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COP26

The biggest climate change talks since the landmark Paris Agreement in 2015, COP26 is a global reassessment of one of the most urgent crises the world is facing right now. But what are the real underlying questions, and how do these translate into investable themes – and potential pitfalls?

Investors split on compulsory ESG reporting

Standardised disclosures will provide useful information for investors, but the changes agreed by the G7 are only one step on the way to net-zero emissions

ARTICLE / 1

Economic and climate justice are intertwined

Limiting global emissions could have the effect of kicking the economic ladder out from under the world’s poorest nations

ARTICLE / 2

What does it all mean?

COP26

Climate funding gap demands investor attention

The $100bn-a-year commitment to aid developing countries with climate finance is not being met and, in any case, is woefully outdated

ARTICLE / 3

Time for transition

The greenhouse gas emissions of today will be the environmental catastrophe of tomorrow if we don’t speed up the green energy transition

ARTICLE / 4

Thematic investing in the wake of COP26

Thematic investment portfolios must consider the climate transition and financial inclusivity as mega-trends lean towards the UN’s SDGs

ARTICLE / 5

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Can environmental solutions make any money?

Climate change is not fake news, and the global rise in temperatures is not a drill. What does that mean for investors following COP26?

VIDEO / 2

The Jupiter Environmental Solutions range

‘It’s a huge booming market, no doubt about it’

What does the massive increase in sustainable bond issuance mean for investors? Could the impact that’s being delivered actually be smaller? Jupiter’s Rhys Petheram weighs in.

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The Jupiter Environmental Solutions range

VIDEOS

ARTICLES

‘Greenhouse gases care little for borders’

It’s a wrap! COP26 has come to an end. Our panellists take a look at its legacy.

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Roundtable

INFOGRAPHIC

COP26: A MAKE OR BREAK MOMENT

The 2015 Paris Agreement committed to keep global temperature rises ‘well below’ 2C, preferably 1.5C. COP26 in Glasgow was a vital staging post: unless things change dramatically, we are not going to meet the Paris targets.

It’s a wrap! COP26 has come to an end. Our panellists take a look at its legacy.

INFOGRAPHIC

Investors split on compulsory ESG reporting

Announced with some fanfare in June, the G7’s move to back the idea of compulsory reporting in line with the Task Force on Climate-related Financial Disclosures (TCFD) framework recognised the need for a ‘baseline global reporting standard for sustainability’. But what does this mean for investors? Opinions are divided. While there’s a consensus that more standardisation of reporting can only be a good thing, opinions differ on how much change will be catalysed. ‘TCFD has so far been a voluntary disclosure regime and now it’s set to become mandatory, but to be blunt I’m not sure how much will really change. Ultimately, the system will still be quite effectively gamed by big companies,’ said Patrick Thomas, head of ESG at Cannacord. He pointed to HSBC as a good example. ‘The company has been disclosing for years that about 21-25% of its balance sheet is going to be highly affected by climate change. That’s been very heavily emphasised in the voluntary TCFD data they already disclose – and yet investors haven’t really done anything about it. The company barely gets a question about it on investor days. I think the fact that these disclosures are now set to become mandatory is not likely to have a big effect.’

Standardised disclosures will provide useful information for investors, but the changes agreed by the G7 are only one step on the way to net-zero emissions

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Louisiana Salge of EQ Investors said mandatory reporting will be helpful, but sees limitations in the framework as set out. ‘While it’s important that governments are pushing the philosophy that companies need to think about climate-related risk and report on that, the framework is not very prescriptive in setting targets and aligning with a net-zero trajectory.’ Nevertheless, TCFD has had an influence on companies and is, therefore, helpful to investors, Salge said, most notably via its impact in getting carbon emissions reporting up to standard in line with the GHG Protocol. ‘It has allowed investors to make better decisions. For example, across the value chains of the businesses we look at, disclosures on emissions are increasing, and that’s really good for us as investors because carbon emissions are the best proxy to understand climate risk. So, on that front, TCFD has been successful and making it mandatory across the G7 will be helpful to investors.’

I think the fact that these disclosures are now set to become mandatory is not likely to have a big effect

Patrick Thomas, Cannacord Genuity

Ultimately, TCFD increases the quality of reporting, which leads to better standardisation – something we don’t have at the moment

Abbie Llewellyn-Waters, Jupiter Asset Management

Although it’s just one step on the journey, mandatory TCFD reporting is helpful, said Abbie Llewellyn-Waters, head of sustainable investing at Jupiter Asset Management. ‘Ultimately, TCFD increases the quality of reporting, which leads to better standardisation – something we don’t have at the moment. Our aim as investors is to get higher-quality, better standardisation of reporting that enables better comparability of climate-related financial risk for the purposes of capital allocation.’ She added that although TCFD covers climate-related risk, including climate resilience, it doesn’t extend to other important areas such as biodiversity and natural capital. ‘The Taskforce on Nature-related Financial Disclosures covers these aspects, and we expect that also to become mandatory at some point.’

