RUFFER LLP

Ruffer LLP Form ADV Part 2A Brochure 80 VICTORIA ST LONDON SW1E 5JL +44 (0)20 7963 8100 RUFFER.CO.UK JUNE 2025  Form ADV Part 2A Brochure ITEM 1: COVER PAGE ITEM 2: SUMMARY OF MATERIAL CHANGES In this Item of our Form ADV Part 2, we are required to discuss any material changes that have been made to Form ADV since the last Annual Amendment in June 2024. MATERIAL CHANGES SINCE THE LAST UPDATE This Firm Brochure (‘Form ADV Part 2’) provides information regarding the qualifications and business practices of Ruffer LLP (the ‘Firm’, ‘we’, ‘us’, ‘our’). If you have any questions about the contents of this Brochure, please contact Lucy Hodgson, Chief Compliance Officer, at +44 (0)20 7824 0520 or lhodgson@ruffer.co.uk In October 2024, an ‘other-than-annual’ amendment was filed to confirm that Lucy Hodgson took on the role of Chief Compliance Officer. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. ANNUAL UPDATE Additional information about our Firm is also available at adviserinfo.sec.gov/firm/summary/309733 You will receive a summary of any material changes to our Form ADV brochure within 120 days of our fiscal year end. We may also provide updated disclosure information about material changes on a more frequent basis. Any summaries of changes will include the date of the last Form ADV Annual Update. We are a registered investment adviser. Please note that use of the term ‘registered investment adviser’ and a description of the Firm and/or our employees as ‘registered’ does not imply a certain level of skill or training. FULL BROCHURE AVAILABLE Our Form ADV may be requested at any time, without charge by contacting Lucy Hodgson, Chief Compliance Officer, at +44 (0)20 7824 0520 or lhodgson@ruffer.co.uk. Additional information about the Firm is also available via the SEC’s website at adviserinfo.sec.gov/firm/summary/309733. The SEC’s website also provides information about any employees affiliated with the Firm who are registered as investment adviser representatives. 1  ITEM 3: TABLE OF CONTENTS Form ADV Part 2A Brochure 1 Item 1: Cover page 1 Item 2: Summary of material changes 1 Item 3: Table of contents 2 Item 4: Advisory business 3 Item 5: Fees and compensation 4 Item 6: Performance-based fees and side-by-side management 4 Item 7: Types of clients 5 Item 8: Methods of analysis, investment strategies and risk of loss 5 Item 9: Disciplinary information 7 Item 10: Other financial industry activities and affiliations 7 Item 11: Code of ethics, participation or interest in client transactions and personal trading 7 Item 12: Brokerage practices 9 Item 13: Review of accounts 10 Item 14: Client referrals and other compensation 10 Item 15: Custody 10 Item 16: Investment discretion 11 Item 17: Voting client securities 11 Item 18: Financial information 11 2  ITEM 4: ADVISORY BUSINESS macro-driven, absolute return strategy. We have two simple investment objectives FIRM INFORMATION 1 not to lose money in any rolling 12 month period 2 to grow funds at a higher rate than would be achieved by depositing them in cash We are a Registered Investment Adviser with the US Securities and Exchange Commission (SEC) and regulated by the UK’s Financial Conduct Authority. The portfolios we create for our clients have no constraints on their asset allocation. This means they will typically consist of some or all of the following assets: equities, bonds, Ruffer-managed funds, third party managed funds, commodities exposure, foreign currencies and derivatives. The portfolio’s multi-asset allocation will be built to reflect our stated investment objective to preserve capital as well as any investment constraints imposed by the client. Ruffer is an independent Investment Manager, founded in 1994 by Jonathan Ruffer (Chairman), to provide a different approach to discretionary fund management. We are owned and operated by the existing and former partners of the Firm. Members of the partnership contribute capital to and share in the profitability of the Firm. We believe this arrangement aligns the interests of the partnership with those of our clients, in seeking to achieve long term, sustainable investment returns and client relationships. TAILORED RELATIONSHIPS TYPES OF ADVISORY SERVICES Whilst keeping to the dual investment aims described above, we are able to tailor investment advisory services to the individual needs of the client. Our clients may impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be agreed in writing. WRAP FEE PROGRAMS We do not sponsor, manage or participate in a wrap-fee program. FIDUCIARY STATEMENT The firm provides discretionary investment management services. Advice is limited to investments in the Ruffer strategy. In the US, the Firm is marketed to non-retail investors. The Firm also manages a number of investment vehicles, including: a London listed, Guernsey registered investment company, a number of UK and Luxembourg domiciled UCITS collective investment schemes and a Cayman Limited Company master feeder fund (with Cayman Limited Company and Delaware Limited Partnership feeder funds). Some of these