3.4 Engagement and cooperation with other shareholders

Our fundamental research process does not typically include engagement with other shareholders of our investee companies. This is to avoid potential conflicts that such engagements may lead to. In exceptional circumstances, on a case-by-case basis, we may elect to engage with other shareholders should the need arise.

3.5 Conflicts of interest management

As set out above, we do not typically engage with investee company management or with other investee companies’ shareholders to avoid the types of conflict that such engagement may lead to. To the extent that such engagement occurs (including as may be required by the Shareholder Rights Directive with respect to EEA listed companies) we would take all reasonable steps to identify, mitigate and manage such conflicts. With respect to other potential conflicts of interest more generally, our conflicts of interest’s arrangements are outlined in the Conflicts of Interest Management policy available on the website www.contrarius.com.

3.6 Annual disclosure obligations

Records of how we voted in shareholder meetings in the previous two quarters are available on our website. Additional proxy voting reports are available to investors on request.

Reports to SRD institutional investors (defined as Occupational pension schemes which fall within the scope of IORP II, and EU life insurers) would be produced at least annually and made available to investors on request.

4. Review

This policy will be reviewed at least annually, and is available on our website www.contrarius.com.

Responsible Investing and Stewardship Report for 2024

This report provides an overview of our approach to responsible investing. The report also outlines our stewardship activities in 2024, including a summary of proxy voting and engagement during the period. This report also constitutes the annual reporting on Contrarius’ engagement and voting activities, as required by the Shareholder Rights Directive II (Directive (EU) 2017/828).

For more information on our approach to responsible investing and other matters discussed in this report, please visit our website (www.contrarius.com).

1. Summary of our Approach to Responsible Investing and Stewardship

At Contrarius, our objective is to create long-term wealth for our investors through superior long-term investment performance. We believe that long-term performance is driven by the consistent application of a sound investment philosophy. The key characteristics of our investment philosophy are that it is contrarian, valuation-based, long-term and based on proprietary fundamental research.

As long-term investors, it is critical for us to understand the full range of factors that might affect a company’s business and share price performance. While there is scope for investors to have diverse views about ESG matters, we believe there is a broad consensus that a company that acts in a way that damages the environment or is morally or socially irresponsible will eventually undermine its own profitability. We believe that by performing rigorous, fact-based research that carefully seeks to consider risks, including relevant ESG related risks, we are able to maximise the chances that we can successfully implement our contrarian, valuation-based and long-term investment philosophy in a sustainable manner.

The incorporation of responsible investing in our research effort extends to our voting at shareholder meetings. Contrarius considers the exercise of proxy voting as central to its stewardship responsibilities. Our Proxy Voting Policy details how proxy voting is directed at Contrarius and sets out the process and procedures taken in relation to resolutions put forward at annual general meetings and extraordinary general meetings.

Our fundamental research process does not typically include engagement with management or other representatives of our investee companies. We generally believe that managements’ actions speak louder than words when assessing the merits of an investment and the quality of management. We are also cognisant that engagement may, on occasion, place the Contrarius Funds in a position where they may be restricted in trading a share, sometimes for lengthy periods. Furthermore, given the publicly available information on companies today (including transcripts and recordings of results, conferences, presentations, investor Q&A’s and detailed filings and company reports), engaging with investee companies does not typically add particular value to the investment decision. However, as part of our approach to responsible investing, we recognise our responsibility as stewards of our investors’ capital and that engagement on ESG-related matters is, on occasion, an effective component of our investment process.

2. Developments in 2024 and Future Commitments

As a signatory to the United Nations-supported Principles for Responsible Investment (“PRI”), Contrarius is committed to the adoption of the six principles for responsible investing outlined by the PRI and to report on this progress. Following the PRI’s enhanced reporting changes, 2024 represented the first year as a signatory to complete a public annual assessment on our responsible investment practices through the PRI Transparency Report. We will make the PRI’s Transparency Report and the PRI Assessment Report available to investors upon request.

In November 2022, the US Securities and Exchange Commission (“SEC”) adopted rule amendments to enhance proxy voting reporting by mutual funds, ETF’s and other registered funds with the aim of making proxy voting records more usable and easier to analyse. The new rules and form amendments became effective for votes occurring on after 1 July 2023, with the first filings due in August 2024. Contrarius made its first requisite Form N-PX submission in 2024.

Our Responsible Investing and Stewardship Report now also includes climate-related disclosures.