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Economic and climate justice are intertwined

In recent years, the world has begun to come to terms with the implications of aligning with the Paris Agreement’s goal of limiting global warming to 2 degrees. The transition to more sustainable methods will involve huge disruption and place more than a billion jobs at risk unless the situation is handled carefully. The secretariat of the UN Framework Convention on Climate Change has identified 1.47 billion jobs at risk across a range of industries, notably in agriculture, manufacturing, building, transport and energy. Unless they are considered from the start, the effect will be even greater inequality and ultimately widespread social problems, said Paris Jordan, multi-asset analyst at Waverton. ‘It’s important to remember that the transition to a more sustainable economy will have enormous social consequences and will affect billions of workers around the world as their industries undergo massive disruption and structural change,’ she added.

Limiting global emissions could have the effect of kicking the economic ladder out from under the world’s poorest nations

The transition to a more sustainable economy will have enormous social consequences and will affect billions of workers around the world

Paris Jordan, Waverton

Abbie Llewellyn-Waters, head of sustainable investing at Jupiter Asset Management, is particularly concerned about the social effects of low-carbon transition in the poorest nations – the so-called least-developed countries. ‘The developed nations have been able to grow their economies for over a century, partly by doing pretty much whatever they wanted regardless of the environmental consequences. ‘Now, we’re saying to the developing world that they need to stop burning coal – but this will come at great expense to their economies, making them less competitive. And, of course, this geopolitical dynamic is one of the bottlenecks to delivering a more actionable global policy mandate,’ she said. ‘This is one of the main reasons why ensuring a just transition will be so important.’ International co-operation will be essential to ensuring the energy transition can be approached in a just manner, Llewellyn-Waters said. ‘The US-China Joint Statement Addressing the Climate Crisis brokered by John Kerry in April 2021 should not be underestimated in this context. That was the world’s two largest emitters agreeing to co-operate on climate policy, which effectively gives a precedent for collaborative or collective action because greenhouse gases – like viruses – care little for borders.’

It will be important for politicians, central bankers and investors to think about what it means for poorer nations to be able to compete on a fair basis while meeting climate goals

Abbie Llewellyn-Waters, Jupiter Asset Management

The largest countries must not only look to their just transitions but also carefully consider the environmental and social aspects of the transition among the least-developed countries, she said. The change is made clear by the rising cost of carbon, which, based on the EU’s emissions trading system, stood above €60 per tonne in early October. ‘Looking back to last year, the price had barely broken through €30 in the history of the scheme. The price doubled in the space of nine months, which means that it’s now much more punitive for companies to emit a tonne of carbon than it used to be,’ Llewellyn-Waters said. ‘Against this backdrop, it will be important for politicians, central bankers and investors to think about what it means for poorer nations to be able to compete on a fair basis while meeting climate goals, as well as the need for standardisation of principles for emission reductions. In particular, we are watching closely what rules will be used to mitigate double counting of carbon, as outlined in article six of the Paris Agreement.’

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Climate funding gap demands investor attention

As part of the COP16 Accord in 2009, developed countries committed to a goal of $100bn a year by 2020 to address the needs of developing countries. With the target date now passed, developed countries are still falling woefully short on that pledge. ‘Currently they’re nowhere near that $100bn number,’ said Rhys Petheram, head of environmental solutions at Jupiter Asset Management. ‘Studies vary, but most suggest the real number is between half and two-thirds of that figure. Many of the countries that signed up to the commitment have actually decreased funding over the last decade.’ He added that more recent assessments have shown that even meeting the $100bn target would fall far short of what is required. ‘In 2009, that might have seemed an easy round number for policymakers to focus on. But since then, there has been a lot of work on studying climate change, physical risks and what we have to do from an investment perspective. More recent reports assess the investment required to reach a 1.5C world, and their estimate is around four or five trillion dollars. The $100bn number, to my mind, is an out-of-date figure.’

The $100bn-a-year commitment to aid developing countries with climate finance is not being met and, in any case, is woefully outdated

It doesn’t matter where you take the carbon out of the atmosphere – whether it’s in Bangladesh or the UK, it’s still the same tonne of carbon

Rhys Petheram, Jupiter Asset Management

The upshot is that the $100bn figure needs to increase – but even that starting point has not been met. ‘This is essential to the global project of emissions reduction: at the end of the day, it’s a global challenge, and it doesn’t matter where you take the carbon out of the atmosphere – whether it’s in Bangladesh or the UK, it’s still the same tonne of carbon. It costs roughly half as much to reduce a tonne of carbon in a developing country, relative to a developed country, because business costs in developing countries are a lot lower. So it makes economic sense.’ As the funding gap is met, opportunities will naturally arise for investors. ‘To give a tangible example, in the context of our environmental solutions, we focus on those companies that are trying to enable or trying to make the investments to make change,’ Petheram said. ‘So, within our global ecology diversified strategy, we have a reasonably heavy allocation to development banks. We think their role is going to become increasingly important over time – and that there will be an increased focus and commitment from sovereigns to support the development banks, underpinning the importance of those institutions over time.’