funds are offered in the US through private placements. Our compensation is solely from fees paid directly by clients. We do not receive commissions based on our clients’ purchase(s) of any financial product, including insurance. No commissions in any form are accepted. INVESTMENT MANAGEMENT SERVICES Both we and our employees are fiduciaries who must take into consideration the best interests of the Firm’s clients. We will act with competence, dignity, integrity, and in an ethical manner, when dealing with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. We will manage investment accounts on a discretionary basis only. This service typically includes the selection, monitoring and review of portfolio assets, and follows a single investment philosophy and process. As a fiduciary, we have the obligation to deal fairly with our clients. We have the following responsibilities when working with a client to– – render impartial advice – make appropriate recommendations based on the client’s needs, financial circumstances and investment objectives – exercise a high degree of care and diligence to Prior to investment, we will gather information about a client’s financial situation, including investment objectives, risk capacity and constraints, to ensure that our approach is appropriate. The client will enter into an Investment Management Agreement (IMA) with us prior to the management of the portfolio beginning. The IMA sets out the terms of the engagement. ensure that information is presented in an accurate manner and not in a way to mislead We manage all client portfolios in line with our single investment approach, which is described as a global, 3  CALCULATION AND PAYMENT – have reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations – disclose any material conflict of interest which can’t be mitigated/managed in writing and The specific manner in which we charge fees is established in a client’s written agreement with us. The amount due in fees is debited directly from our client’s accounts unless they have elected to be invoiced directly for fees. – treat clients fairly and equitably. ASSETS UNDER MANAGEMENT Accounts initiated during a calendar quarter will be charged a prorated fee. Upon termination of any account, the fee for the final, partial calendar quarter will be prorated. Any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. As of 31 March 2025, our assets under management are $24,201,709,009. This number represents all the assets the Firm manages for its discretionary clients. The Firm does not manage any assets on a non- discretionary basis. AGREEMENT TERMS ITEM 5: FEES AND COMPENSATION We base our fees on a percentage of assets under management. Our fee schedules are described below. The client may terminate an agreement at any time by notifying us in writing. We may terminate an agreement by giving the client at least four weeks’ notice. COMPENSATION – INVESTMENT GENERAL INFORMATION ON COMPENSATION MANAGEMENT SERVICES AND OTHER FEES Our annual investment management fees are calculated upon the level of chargeable assets under management in accordance with the following schedule. Segregated portfolios tiered fee scale* (% of funds under management) % Minimum $100,000,000 $100,000,000-250,000,000 0.90 $250,000,000-500,000,000 0.80 In certain circumstances, fees, account minimums and payment terms are negotiable depending on a client’s unique situation – such as the size of the aggregate related party portfolio size. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation. Above $500,000,000 0.70 This table of charges is supplied to the client along with the IMA. Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall not receive any portion of these commissions, fees, and costs. The asset-based fee is billed on a quarterly basis, in arrears, based upon the market value of the client’s account, on the last day of the previous quarter. Clients should note that similar management services may (or may not) be available from other registered investment advisers for similar or lower fees. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT It should be noted that in order to ensure there is no double charging to clients, holdings in any Ruffer funds are excluded from the calculation of the investment management fees where Ruffer receives a management fee directly from the fund. The annual investment management charge for the Ruffer funds ranges from 0.7% to 1.5% depending on the individual fund and the class of units held. ‘Performance-Based Fees’ are fees based on the capital gains or capital appreciation in an account. We do not charge performance-based fees. There are normally no initial or termination charges for new or leaving clients. Fee arrangements vary by client as described in Item 5. As a result, conflicts of interest could arise with respect to the allocation of more profitable trades to 4  good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. higher fee-paying accounts. To mitigate such potential conflicts of interest, the Firm’s policies and procedures state that investment