Law Debenture's Investment Strategy Guidelines

The Board sets the investment strategy and actively monitors both the Investment Managers’ and Executive Leadership team’s adherence through a series of guidelines and parameters in each scheduled Board meeting. The strategy is reviewed periodically to ensure we deliver on our objective.

Investments	Permitted types of investments are:	Restrictions:
	Equity Shares	Trading is not permitted in suspended shares or short positions
	Cash/Liquid Assets	No more than 15% of gross assets will be invested in other UK listed investment trusts
		No more than 175 stocks
		No investment may be made which raises the aggregate value of the largest 10 holdings, excluding holdings in collective investment vehicles that give exposure to Japan, Asia/Pacific or emerging market regions, to more than 40% of the Portfolio, including gilts and cash
		The value of a new acquisition in any one holding may not exceed 5% of the total Portfolio value (including cash) at the time the investment is made
		Further additions shall not cause a single holding to exceed 5%, and Executive approval must be sought (to be reported at the next Board meeting), to retain a holding should its value increase above the 5% limit
		No investment in any investment vehicle managed or advised by Janus Henderson shall be made without prior Board approval
		No investment other than in equity shares quoted on a major international Stock Exchange (including AIM for the avoidance of doubt) or instruments convertible into the same may be made without prior Executive approval
		The Company may not make investments in unlimited liability companies

The current regional parameters are:
	Minimum	Maximum
	%	%
United Kingdom	55	100
North America	0	20
Continental Europe	0	20
Japan	0	10
Asia/Pacific	0	10
Other (including South America)	0	10

Derivatives	May be used with prior authorisation of the Board
Hedging	Currency hedges may be put in place with Board approval to protect against foreign exchange movements on the capital and income accounts
Stock-lending	Up to 30% of the market value of the Portfolio may be lent
Gearing	A ceiling on net gearing of 50% is applied. Typically net gearing, (i.e. gearing net of cash), is between 10% and 20% of the total Trust value. The Board retains the ability to reduce equity exposure so that net cash is above 10% if deemed appropriate
Daily dealing limit	Net purchases in any dealing day are to be limited to £30 million unless prior Executive approval is obtained
Underwriting	Permitted capital at risk up to 5% of the value of the Portfolio
Corporate approval	Where indicated, the Investment Manager must obtain prior approval to exceed permitted limits either through Board or Executive approval. Executive approval shall be the approval of either the Board Chair or the Chief Executive Officer. The Board may make non-material adjustments or changes to the investment policy from time to time. Any changes to the investment policy, which the Board deem to be material, require prior shareholder approval