By focusing on development banks, we think we are directing capital towards the entities best placed to be able to directly fund projects and manage the human rights component

Rhys Petheram, Jupiter Asset Management

From a fixed income point of view, he said investing in sovereign debt in the developing world can raise a plethora of conflicts- and this makes the development banks more attractive. ‘If you’re funding a budget in Egypt, you are effectively supporting a regime that is responsible for human rights abuses. By focusing on development banks, we think we are directing capital towards the entities best placed to be able to directly fund projects and manage the human rights component.’

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Time for transition

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As the climate crisis becomes increasingly visible, the risks and opportunities of a green energy transition cannot be ignored by investors. ‘We are now getting very close to the wall,’ said Damien Lardoux, head of impact investing at EQ Investors. ‘The emissions we are producing today will be having an impact in 10- or 20-years’ time. So, when we look at 2050 targets for emissions, we have to understand that the crucial decade is the coming one, and we need to start moving towards those targets in a decisive manner, with no time to lose.’ To consider the downside, in terms of portfolio assessment, key sectors now have massive embedded risk, he said. ‘Stress testing has shown that if we rapidly align with a 1.5-degree emissions target, then energy, utilities, airlines and some other sectors could see companies losing up to 60% of their value. So the message we are trying to get across is that it makes sense to minimise exposure to those sectors, or at least, within those sectors, go for the best in class,’ he said. ‘For example, in the energy sector, it would make sense to avoid Exxon, which is moving relatively little into green energy, and instead favour a company like France’s Total, which is a lot more forward-thinking. We see the Science Based Targets as important to making these assessments.’ On the flip-side, the energy transition will require huge investment, creating a big opportunity for investors, Lardoux said. ‘This is an area where we are really excited to get clients invested across the whole value chain. It’s not only about renewable energy, but will also be about energy storage and battery technology.

The greenhouse gas emissions of today will be the environmental catastrophe of tomorrow if we don’t speed up the green energy transition

In the energy sector, it would make sense to avoid Exxon, which is moving relatively little into green energy, and instead favour a company like France’s Total, which is a lot more forward-thinking

Damien Lardoux, EQ Investors

‘It will be the entire power grid, including smart meters. It will also be electric vehicles, and insulation panels. It’s not just a single-sector story: it’s now possible to build a portfolio diversified across sectors, benefiting from these opportunities and offering better growth prospects than the overall market.’ While seeing great opportunity in the clean energy space, Jon Wallace, fund manager in the environmental solutions team at Jupiter, highlighted areas where the effects of the energy transition are less immediately obvious but nevertheless enormously influential going forwards. ‘One area I would highlight is the circular economy and, in particular, the energy efficiency space: Companies, including Jupiter but also many other big companies, have plans to reach net-zero emissions,’ he said. ‘We are all having to think about what running a net-zero emissions business by 2050 will mean – and then, what does that mean over the five or 10 years?’ This means that companies have to think outside the four walls of their businesses, beyond their own direct energy use, and look through their supply chains and at their energy sources. ‘Companies are starting to think “upstream and downstream” at their suppliers and also how their products are used throughout their lifecycle,’ Wallace said. ‘What happens to their product – if it is a product – at the end of that period? Is it disposed of? What does that mean from a carbon emissions perspective?’ This thought process is triggering a lot of change in industries that haven’t previously considered these issues, he added. ‘We are starting to see powerful signals driven by the corporate net-zero agenda. And what we as investors are looking for is the enablers, the companies that have the technologies and solutions that enable other companies to meet their net-zero targets,’ he said.

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Thematic investing in the wake of COP26

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The post-pandemic world offers new perspectives on how to position portfolios in light of long-term megatrends, investors say. ‘Whereas a couple of years ago, investment managers were talking about China or inflation or other macro themes, we think the most important megatrends that should shape portfolios for the next 10 to 20 years are the climate transition and the idea that economic growth must work for more people,’ Patrick Thomas, head of ESG at Canaccord Genuity Wealth Management, said. ‘If you’re looking for areas that can drive exponential growth returns ahead of the MSCI World over the next five to 10 years, I would focus exclusively on those areas,’ he said. ‘And what’s interesting is that, 10 years ago, those would be niche thematic areas of your portfolio, but now they need to be the core.’ Within the climate transition, sub-themes could include electrification of transport, clean energy, clean water, circular economy and reusable materials, while on the more inclusive economic growth side, he highlighted healthcare, education and data privacy. At an implementation level, Thomas uses these themes as starting points, and prefers funds offering a relatively broad exposure. ‘Many of these themes are very multi-faceted: Clean energy, for example, can be viewed as a play on the utilities transition, the industrials facilitating that transition, or the future of transport with EVs and then looking along the battery value chain. ‘So, it might sound like a niche area, but it is, in fact, very broad and spans a number of sectors, meaning there will be a number of very, very different drivers at different times fuelling your return profile.

