UK Stewardship Code Disclosure Statement

Under COBS Rule 2.2.3R of the FCA Handbook, Gravis Capital Management Ltd ("Gravis" or "we”) is required to disclose the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”), or alternatively to explain its reasons for not complying with the Code.

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 in UK project finance debt secured against physical assets and/or contracted cash flows. GCP Student Living plc invests directly in real estate.

While Gravis supports the principles of the Code, it does not consider it appropriate to conform to the Code at this time.

Should the investment strategies change, Gravis will review its commitment to the Code and amend this disclosure as necessary.