We will continue to evolve our approach to responsible investing over time and in response to evolving best practices. We continue to source new and updated ESG data to develop a better understanding of the impact of ESG and sustainability issues and continue to enhance our internal ESG analysis and monitoring capabilities.

3. Proxy Voting

Contrarius considers the exercise of proxy voting as central to its stewardship responsibilities. Our Proxy Voting Policy details how proxy voting is directed at Contrarius and sets out the process and procedures taken in relation to resolutions put forward at annual general meetings and extraordinary general meetings.

Our overriding objective is to act in the best interests of the Funds by voting in support of proposals that will further the long-term value of the companies that the Funds are invested in. We aim to vote on all resolutions wherever possible and practical, taking into consideration local market and operational requirements. We use our own research and make voting decisions without the use of external service providers.

When voting at shareholder meetings, we consider all the aspects of a proposal being put to the vote, including relevant ESG issues. We are mindful to not follow a prescriptive set of rules for proxy voting as this could restrict our ability to act in the Funds’ best interests.

For more information about our approach to proxy voting, please refer to our Proxy Voting Policy, available on our website.

Below we provide a summary of the proxy voting activity undertaken during the calendar year 2024.

3.1 Proxy Voting Record in 2024

During calendar year 2024, we voted on 660 resolutions at 52 meetings. Of the 52 meetings at which we voted, we cast at least one dissenting vote (where we voted against management’s recommendation) at 9 (17%) of these meetings. The below table outlines how we voted for each quarter during the period for the Contrarius Global Equity Strategy.

Table 1: Proxy Voting Resolution Summary over the 12 Months ending 31 December 2024

Contrarius’ long-term, contrarian, and valuation-based investment philosophy is based on proprietary fundamental research conducted by our research analysts. Our investment process involves rigorous debate at investment policy group meetings and a significant amount of time is spent before a security can enter the universe of eligible shares from which the Contrarius Funds may invest. Since our assessment of the quality of management plays an important role in stock selection, it is no surprise that we are generally supportive of management of investee companies. However, as outlined in our Proxy Voting Policy, we apply our mind to each resolution put forward to vote at shareholder meetings, and we may vote against a resolution where we believe it is in the Contrarius Funds’ best interests.

The table below outlines how we voted by topic for the calendar year for the Contrarius Global Equity Strategy. Dissenting votes related to the topic areas of share issuance, remuneration-related matters, amendment to memorandum of incorporation, dis-application of pre-emptive rights and other.

Table 2: Proxy Voting Resolution Summary by Topic over the 12 Months ending 31 December 2024

The above summaries exclude meetings where the Strategy had fully exited the position prior to the company’s meeting date. 

The topic that garnered the most dissenting votes as a percentage of total votes cast was issues relating to share issuance. A large proportion of these votes related to resolutions put forward by management for authorisation to issue shares generally and unconditionally. In general, we oppose overly broad resolutions that empower a board to raise potentially excessive capital without shareholder consultation. We discuss our thoughts on this topic further, together with examples, in the following section of this report.

Shareholder resolutions are a formal way for shareholders to submit resolutions to companies at their annual meetings with the intent of influencing corporate action. There has been an increase in the number of shareholder resolutions appearing on meeting agendas in recent years. These resolutions can cover a broad spectrum of topics, but typically focus on specific environmental, social and governance issues. Management typically recommend voting against these resolutions, citing that they are not believed to be in the interests of shareholders. As with all resolutions, we assess the merits of each resolution individually and vote on a case-by-case basis, with the guiding principle of enhancing long-term value for investors in the Contrarius Funds.

Full detailed proxy voting records for the Contrarius Global Equity Strategy are made available for the last two quarters on our website. Detailed proxy voting records for previous periods are made available on request.

3.2 Proxy Voting Examples from 2024

When a company issues additional shares (other than in a rights issue more generally), the proportional ownership of existing shareholders is collectively reduced. As long-term, contrarian, valuation-based investors we seek to invest in companies that are trading below our assessment of the company’s underlying intrinsic value. Issues of shares by these companies at current prices would therefore typically reduce the value per share. In general, we therefore tend to be opposed to shareholder resolutions that seek to grant management the authority to issue new shares. Examples of where we voted against resolutions to authorise the issuance of shares include Entain, Just Eat Takeaway.com, CRISPR Therapeutics and Prosus.