Thematic investment portfolios must consider the climate transition and financial inclusivity as mega-trends lean towards the UN’s SDGs

Financial inclusion, social equality and carbon capital at risk in the market through decarbonisation are the key long-term structural allocations for us

Abbie Llewellyn-Waters, Jupiter ASSET MANAGEMENT

‘When you start putting these themes into a portfolio, I think you need to accept that you’re unlikely to be the person that picks the winner and that what matters more is that you have a fund that is exposing you to a group of companies that are likely to win,’ he said. Abbie Llewellyn-Waters, head of sustainable investing at Jupiter, picked up the point about greater inclusivity. ‘The pandemic has had a severe impact on the socially-oriented goals of the SDGs [the UN’s Sustainable Development Goals], and this is not just a developing market problem,’ she said. ‘If we look at child poverty rates – those living on less than $1.90 a day – across the world, including developed markets, they’re running unsustainably high: in Europe and the US, they are over 20%. ‘For us, as investors, this means that the inclusivity of the economic frameworks of the companies we invest in will be very important going forwards.’ Again, the theme is broad and can be addressed in different ways. ‘We know that female participation in the workforce leads to a reduction of child poverty. So having an investment framework that seeks to understand gender parity and gender participation in the workforce is intrinsically important to delivering a more inclusive economic framework, in our view. ‘We will continue to focus on the social equality element through a lens of inclusivity,’ she said. Llewellyn-Waters also highlighted the importance of financial inclusion, particularly in the developing world. Echoing Thomas’s sentiment around the two broad macro megatrends, she said: ‘Financial inclusion, social equality and carbon capital at risk in the market through decarbonisation are the key long-term structural allocations for us.’

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COP26: A MAKE OR BREAK MOMENT

The 2015 Paris Agreement committed to keep global temperature rises ‘well below’ 2C, preferably 1.5C.

COP26 in Glasgow was a vital staging post: unless things change dramatically, we are not going to meet the Paris targets.

Did the Glasgow summit live up to its billing?

Politicians, industry, regulators, and investors have come together at exactly the right time to be able to deliver something meaningful. I think they’ve gone to the heart of some of the most difficult issues around reduction of emissions, fossil fuel subsidies, and how we price or internalise some of these costs.

I think it has been an incredibly historic event. I would hope that the delivery of it will be just as historic. I have spoken to people who have been on the ground there, and many are full of cautious hope.

After COP26, are we on track for a 1.5-2 degree global heating target?

According to the International Energy Association, COP26 climate pledges could help limit global heating to 1.8C. But how these pledges are implemented will be key.

reduction of emissions

fossil fuel subsidies

Source: https://www.iea.org/commentaries/cop26-climate-pledges-could-help-limit-global-warming-to-1-8-c-but-implementing-them-will-be-the-key

‘What we’re focused on is the actionability of the policies, the measurability of the policies and their irreversibility.’

1.8°

1.5°

2°

Abbie Llewellyn-Waters

Have the biggest greenhouse gas emitters changed their position?

The positions of the biggest emitters, China and the US, are key:

China

27%

is responsible for around

of the world’s emissions

11%

is the second-largest at around

India

6.6%

is third at

Source: https://rhg.com/research/chinas-emissions-surpass-developed-countries/

The US and China pledged to boost climate co-operation over the next decade, agreeing to work together on methane emissions, decarbonisation and a clean energy transition.

India pledged to hit net-zero emissions by 2070.

‘We’ve got the two largest emitters at the table now. I think that sends a really strong signal that we’re going to see that progress coming through.’

Abbie Llewellyn-Waters

The US-China announcement was really a change in landscape.

The least-developed countries were the focus of much attention in Glasgow. They stand to suffer economic and social damage from stricter targets on CO2 emissions because their economies are more reliant on fossil fuels. What can investors do to help with the problem?

‘The Just Transition principles are essential to helping the least developed countries. This means making sure the transition to a resilient, low-carbon economy takes place in a socially inclusive way by protecting jobs and ensuring equitable solutions for everyone as global industries realign. ‘Developed markets have been able to grow their economies for centuries with little regard to the environmental consequences. Now we are saying the developing world must cut emissions, but this could affect their economic growth. So, ensuring a just transition is vital.’

Abbie Llewellyn-Waters

What does all of this mean for investors? How will the COP26 outcomes affect portfolios?

‘This is a long-term structural shift in how we price assets and how we generate returns for our clients. I think from that perspective, either it’s investing in solutions or it’s investing in those companies who are mitigating their impact. ‘At the same time, with the Task Force on Climate-related Financial Disclosures becoming mandatory across the G7 countries, companies are also under pressure to improve their reporting on climate and other sustainability issues. This supports comparability, improving managers’ ability to measure and manage climate related financial risk in portfolios.’

Abbie Llewellyn-Waters

‘The focus on reporting and science-based targets is going to be really important. It will make our lives easier, but it will also mean that we must hold fund managers and companies to account.’

Victoria Hasler

GLASGOW

COP26

What stands out about Jupiter’s offering when it comes to responsible investing?

