Shareholder Rights Directive Disclosure Statement

COBS Rule 2.2B of the FCA Handbook imposes the requirements of the Shareholder Rights Directive (“SRD”) on a full-scope UK AIFM to the extent the firm invests on behalf of investors in shares traded on a regulated market.

Gravis manages two infrastructure debt funds and a student accommodation REIT. GCP Infrastructure Investments Ltd is focused on investment in UK infrastructure debt secured against projects generating long-dated, predictable, public sector cash flows. GCP Asset Backed Income Fund Ltd is focused on investment predominantly in debt secured against physical assets and/or contracted cash flows which are predominantly UK based. GCP Student Living plc invests directly in real estate.

The investment strategies of the funds managed by Gravis do not currently involve investing in shares traded on a regulated market and Gravis will not therefore be publishing an engagement policy as defined in the SRD.

Should the investment strategies change, Gravis will review its obligations under the SRD and amend this disclosure as necessary.

June 2019