In some instances, we have made exceptions to this rule. This is because we apply our minds to each resolution and vote on a case-by-case basis.

At Hewlett Packard, we voted in favour of a resolution that would result in a relatively small issue of shares. The Hewlett Packard Enterprise Company 2021 Stock Incentive Plan (“2021 Plan”) received shareholder approval and was adopted in April 2021. It is the only plan under which equity-based compensation may currently be awarded to Hewlett Packard employees and non-employee directors. The 2021 Plan superseded the 2015 Stock Incentive Plan, with no future awards available for issuance under the 2015 plan. This amendment to the 2021 Plan increases the number of shares of common stock for issuance. We believe that it is necessary to enable the continued use of equity compensation awards to incentivise key talent and promote better alignment between management and shareholder interests. Hewlett Packard’s expansion into higher-growth, higher-margin areas such as Intelligent Edge, Hybrid Cloud and AI requires successful attraction and retention of high-demand talent in a very competitive business environment. We believe that in this case, the benefits more than offset the disadvantages. The share issuance was specific to the 2021 Plan and was not for general purposes.

In January 2024, a Delaware judge rescinded a 2018 compensation package that 73% of Tesla shareholders (excluding Elon Musk and his brother Kimbal Musk, who are on the Tesla board of directors) approved at the time. In June 2024, the 2018 compensation package was again put to shareholders. We voted in favour of the pay package. 84% of Tesla’s shareholders (excluding the shares held by Elon and Kimbal) agreed with us, by also supporting this resolution. Given the publicity and polarising opinions that Elon’s compensation elicited, we believe it is worth elaborating on our rationale for voting in support of his pay package.

Elon Musk’s 2018 pay package required him to deliver transformative and unprecedented growth to earn any compensation whatsoever. Elon was given extremely challenging performance targets, that when reached would result in a pay-out of stock options to be delivered in tranches for each set of targets achieved. The targets were tied to market capitalisation, revenue and earnings. Importantly, Musk would receive no other compensation of any kind – no salary, no cash bonuses and no equity. Elon’s only compensation was the 100% at-risk performance award. It was a big risk to Elon Musk at the time. Many felt that the targets were unachievable. For example, for Elon to fully vest in the market cap milestone award, Tesla’s market cap would have to increase from around USD50bn at the time to USD650bn.

We believe that Musk’s incentive was very closely aligned with the company’s performance and shareholder outcomes. We also believe that Elon’s leadership is instrumental in Tesla’s continued success in new areas. Elon’s compensation package is all stock-based, and ensures his continued dedication to Tesla. Elon is required to hold on to any shares he receives upon exercising his options for at least an additional 5 years. Elon Musk has not been paid for all his work and the tremendous shareholder value he created over the past 6 years.

There is also the broader issue of shareholder rights and corporate democracy, which we believe to be sacrosanct. No court should be second-guessing or overturning the requests and votes of a considerable majority of shareholders. We believe shareholders deliberately approved the pay package in 2018, and supported it even more overwhelmingly in 2024. We believe shareholder voices should be heard and respected.

Another proposal tabled at Tesla’s 2024 annual meeting was to approve the re-domestication of Tesla from Delaware to Texas. It is believed that Texas has more favourable legal and regulatory conditions and more business-friendly policies. This is particularly advantageous to entrepreneurial companies like Tesla, where attracting and retaining key talent is important in driving continued innovation. Tesla already has its Gigafactory—one of the largest factories in the US—in Texas, along with over 20,000 staff and engineers. Furthermore, Tesla’s physical headquarters are in Austin, and the executives are based there. Since Tesla would benefit from a more favourable business environment, we voted in support of the resolution to redomicile from Delaware to Texas.

3.3 Significant Votes in 2024

Under Article 3g(1)(b) of Directive (EU) 2017/828, the most “significant” votes are determined on the basis of quantitative and/or qualitative criteria as set by Contrarius. We have determined the most “significant“ votes to be those relating to companies in which the Contrarius Funds combined voting rights exceed 10% of total voting rights, and where Contrarius voted against management’s recommendation or against a shareholder resolution.

There were no significant votes for the Funds in 2024.

4. Engagement

As part of our approach to responsible investing, we recognise our responsibility as stewards of our investors’ capital and that engagement on ESG-related matters is, on occasion, an effective component of our investment process.