decisions are to be made in accordance with our fiduciary duties and regulatory principles. In determining the suitability of investment opportunities for client accounts and funds, we consider several factors, including their investment objectives, constraints, existing portfolio composition, and legal or process constraints surrounding the investment. See Item 11 for additional information on conflicts management. Technical analysis, which analyzes past market movements and applies that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. ITEM 7: TYPES OF CLIENTS TYPES OF CLIENTS Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. In the US, discretionary investment management services are marketed to non-retail investors, including: banks or thrift institutions, pooled investment vehicles, pension and profit-sharing plans, trusts, estates and charitable organizations, family offices, corporations and other investment managers. The terms ‘charting’ and ‘technical’ analysis are generally used synonymously and therefore, for the purpose of this document, we will use the term, ‘technical analysis.’ ACCOUNT MINIMUMS Cyclical analysis, which measures the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. For our separately managed accounts we require a minimum size of $100,000,000. We may group certain related client accounts for the purposes of achieving the minimum account size. INVESTMENT STRATEGIES We have one global, macro-driven, absolute return strategy that is unchanged since our Firm began in 1994. We define this single investment strategy with two simple investment objectives 1 not to lose money in any 12 month rolling period In exceptional circumstances, we have the discretion to waive the account minimum. Accounts of less than $100,000,000 may be set up when we anticipate the client will add additional funds to the accounts bringing the total to $100,000,000 within a reasonable time. 2 to grow funds at a higher rate than would be achieved by depositing them in cash The account minimums for funds are provided in the respective fund offering documents. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS Our approach starts with managing the risk of losing money. We aim to identify the future risks we see in markets, considering a range of possible scenarios, and choose assets which will benefit should those events come to pass. These are the assets which should provide genuine protection to the portfolio in the event of market downturns. We may employ the following security analysis methods: fundamental analysis, technical analysis, and cyclical analysis. Fundamental analysis, which attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a By focusing, first and foremost, on the protection of capital, we are then able to be opportunistic in allocating to growth assets throughout the market cycle. This is typically through our exposure to global equity markets. By building a balanced portfolio in this way, our aim is to deliver consistent positive returns through the market cycle and with less volatility than would be expected from equities. 5  currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment risk: this is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (ie, interest rate). This primarily relates to fixed income securities. Our asset allocation is the key driver of returns. It is dynamic and completely unconstrained, meaning there is no strategic asset allocation and there are no control ranges. This allows us to look across a broad asset universe to identify the assets that can best protect our portfolio against the risks we see. Equally, we are free to avoid assets that we believe look overvalued or carry too much risk. We invest across asset classes and geographies in order to form a portfolio we feel to be suitably diversified. Business risk: these risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. This asset allocation is complemented by our own in-house equity research. Our analysts undertake extensive research, including meeting with the management of a company, to identify the best ideas to fit into the top-down asset allocation. These allocations may be geographic, thematic or special situations. We use long-term trading and short-term trading. RISK OF LOSS Investing in securities involves risk of loss that clients should be prepared to bear. Liquidity risk: liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, treasury bills are highly liquid, while real estate properties (ie non-traded REITs and other alternative investments) are not. Financial risk: excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with your investment objectives and risk tolerance, there can be no guarantee that our efforts will be successful. You should be prepared to bear the following risks of loss Interest-rate risk: fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Cybersecurity risk: a breach in cyber security refers to both intentional and unintentional events that may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause an account to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. Pandemic