‘There is a phenomenal opportunity to get this right. Jupiter’s sustainable investing strategies offer a credible alternative to mainstream global equities with a capital growth objective while also delivering positive outcomes for environmental and societal needs, based on 30 years of investing in this space.‘

Abbie Llewellyn-Waters

to find out more about Jupiter’s sustainable investing expertise, click here

Abbie Llewellyn-Waters

HEAD OF SUSTAINABLE INVESTING, JUPITER ASSET MANAGEMENT Since joining Jupiter Asset Management in 2006, she has dedicated her investment career to sustainable investing, with her team building and designing a rigorous investment framework that embeds all stakeholders into fundamental stock analysis. Multi-award winning, Abbie has received recognition for her investment performance, her approach to ESG integration and her contribution to address the structural hurdles that women in investment face. She also collaborates on several industry initiatives including as an author for the CFA Institute on Climate and Investing certificate. She is an Ambassador for the Diversity Project and is a member of the 30% Club Investor Group. She has a degree in Classics.

MULTI-ASSET ANALYST, WAVERTON INVESTMENT MANAGEMENT Paris joined Waverton in 2021 as a multi asset analyst, specialising in fund selection. Paris has held roles at Murano as head of investment consulting and prior to that at Sanlam and Fidelity. She has a proven track record across a variety of asset classes and a notable specialism in ethical and sustainable investing. Paris was ranked a Top 30 under 30 Investor by Citywire and was awarded WeAreTheCity’s Rising Star in Investment Management Award. She is a CFA Charterholder.

Paris Jordan

HEAD OF FUND SELECTION Victoria is Head of Fund Research at EQ Investors, having joined in 2020 from Square Mile Investment Consulting & Research where she was Director, Research and Consulting. Victoria is responsible for the fund research team and output, as well as covering various sectors including fixed income, property and alternatives. She also sits on the investment oversight, portfolio management, strategic asset allocation and fund selection committees. Victoria began her career in Financial Services at Merrill Lynch Investment Managers and gained experience at Rothschild Private Bank and Trust and Brewin Dolphin as well as Square Mile. She graduated from the University of Durham with a BA in Economics and French, and is a CFA charterholder as well as holding the IMC and CAIA qualifications and the CFA Society’s Certificate in ESG Investing. Outside of the office Victoria enjoys hiking, both locally and in more exotic climes, cross-country and downhill skiing and bootcamp classes in muddy parks.