Our engagement activities are guided by our consideration of what is in the best interests of the Funds we manage for investors and subject to applicable laws and regulations.

Where we conduct engagement activities with our investee companies, we prioritise our efforts and resources generally on areas that we believe may provide the most positive impact on the Funds. We generally conduct our engagement activities privately, but may consider pubic engagement, where appropriate, among other methods of escalation. Our engagement activities with investee companies may be for various reasons, including influencing corporate practice on ESG-related issues, encouraging improved ESG disclosure or gaining a better understanding of ESG strategy.

For more information about our approach to engagement, please refer to our Responsible Investing Policy, available on our website.

4.1 Engagement Activity in 2024

Our engagements throughout 2024 have generally been of a constructive nature, relating to proxy voting clarifications, requests and/or confirmations of receipts of certain information or expressions of approval. Our approach to engagement means that we would expect the level of engagement to vary from year to year and to be dependent on our consideration of what is in the best interests of the Funds we manage.

One example of a more notable engagement activity relating to a matter concerning corporate governance is our engagement with the Paramount Global Board of Directors (“Board”). Earlier in 2024, there were reports that Paramount Global was to merge with Skydance Media, controlled by Oracle founder Larry Ellison’s son David Ellison. We strongly opposed any transaction that involved the issue of Paramount Global shares at what we believed to be an extremely depressed market price, either for the purpose of acquiring Skydance Media or for cash, and formally communicated our opposition to the Paramount Board of Directors.

Complicating this transaction are Paramount’s two classes of shares: Class A shares, that carry voting rights, and Class B shares that are non-voting. The Class A shares are controlled by Shari Redstone, Chair of Paramount Global and Chair, President and CEO of National Amusements.

We communicated to the Board that we believed the contemplated transaction, as reported, to be highly prejudicial to Paramount Global Class B shareholders and would amount to a breach of the directors’ fiduciary duties. We reminded the board that they should seek to maximise long-term value for all shareholders. We also informed the Board that we reserved our rights should they proceed as reported.

Paramount ultimately announced the terms of a transaction in July 2024 that we believe adequately addressed our concerns. Paramount remains one of the largest holdings in the Funds.

5. Examples of ESG issues that influenced our investment decisions in 2024

As outlined in section 1 of this report, we believe that as long-term investors, it is critical for us to understand the full range of factors that might affect a company’s business and share price performance. We believe that by performing rigorous, fact-based research that carefully seeks to consider risks, including relevant ESG related risks, we are able to maximise the chances that we can successfully implement our contrarian, valuation-based and long-term investment philosophy in a sustainable manner. Our approach to responsible investing, however, extends beyond initial bottom-up fundamental research and is integrated throughout the investment process. Below we discuss several examples of ESG issues that influenced our investment decisions in 2024.

One of the Funds’ largest holdings in 2024 is a leading communication platform that enables remote communication and facilitates video meetings, phone calls and whiteboards that enable individuals and organisations to connect. The company’s products and services facilitate hybrid work, thereby reducing commutes and other business travel and positively impacting the environment through reduced transport-related carbon emissions. The company is committed to achieving 100% renewable electricity in its direct operations by 2030. By the end of FY2024, the company had 28 active data centres globally with its colocation partners. Approximately half of its colocation data centres are leased from Equinix. As at end-2023, over 96% of Equinix’s operational load was covered by renewable energy.

This communications company has a dual share class structure: Class A shares—which the Funds hold—are entitled to one vote per share, and Class B shares are entitled to ten votes per share. As at the end of the most recent financial year-end, Class B shareholders held 64% of the voting power of the outstanding capital stock. Class B shareholders could therefore exert significant influence over the company, potentially to the detriment of Class A shareholders. A material portion of the Class B shares are held by the company’s founder, who also serves as President and CEO. We are comforted by his track record. In our assessment, we have found him to be extremely innovative and focused on the best long-term interests of all shareholders. The company has a long-term plan to convert the Class B shares into Class A shares.

