SEC Insider Trading

Strategic Equity Capital plc is a closed-ended equity mutual fund launched and managed by GVO Investment Management Limited. It invests in the public equity markets of the United Kingdom. The fund seeks to invest in the stocks of companies operating across diversified sectors. It primarily invests in value stocks of companies with market capitalization of less than GBP 150 million. The fund employs a private equity technique to create its portfolio with a focus on companies that can benefit from strategic, operational or management initiatives and factors such as cash flow, asset backing, internal rate of return, value catalyst identification, and exit plan. It benchmarks the performance of its portfolio against the FTSE Small Cap ex IT Total Return. Strategic Equity Capital plc was formed on May 10, 2005 and is domiciled in the United Kingdom.