risk: large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Market risk: the price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Inflation risk: when any type of inflation is present, a dollar next year will not buy as much as a dollar today, because purchasing power is eroding at the rate of inflation. Custodial risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfil its contractual obligations either due to technological errors, control failures, malfeasance, or potential regulatory liabilities. Currency risk: overseas investments are subject to fluctuations in the value of the dollar against the Alternative investments (limited partnerships): the performance of alternative investments (for example limited partnerships) can be volatile and may have 6  AFFILIATIONS – POOLED INVESTMENT VEHICLES (‘RUFFER FUNDS’) limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Clients should only have a portion of their assets in these investments. ITEM 9: DISCIPLINARY INFORMATION Ruffer LLP and its subsidiaries manage a number of pooled investment vehicles; including a London listed, Guernsey registered investment company, a number of UK and Luxembourg domiciled UCITS collective investment schemes and a Cayman Limited Company master feeder fund (with Cayman Limited Company and Delaware Limited Partnership feeder funds). AFFILIATIONS – OTHER We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary events that would be material to your evaluation of the Firm or the integrity of our management. We have no material legal, regulatory or disciplinary events to disclose in this Item. Apart from affliations noted above, we do not have a material relationship or arrangement with related persons or financial industry entities in the following categories– – municipal securities dealer, or government ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS securities dealer or broker FINANCIAL INDUSTRY ACTIVITIES – futures commission merchant, commodity pool operator, or commodity trading adviser – banking or thrift institution Our business activities are associated with providing discretionary investment management and investment advisory services to our clients. – accountant or accounting firm – lawyer or law firm FINANCIAL INDUSTRY ACTIVITIES – – insurance company or agency BROKER-DEALERS – pension consultant – real estate broker or dealer – sponsor or syndicator of limited partnerships. RECOMMENDING OTHER INVESTMENT ADVISERS We are not registered as a broker-dealer, and none of our management persons are registered representatives of a broker-dealer. However, we have a subsidiary, Ruffer LLC, which is a FINRA broker- dealer. Ruffer LLC markets Ruffer funds to US non- retail investors. We do not recommend or select other investment advisers for our clients. FINANCIAL INDUSTRY ACTIVITIES – FUTURES AND COMMODITIES ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We are registered as a commodity pool operator, however the Ruffer funds currently rely on pool exemptions. CODE OF ETHICS AFFILIATIONS – OTHER INVESTMENT ADVISERS Our employees must comply with a Code of Ethics and Statement for Insider Trading (the ‘Code’). The Code describes our high standard of business conduct, and fiduciary duty to our clients. The Code’s key provisions include 1 Statement of general principles 2 Policy on and reporting of personal securities transactions Ruffer LLP has three related investment advisers: Ruffer S.A., Ruffer AIFM Limited and Ruffer (Channel Islands) Limited. These are wholly owned subsidiaries of the Firm and are organized to provide investment advisory services in other jurisdictions or manage Ruffer funds. Please note that none of the Firm’s subsidiaries may take on US-based clients, as they are not registered with the SEC. Ruffer AIFM Limited is notified to the SEC as an Exempt Reporting Adviser. 3 A prohibition on insider trading 4 Restrictions on the acceptance and giving of significant gifts 7  5 Procedures to detect and deter misconduct and violations 6 Requirement to maintain confidentiality of client information employees may not purchase or sell based upon having (or possibly having) access to inside information. Employee trading is continually monitored under the Policy and designed to reasonably prevent conflicts of interest between the Firm’s employees and our clients. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PRINCIPAL/AGENCY Our employees must acknowledge the terms of the Code at least annually, and any employee not in compliance with the Code may be subject to disciplinary action or termination. CROSS TRADES Clients and prospective clients can obtain a copy of the Firm’s Code of Ethics by contacting Ruffer’s Chief Compliance Officer, Lucy Hodgson, at +44 (0)20 7824 0520 or lhodgson@ruffer.co.uk PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS – PERSONAL SECURITIES TRANSACTIONS Employees may buy or sell securities identical to those recommended to clients for their personal accounts. In the ordinary course of business we do not act as principal, buy securities for ourselves from, or sell securities we own to clients. We shall only act as principal in a transaction in order to correct an error that we have made when managing our client’s portfolios. We do not recommend any securities to our clients in which we have a material financial interest. We do not effect any principal transactions for client accounts. We may cross trades between client accounts, but only when it is considered in the best interests of both clients and best execution can be achieved for both clients. CONFLICTS OF INTEREST However, employees are subject to the requirements of our Personal Account Dealing Policy and Procedures (the ‘Policy’), to ensure that any conflicts of interest that arise are mitigated. The Firm takes appropriate steps to ensure the interests of our clients are put ahead of the interests of ourselves or our employees. The policy requires employees to obtain prior approval for personal transactions and report such transactions and holdings. Client orders will have priority over employee deals. All securities captured by the Policy must be held for 90 calendar days. The Firm considers that the organizational and administrative arrangements it has established to prevent or manage conflicts of interest are sufficient to ensure, with reasonable confidence, that the risks of damage to the clients’ interests will be prevented. However, there are some examples of conflicts which we want to draw to your attention, so that you are aware of the sort of conflicts which we are preventing or managing and how we will try and mitigate or manage the conflict. The Code and Policy, described above, are designed to ensure that the personal securities transactions, activities and interests of the employees of the Firm will not interfere with (i) making decisions in the best We may without prior reference to the client, give investment advice or effect transactions for the client which may involve (either directly or indirectly) a conflict between the client’s interests and Ruffer’s interests or the interests of another Ruffer client. These may arise for example because interest of clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. a we act as investment manager for another client or clients with interests in investments in relation to which we provide investment advice or may effect transactions for the portfolio b we, or our staff members, may have an interest in investments in which we may provide investment advice or effect transactions for you Under the Policy certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of our clients. Nonetheless, because the Policy in some circumstances would permit employees to invest in the same securities as clients, there is a potential risk that employees might benefit from market activity by a client in a security held by an employee. To help manage this risk, the Firm maintains a list of restricted securities that c your portfolio contains securities where a Ruffer staff member is a director or other officer of the issuer 8  d the transaction or investment advice is in relation to a collective investment scheme or investment trust whose assets are managed by us or one of our subsidiaries e only limited quantities of a particular investment of the transaction, the need for timely execution, the liquidity of the market, the size of the order, the nature of the financial transaction, including whether it is executed on a regulated market or over-the-counter, the likelihood of settlement and the prevention of any information leakage. We will exercise our own discretion in determining the factors that we need to take into account for the purpose of providing ‘best execution’ to our clients. may be transacted for client portfolios, for instance because of a shortage in the market, because there is a limit on the amount of a particular investment that we can sell, or because there is a limit to the amount of an investment that it would be prudent for us to take on for our client base as a whole or f we are correcting a dealing error. Research is paid for directly by us, whether it is provided by a broker or an independent research provider. Third party research is an important source material for our research team and fund managers. The cost is not part of dealing/execution charges mentioned above and there is no link between the execution commission paid when we deal and the receipt of research. BROKERAGE FOR CLIENT REFERRALS As concerns items (a) to (d) and (f) above, we will always take appropriate steps to ensure fair treatment for you by disregarding any interest we may have when advising you or dealing on your behalf, and by maintaining procedures preventing members of staff from gaining an unfair advantage from the holding of, giving advice in relation to, or dealing in investments on behalf of their clients. We may pay referral fees to independent broker-dealers for the marketing to and referral of US clients to our Firm. In these cases, there will be a written agreement between ourselves and the solicitors, which clearly defines the duties and responsibilities