In 2024, the Fund had an investment in a digital sports entertainment and gaming company that provides users with online sports betting, online casino and daily fantasy sports product offerings, as well as a retail sportsbook, media and other consumer offerings. To many observers, the casino and gaming industry would not typically be synonymous with ESG. However, we believe that the company has gone to great lengths to provide a safe gaming environment through regulatory compliance, ethical decision-making and responsible gaming initiatives that are designed with consumer protection in mind. Responsible gaming is a core priority at the company. In the first half of 2024, the company appointed a Chief Responsible Gaming Officer who reports directly to the CEO. The company continues to introduce new tools and partnerships to enhance its responsible gaming efforts. The company has tools that allows players to set budgets, manage their time and, if necessary, set cool-off periods and provide a means to self-exclude (i.e., a complete break from gaming). The company expanded and updated its Responsible Gaming Centre—a centralised location that hosts all the player safety tools and resources. Players can track and review their personal activity in real time. Advertising is performed in a safe and responsible way. The company’s commitment to responsible gaming extends to partnerships with industry, regulatory and public health bodies. All employees complete responsible gaming training when they join and annually thereafter. Customer-facing employees receive live, targeted training on responsible gaming, and refresher course every 6 months. The company contributes meaningfully to the various jurisdictions in which it operates through substantial state-imposed taxes on online sports betting and iGaming revenue, in addition to a federal excise tax of 25 basis points on the amount of each online sports betting wager and normal corporate income taxes.

This company also has a dual share structure, with the high voting shares all held by the founder, who is also the CEO and Chairman. Accordingly, voting power is concentrated with this person. That the founder/CEO/Chairman managed to build a market-leader in a brutally competitive environment against larger competitors who arguably had a competitive advantage in the early days of the industry is testament to his long-term vision, execution ability and determination. He remains extremely engaged and motivated about the industry which is still in its early days of growth and we are pleased to have been co-invested.

In 2024, the Fund was invested in a biotechnology company focused on a revolutionary technology that enables the precise alteration of specific sequences of genomic DNA. This technology has the potential to disrupt, delete, correct and insert genes to treat rare and common diseases that traditional biopharmaceutical approaches had little success with. The technology was co-invented by the scientific founder of the company, who shared a Nobel Prize in Chemistry for her ground-breaking work.

The emergence of gene-editing technologies sparked public debate around bioethics, especially on the potential application of genome editing to human embryos or for reproductive purposes. Some are understandably concerned that any gene editing could start us on a slippery slope to using it for non-therapeutic purposes, especially when the technology might only be accessible to the well-heeled. We think these are very important debates, and it is critical to continue the dialogue given the rapid progress in this field of medicine. It is worth pointing out that this company does not use its technologies to edit human embryos or the human germline. The Alliance for Regenerative Medicine in Washington, D.C. has called for a voluntary moratorium on the use of gene editing technologies in research that involves human embryos or human germline cells. There are laws in the UK and other European countries that prohibit the same.

There are thousands of diseases caused by aberrant DNA sequences. We believe that newer technologies and approaches, such as those pioneered by this company, have the potential to provide curative therapies to broad groups of patients in instances where no forms of medicine are available, or no other forms of treatment have worked. These technologies could also make other forms of treatment (such as cell therapy) more efficacious, safer and available to a broader group of patients. Furthermore, we believe that these technologies will be significantly enhanced by AI-driven tools that should increase the safety and efficacy of future interventions. We therefore believe that these technologies—whilst still in their early days—have the potential to transform many areas of medicine and potentially usher in a new era of healthcare.

Potential use cases extend beyond healthcare. These technologies could be used to make agriculture more resistant to disease and to climate change, thereby increasing agricultural productivity and mitigating food insecurity and hunger.

6. Climate-related Disclosures

In recognition of a growing need from investors in the Funds to measure and report on the climate-related exposure of the Contrarius Funds, we provide portfolio-level emissions metrics for the Contrarius Global Equity Strategy. It is important to note that these metrics are provided for disclosure purposes and represent portfolio exposures that are a result of our contrarian, fundamental and valuation-based investment process.

Understanding the carbon footprint of a portfolio helps investors identify potential risks, ranging from climate-policy related cost increases to revenue impacts due to changes in consumer demand. Greenhouse gas emissions (“GHG”) include carbon dioxide and methane, both of which may be released through natural processes and human activities, such as the production and burning of fossil fuels, deforestation, and landfill waste dumps. Measuring GHG emissions may facilitate the management and reduction of those emissions by identifying holdings that may have above-average climate risk. GHG emissions are typically separated into three scopes:

• Scope 1 – covers all direct emissions from owned or controlled sources, such as those released during mining or during the manufacturing process;
• Scope 2 – covers all indirect emissions from owned or controlled sources. This may include the purchase and use of electricity, fuel or other energy sources consumed during the operations;
• Scope 3 – all indirect emissions that may occur before (upstream) or after (downstream) the activities of an organisation, such as from employees commuting or the end use of the organisation’s sold products.