Victoria Hasler

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This includes, but is not limited to, the use of Content for any form of news aggregation service or for inclusion in services which summarise articles, the copying of any fund manager data (career histories, profiles, ratings, rankings etc) either manually or by automated means (“scraping”). 4.2 All Intellectual Property Rights in and to our Site and App (including the Content) is owned by Citywire or our third party licensors. No rights are granted to you in relation to such Intellectual Property Rights other than the limited licence rights expressly set out in clause 5. 4.3 Content is protected by copyright laws and treaties around the world, including, without limitation, U.S. Copyright law. Unless otherwise noted, the Site, the App, and all Content are © Citywire Financial Publishers Ltd 2019. All rights not expressly granted herein are reserved. Images and videos used on our websites may come from various third party image libraries. For credit information relating to specific images where not stated, please contact picturedesk@citywire.co.uk 5. Licence 5.1 Subject to the terms of this Agreement, Citywire grants you a non-transferable, non-sublicensable, royalty-free, non-exclusive limited licence to use our Site on the following conditions: (i) you may, subject to clauses 5.3, 5.4 and 5.5, display Feed Content on your website and on other websites in respect of which you have obtained all necessary permissions and authorisations to display Feed Content on; (ii) you shall not copy, display, reproduce or create derivate works from any Content (other than Feed Content to which clause 5.1(i) applies); and (iii) nothing in these Terms grants you any right to use Citywire’s logo, brand or trade marks on your site or elsewhere. 5.2 You must ensure that all Feed Content displayed on any websites pursuant to clause 5.1 has an accreditation to Citywire as follows: “Citywire information is proprietary and confidential to Citywire Financial Publishers Ltd (“Citywire”). It may not be copied. Citywire excludes any liability arising out its use.” 5.3 Unless otherwise specifically agreed in writing by Citywire, you may not directly or indirectly charge users specifically for accessing Feed Content or otherwise commercialise Feed Content. You shall not re-sell or otherwise commercialise the Content in any way (other than the limited rights in relation to Feed Content set out in clause 5.1). 5.4 You must create a functional link back to the Citywire story(ies) summarised by the Feed Content. If you are displaying the Feed Content where a functional link back to Citywire is not possible, you must display on-screen the URL from which the Feed Content can be obtained. You may not directly or indirectly change, edit, add to or produce summaries of or derivative works from Feed Content or any content on the Citywire website nor place any full-story Citywire content in an HTML (or any other markup language) frame-set. 5.5 You may not directly or indirectly suggest any endorsement or approval by Citywire of your website or any non-Citywire entity, product or content or any views expressed within your website or service. 5.6 You acknowledge that Citywire has absolute editorial control over all Content and you accept that Citywire is editorially independent and that the editorial integrity of Content is the sole responsibility of Citywire. 5.7 Should you receive any enquiries which relate to Citywire or the Citywire Content you shall promptly refer such enquiries to Citywire. 5.8 You acknowledge and agree that we own all rights of whatever nature in and to the App. Citywire grants you a non-transferable, non-sublicensable, royalty-free, non-exclusive limited licence to (i) download the App to your device from the app store where it is lawfully held; and (ii) use the App for the purpose of accessing our Site on these Terms. You are granted no other rights in relation to the App and all rights not expressly granted are reserved by us. You acknowledge and agree that Citywire has no responsibility for or in relation to the app store from which you downloaded the App and has no obligation to maintain the App. The App is supplied ‘as is’ and neither Citywire nor any anyone else makes any representation, warranty, condition or other commitment (whether express or implied, by statute, common law, collaterally or otherwise) of any kind in relation to the App. Neither Citywire nor anyone else will have any liability of whatever nature (whether in contract, negligence or other tort or otherwise) in relation to the App. You will not reverse engineer, decompile or otherwise endeavour to obtain the source code to the App (save to the extent that you cannot be prohibited from so doing under applicable law). 6. Contributions 6.1 Whenever you make any Contribution you must comply with the Content Standards. 6.2 Subject to these terms of use, Citywire acknowledges and agrees that you retain ownership of all your intellectual property rights to your Contributions, and no intellectual property rights shall be assigned from you to Citywire. 6.3 You grant Citywire a perpetual, royalty-free, non-exclusive, perpetual (which for the avoidance of doubt means continuing after this Agreement), irrevocable, transferable, world-wide licence to use, copy, distribute, display, disclose and sell to third parties any Contribution (in whole or in part) for any purpose. These activities include but are not limited to editing or creating derivative works of any Contribution. 6.4 To the maximum extent permitted by applicable law, you irrevocably and unconditionally waive all moral rights to any Contribution. 6.5 You acknowledge and agree that (i) we have the right to remove or edit any Contribution you make on our services, including modifying and adapting it for operational and editorial reasons, with or without showing or marking that the Contribution has been removed or edited; and (ii) we have the right to disclose your identity to any third party who is claiming that any Contribution constitutes a violation of their intellectual property rights, or of their right to privacy. 6.6 Citywire does not moderate or actively review Contributions. Therefore all Members and visitors to the Site should treat any Contributions with caution. You accept (i) that we are not responsible for content of Contributions; (ii) that we do not endorse any of the material contained in them; and (iii) Citywire does not check the accuracy of information supplied by Members in their profiles. 