of the solicitor under this arrangement. The referral fees represent a share of the investment management fee that we charge to our clients, but do not result in higher costs. The referral fees will be disclosed to clients who are referred to us under such an arrangement. DIRECTED BROKERAGE As concerns item (e) we operate the overriding principle that any allocation of an investment to or from a client is that it must be fair and appropriate to all the Ruffer clients concerned. We will disregard any differential portfolio performance of clients involved in allocation decisions and will ensure that no client is intentionally advantaged or disadvantaged vis-à-vis another, though on occasion the effect of allocation may be to favor one client over another. A pro rata allocation process is followed, subject to minimum trade size and minimum trade increment of the investment. Clients cannot direct us to use a particular broker- dealer to execute some or all transactions for the client (‘directed brokerage’). ITEM 12: BROKERAGE PRACTICES TRADE AGGREGATION RESEARCH AND OTHER SOFT DOLLAR BENEFITS We do not receive soft dollar benefits. The cost of execution charged by broker/dealers in connection with client securities transactions are charged directly to the client. We may aggregate trades for multiple accounts. Trade aggregation is the act of trading a large block of a security in a single order. Shares of a purchased or sold security are then allocated to the appropriate accounts in the appropriate proportion. The main purposes of order aggregation are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a larger quantity. Orders for the same security entered on behalf of more than one client may be aggregated (ie, blocked or bunched) subject to the aggregation being in the best interests of all participating clients. If an order has not been filled completely so that there are not enough shares to allocate among all the clients equally, When dealing we will pass orders to a broker/dealer for execution. When executing an order, we take all sufficient steps to achieve ‘best execution’ in relation to that order. We have in place a policy and procedures which are designed to obtain the best possible execution result for the client. This is dependent on the nature of the orders, the market in question and a balance of other, sometimes conflicting, factors. We will take into consideration a range of different factors which include not just price, but also the total cost 9  We encourage frequent contact with our clients but will only contact the client when deemed necessary. Our clients can contact us at any time. Clients are obligated to promptly notify us of any material changes in their financial situation or investment policy to ensure that our investment strategy continues to be appropriate and in line with expectations. shares will be allocated in good faith, on a pro rated basis. If a partial execution is attained at the end of the trading day, we will allocate shares on a pro rata basis. All clients participating in each aggregated order shall receive the average price and subject to minimum ticket charges, pay a pro-rata portion of execution commissions. REPORTING Our allocation procedure seeks to be fair and equitable to all clients with no particular group or client(s) being favored or disfavored over any other clients. ITEM 13: REVIEW OF ACCOUNTS REVIEWS We prepare periodic reports, at least quarterly, which generally include individual holdings, cost basis information, deposits and withdrawals, acquisitions and disposals, accrued income, dividends, performance, a broker commission summary and custody statement. We may also prepare reports or communications related to our investment services at other times, including when requested by clients. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Fund managers have overall responsibility for the management of each account. Each Fund Manager has the responsibility of managing the portfolio according to Ruffer’s single investment strategy, taking into account the clients’ specific investment policy objectives and constraints. OTHER COMPENSATION We do not receive any economic benefits (other than normal compensation and benefits described in Item 12) from any firm or individual for providing investment advice. The Asset Allocation team meets regularly, at least once a week, to set our investment strategy and asset allocation. They review the overall portfolio in the context of the macroeconomic environment and ensure it is well positioned to meet our central investment objectives of capital preservation. The analysis incorporates stress testing and scenario analysis. COMPENSATION – CLIENT REFERRALS – SOLICITATION ARRANGEMENT We review all of a client’s relevant financial information, including investment portfolios. Reviews include analyzing securities, sensitivity to overall markets, economic changes, investment results and asset allocation, to ensure the investment strategy and expectations are structured to continue to meet clients’ investment objectives. We may pay