Shareholder Rights Directive Disclosure

Article 3(g) of Directive 2007/36/EC as amended by Directive (EU) 2017/828 (together with the relevant national implementing regulations, the “SRD”) requires asset managers to adopt on a “comply or explain” basis an engagement policy describing how an asset manager integrates its investment strategy relating to shareholder engagement in companies that have a registered office in the EU and are listed on EU regulated markets (“EU investee companies”).

MacKay Shields Europe Investment Management Limited (“MacKay Europe”) is an asset manager for the purposes of the SRD. MacKay Europe does not actively invest as part of its investment strategy in the shares of EU investee companies. Any shares in EU investee companies would only be held as an investment ancillary to, or as a result of, a credit investment. On this basis, MacKay Europe has determined that it is not appropriate to adopt an engagement policy for the purposes of the SRD.