6.7 It is the policy of Citywire to respond to alleged infringement notices that comply with the Digital Millennium Copyright Act (“DMCA”). If you believe that your copyrighted work has been copied in a way that constitutes copyright infringement and is accessible via the Solution, please notify the Citywire copyright agent as set forth below. For your complaint to be valid under the DMCA, you must provide the following information in writing: a. An electronic or physical signature of a person authorized to act on behalf of the copyright owner; b. Identification of the copyrighted work that you claim has been infringed; c. Identification of the material that is claimed to be infringing and provide a link (where available) to where it is located on the Solution; d. Information reasonably sufficient to permit Citywire to contact you, such as your address, telephone number, and, email address; e. A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or law; and f. A statement, made under penalty of perjury, that the above information is accurate, and that you are the copyright owner or are authorized to act on behalf of the owner. The above information must be submitted to the following Citywire copyright agent: Ona Kviliute +44 (0)20 7840 5125 okviliute@citywire.co.uk 3 Spring Mews, London, SE11 5AN, United Kingdom UNDER FEDERAL LAW, IF YOU KNOWINGLY MISREPRESENT YOUR CLAIM, YOU MAY BE SUBJECT TO CRIMINAL PROSECUTION FOR PERJURY AND CIVIL PENALTIES, INCLUDING MONETARY DAMAGES, COURT COSTS, AND ATTORNEYS’ FEES. In accordance with the DMCA and other applicable law, Citywire has adopted a policy of terminating, in appropriate circumstances, the accounts of users who are deemed to be infringers. Citywire may also, at its sole discretion, limit access to the Site and/or terminate the accounts of any users who infringe any intellectual property rights of others, whether or not there is any repeat infringement. 7. Acceptable Use Policy 7.1 You may use our Site only for lawful purposes. You may not: (i) use our Site in any way that breaches any applicable local, national or international law or regulation; (ii) use any materials, data or information which you have obtained from the Site in any manner which, in Citywire’s reasonable opinion, is derogatory, damages Citywire’s reputation or takes advantage of it in any way; (iii) use our Site in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect; (iv) use our Site to send, knowingly receive, upload, download, use or re-use any material which does not comply with the Content Standards; (v) subject to Clause 5, deep-link to any portion of our Site for any purposes without the prior written permission of Citywire; (vi) perform any automated use of our Site, such as, but not limited to, using robots, spiders, scripts to create Contributions, to extract any of the content of our Site through such means as ‘screen scraping’, ‘database scraping’ or otherwise; (vii) violate the restrictions in any robot exclusion headers on this website or bypass or circumvent other measures employed to prevent or limit access to our Site; (viii) use this service as research or support for, or to inform your own or your company’s or employer’s subscription based service, or any subscription based service without obtaining a licence from Citywire in writing, such licence to be on commercial terms agreed by the parties; (ix) use our Site (or any of the Content) for the purpose of building a database or to use this for your own commercial exploitation by its inclusion in your own activities and/or services without obtaining the written approval of Citywire in advance of its publication; (x) access, use, or distribute the Site, App (or any Content) to develop (or assist any third party in developing) a product or service (including events) that competes with any product, service, or event of Citywire, or for any other competitive purposes. (xi) interfere with, disrupt, or create an undue burden on our services or the network or services connected to our Site; (xii) engage in, either directly or indirectly, or encourage others to engage in, click-throughs generated through any manner that could be reasonably interpreted as coercive, incentivised, misleading, malicious, or otherwise fraudulent; (xiii) collect information from our Site and incorporate it into your own database or products; or (xiv) use our services to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware. 7.2 Use of the Printable Version facility is for private purposes only EXCEPT ONLY In the case of financial intermediaries, wealth managers or other entities or individuals providing investment advice to clients the printable version can be used to aid such services. 8. Content standards 8.1 These content standards apply when you make a Contribution to the Site. These content standards apply to each part of any Contribution as well as to its whole. 8.2 Contributions must: (i) be accurate (where they state facts); (ii) be genuinely held (where they state opinions); and (iii) comply with applicable law, rules and regulations, in the U.S. and in any country from which they are posted. 8.3 Contributions must not: (i) infringe or promote infringement of any copyright, database right, trade mark or other intellectual property right of any other person (including, promoting or offering pirated computer programs or links to such programs, information used to circumvent manufacturer-installed copy-protect devices, including serial registration numbers for software programs, rights management information or any type of cracker utilities); (ii) contain intentionally made false or misleading statements; (iii) offer to buy, sell or broker an investment; (iv) violate applicable laws, rules or regulations, including without limitation, rules or regulations of any applicable stock exchange or breach insider dealing regulations or confidentiality agreements; (v) involve commercial activities and/or sales without prior written consent from us such as contests, sweepstakes, group-buying, advertising, or pyramid schemes; (vi) be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence; (vii) contain any material or link to material which: a. is defamatory of any person; b. is obscene, vulgar offensive, hateful or inflammatory; c. is likely to harass, upset, embarrass, alarm or annoy any other person; d. is threatening, abusive or invade another’s privacy, or likely to cause annoyance, inconvenience or needless anxiety; e. contains or promotes sexually explicit material or violence; f. promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age; or g. is likely to deceive any person; (viii) use invalid or forged headers to disguise the origin of any Contribution, or otherwise misrepresenting yourself or the source of any Contribution; (ix) use our Site to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam); (x) be used to impersonate any person, or to misrepresent your identity or affiliation with any person; (xi) give the impression that they emanate from Citywire or a Citywire employee, administrator or moderator, or another user of our Site; or (xii) advocate, promote or assist any illegal activity. 9. Non-reliance 9.1 You agree that you are responsible for your own investment decisions and that you are responsible for assessing the suitability and accuracy of all information and for obtaining your own advice thereon. You recognise that any information given on our Site is not related to your particular circumstances. Circumstances vary and you should seek your own advice on the suitability to them of any investment or investment technique that may be mentioned. (a) We do not provide, and no Content constitutes, investment advice; (b) You will not treat or represent Content as investment advice; (c) We do not recommend or endorse any product; (d) Content is not intended to address your particular requirements. We are not aware of circumstances specific to you and which could influence which financial products are more or less suitable for you and do not represent that we are aware of any such circumstances. We do not recommend that any particular product is suitable for you; (e) No Content constitutes or should be interpreted as a solicitation to engage in any investment activity; (f) Any investment decision made by you is entirely at your own risk; (g) Subject to paragraph 11, we shall not be liable for any losses, cost or expenses which may be incurred by you as a result of any investment made; (h) You may not use the Content in, or generate based on the Content, any advice, recommendations, guidance, publications or alerts made available to your clients or other third parties; (i) Whilst we try to ensure the Content is accurate and up to date, we cannot be responsible for any inaccuracies in Content. We are under no responsibility to provide you with access to any additional information or to update the Site, even if inaccuracies become apparent. 