referral fees to independent solicitors for the referral of clients to our Firm. In these cases, there will be a written agreement between ourselves and the solicitors, which clearly defines the duties and responsibilities of the solicitor under this arrangement. Any client who is referred to us by a solicitor will be given a full written disclosure describing the terms and fee arrangements between us and the solicitor(s). ITEM 15: CUSTODY CUSTODY – ACCESS TO CLIENT CASH AND/ OR SECURITIES Portfolios are generally monitored continuously by the portfolio manager; however, formal reviews could also occur at the time of new deposits, material changes in a client’s investment policy requirements or financial situation, changes in market, political or economic conditions, at our discretion, or as often as the client directs. On a quarterly basis all portfolios are independently reviewed for performance dispersion and large dif- ferences in asset allocation. Where portfolios flag the relevant manager is required to provide a reason and, if necessary, correct the divergence. The Oversight & Controls Committee oversees this process, and reports to the Executive and Risk Committees of the Board. We do not have physical custody of any clients’ cash or bank account or securities. Our clients will direct us to work with their chosen acting custodian, with our authority over the client’s custody account being limited to settling transactions that we have undertaken under the terms of the IMA and related currency transactions, corporate actions and exercising voting rights. 10  CUSTODY – FEE DEBITING ITEM 17: VOTING CLIENT SECURITIES PROXY VOTING We will vote proxies on behalf of our clients, using the authority set out in the IMA. If any conflict of interest exists which cannot be mitigated, it will be disclosed to the client. Clients may contact us for information about proxy voting which has been carried out on their behalf. Clients may authorize us (in the IMA) to debit fees directly from their account at the broker dealer, bank or other qualified custodian (‘custodian’). The custodian is advised in writing of the limitation of our access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to the Firm. For funds, the administrator reconciles to the custodian daily. CUSTODY – POOLED INVESTMENT VEHICLES Ruffer LLP and/or one of our subsidiaries are either the General Partner, Managing Member and/or sole investment adviser to one or more private funds (the ‘Fund(s)’). We are committed to being good stewards of our clients’ assets. We believe this approach will lead to better long-term performance for our clients, whilst also benefiting the companies we invest in, the environment and society. To that end, we take our voting responsibilities seriously. The opportunity to vote enables us to encourage boards and management teams to consider and address areas we are concerned about or want to support, particularly if engagement has not been successful. We comply with the SEC’s Custody Rule with regard to the custody of the Fund(s) by ensuring that each US- based Fund receives an annual audit, and the audited financial statements are sent to investors within 120 days of each Fund’s fiscal year end as required. CUSTODY – ACCOUNT STATEMENTS We have an internal voting policy which reflects both our investment objectives and our investment approach. The policy includes criteria for determining whether a remuneration policy should be supported, along with criteria for determining independence and over-boarding of directors and the composition of board sub-committees. Clients receive at least quarterly statements from the custodian that holds and maintains client’s investment assets. Clients are urged to carefully review such statements and compare such official custodial records to the reports that we provide. Our quarterly reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. ITEM 16: INVESTMENT DISCRETION Our internal voting policy provides guidelines to assist analysts in their decision to vote. However, our research analysts review relevant issues case by case. Drawing on support from our Responsible Investment team and the accumulated knowledge of the company, analysts will make an informed judgement on how to vote. ITEM 18: FINANCIAL INFORMATION The Firm only manages client accounts on a discretionary basis. The terms of this discretion are laid out in the IMA provided to all clients before the commencement of the investment management service. We have no financial commitments that impair our ability to meet contractual and fiduciary commitments to clients and we have not been the subject of a bankruptcy proceeding. We have the right to retain, sell, buy, exchange or otherwise deal in investments without getting our client’s consent first. When we do this, we are guided by our investment objectives, taking into account our client’s investment constraints. We do not require prepayment of fees of more than $1,200 per client, six months or more in advance; and therefore, we are not required to provide a balance sheet to clients. 11