Absolute measures of carbon intensity, measured in total tonnes, take no consideration of the overall size of the respective businesses. We believe that measuring GHG emissions on a standardised basis, using a measure like the Weighted Average Carbon Intensity (“WACI”), enables better comparison across different companies. WACI is a measure of carbon emissions normalised by revenues, which is a relevant comparison point across all companies and allows for analyses across industries and sectors.

6.1 Portfolio Carbon Emissions

In preparing the Fund’s portfolio-level emissions metrics, we used data provided by Morningstar. We report the WACI of Contrarius Global Equity Fund, the WACI percentage of the Fund’s portfolio covered, and the WACI of the Morningstar category average as at 31 December 2024.

Table 3: Carbon Emissions of Contrarius Global Equity Strategy Investments

Source: Morningstar
¹ WACI (Scope 1+2) is the asset-weighted average for the portfolio of the underlying holdings’ carbon intensity Scope 1 and 2. The average only includes holdings for which company carbon intensity Scope 1 and 2 is available. Carbon intensity for a company represents the volume of carbon emissions per million USD in revenue, computed as follow: Total Emissions Scope 1 and 2 (metric tons of CO2)/ Revenue (USD millions). A lower value indicates lower intensity, and greater carbon efficiency.
² The percentage of the eligible portfolio with the relevant underlying data for the calculation of the weighted average carbon intensity statistics.
³ WACI (Scope 1+2) Category Average is the average WACI (Scope 1+2) for portfolios within the Morningstar category ‘EAA Global Large-Cap Blend Equity’, expressed in tonnes CO2e per millions USD.

It is important to be mindful of the limitations of compiling portfolio-level carbon emission statistics. Carbon emissions data is backward-looking. Portfolio-level emissions statistics are also not necessarily comparable from period to period as a result of changes in portfolio holdings and availability of holdings-level carbon emissions data. Normalising the emissions data by whichever variable creates its own challenges and limitations. Revenue, for example, can be affected by short-term price fluctuations, currencies and the competitiveness of different markets.

6.2 Contributors to Weighted Average Carbon Intensity (“WACI”)

The five largest contributors to the Strategy’s WACI as of 31 December 2024 were Meta Platforms, Amazon.com, Alphabet, Caesars Entertainment, and Alibaba. These five largest contributors to WACI accounted for 50.1% of the Strategy’s WACI, and represented 18.5% of the Strategy’s NAV.

Table 4: Largest Contributors to Contrarius Global Equity Strategy WACI

Source: Morningstar, Contrarius Research.
¹ Carbon Intensity for each holding in the Fund is provided by Morningstar. It is calculated as the Total Emissions divided by the revenue in USD million.
² % Contribution to Portfolio WACI is calculated using the Carbon Intensity data provided by Morningstar, and the allocation of each company in the Fund, in terms of NAV.
N/B - Please note that the contribution to portfolio WACI is our own estimate using the data available, and it may not represent a complete picture of the Fund’s Carbon Intensity in instances where there is no Carbon Intensity data available. As of 31 December 2024, individual Carbon Intensity data was available for 98.1% of the Fund’s holdings.

7. Principles for Responsible Investment

Contrarius has been a signatory to the United Nations-supported Principles for Responsible Investment (“PRI”) since 2021. The PRI initiative encourages asset managers and other institutional investors to engage with corporations on environmental, social and governance (“ESG”) issues to create a more sustainable global financial system and support long-term investment value. The PRI sponsors six voluntary and aspirational Principles that offer guidance to firms regarding how to incorporate ESG risks into investment practices and portfolio ownership (corporate engagement/proxy voting) practices.

As a signatory to PRI, we formalized our existing investment approach to better outline the ways in which our investment philosophy and investment process integrates ESG issues and considerations. In 2024 we completed the first annual report on our responsible investing practices through the PRI Transparency Report.

Contrarius’ full PRI Public Transparency Report is available from PRI at www.unpri.org. We will make the PRI’s Transparency Report and the PRI Assessment Report available to investors upon request.

For more information about our approach to responsible investment, including our voting and engagement actions, please visit our website at www.contrarius.com/policies.

You can learn more information about the Principles for Responsible Investment at www.unpri.org.