9.2 The fund manager performance analyses and ratings provided on this website are the opinions of Citywire as at the date they are expressed and are not recommendations to purchase, hold or sell any investment or to make any investment decisions. Citywire’s opinions and analyses do not address the suitability of any investment for any specific purposes or requirements and should not be relied upon as the basis for any investment decision. 9.3 Persons who do not have professional experience in participating in unregulated collective investment schemes should not rely on material relating to such schemes. 9.4 Past performance of investments is not necessarily a guide to future performance. Prices of investments may fall as well as rise. 9.5 Persons associated with or employed by Citywire may hold positions or take positions in investments referred to in this publication. 9.6 Citywire operates a policy of independence in relation to matters where the operators may have a material interest or conflict of interest. 10. Limited Warranty 10.1 Citywire will use reasonable endeavours to maintain the Site. You will not be eligible for any compensation because you cannot use any part of the Site or for any failure of the Site as a result of an event beyond Citywire’s reasonable control. 10.2 Neither Citywire nor its employees assume any responsibility or liability for the accuracy, completeness or availability of the information contained on our Site. 10.3 Neither Citywire nor anyone else makes any representation, warranty, condition or other commitment of whatever nature in relation to any information obtained by you through use of this Site. You acknowledge and agree that any information that you receive through use of the Site is provided “as is” and “as available” basis without representation or endorsement of any kind and is obtained at your own risk. 10.4 You agree that you are solely responsible for any damage to your computer system and/or loss or damage to your data files through use of this Site or by the use of links on the Site to external information. 10.5 To the maximum extent permitted by law, Citywire excludes all representations, warranties, conditions or other terms, whether express or implied (by statute, common law, collaterally or otherwise) in relation to the Site or otherwise in relation to any Content or Feed, including without limitation as to satisfactory quality, fitness for particular purpose, non-infringement, compatibility, accuracy, or completeness. 11. Liability To the maximum extent permitted by law, Citywire will not be liable in contract, tort (including negligence) or otherwise for any liability, damage or loss (whether indirect, consequential, special or otherwise) incurred or suffered by you or any third party in connection with our Site, or in connection with the use, inability to use, or results of the use of our Site or App, any websites linked to it or any materials posted on it or otherwise in relation to any Content or Feed. Citywire does not limit liability for fraudulent misrepresentation or for death or personal injury arising from Citywire’s gross negligence or willful misconduct. HOWEVER, YOUR EXCLUSIVE REMEDY FOR ANY CLAIM ARISING FROM A BREACH BY CITYWIRE OF THESE TERMS IS CESSATION OF USE OF THE SITE, APP, OR CONTENT. FURTHER, TO THE GREATEST EXTENT PERMITTED BY LAW, THE TOTAL LIABILITY OF CITYWIRE IS LIMITED TO THE GREATER OF $50 OR AN AMOUNT NOT EXCEEDING THE TOTAL AMOUNT ACTUALLY PAID BY YOU TO CITYWIRE DURING THE PRIOR SIX (6) MONTHS IN CONNECTION WITH YOUR INDIVIDUAL USE OF THE SITE OR THE APP. In addition, you may bring a claim only on your own behalf. You will not participate in a class action or class-wide arbitration for any claims covered by these terms. 12. Changes to our Terms Citywire may change the Terms from time to time. Any such changes will be incorporated on our Site. Changes will take effect 30 days after notification. Your continued use of any part of the Site following such change shall be deemed to be your acceptance of such amended Terms. You acknowledge that you are solely responsible for checking these Terms from time to time to see the changes which have been made to these Terms. If you do not accept any such changes you should stop using our Site. 13. Breaches; Term and Termination 13.1 The Terms will take (re-take) effect at the time you access and use the Site. You agree that Citywire may terminate your membership or the agreement constituted by these Terms (as Citywire may choose) and restrict your access to the Site (or part thereof) without prejudice to any other rights or remedies that Citywire may have if Citywire is of the reasonable opinion that you have breached these Terms or acted inconsistently with the spirit of these Terms. The provisions concerning Intellectual Property Rights, The Site, Contributions, Non-Reliance, Limited Warranty, Liability, Breaches; Term and Termination, Enforcing Security, Governing Law, Arbitration, Injunctive Relief, Waiver and Severability and Entire Agreement the Solution Feedback, Confidentiality, will survive the termination of these Terms and Conditions for any reason. 13.2 You agree to indemnify Citywire against any and all actions, claims, costs, proceedings, losses, damages or liabilities arising from your use of the Site or App (including without limitation Contributions or Content) and/or in relation to any information or data you use or access by means of the Site. 13.3 You acknowledge that a breach of these Terms may give rise to civil damages and criminal penalties. Citywire reserve the right to take action against you to uphold these Terms and its rights, which may involve pursuing injunctive proceedings, as further set forth below. 14. Enforcing Security. You may not use the Site, App, Content or any of Citywire’s data, systems, network, or services to engage in, foster, or promote illegal, abusive, or irresponsible behavior, including, without limitation, accessing or using data, systems, or networks in an unauthorized manner, attempting to probe, scan, or test the vulnerability of a Citywire system or network, circumventing any Citywire security or authentication measures, monitoring Citywire data or traffic, interfering with any Citywire services, collecting or using from the Site email addresses, screen names, or other identifiers, collecting or using from the Site information without the consent of the owner or licensor, using any false, misleading, or deceptive TCP-IP packet header information, using the Site to distribute software or tools that gather information, distributing advertisements, or engaging in conduct that it likely to result in retaliation against Citywire or its data, systems, or network. Actual or attempted unauthorized use of the Site may result in criminal and/or civil prosecution, including, without limitation, punishment under the Computer Fraud and Abuse Act of 1986 under U.S. federal law. Citywire reserves the right to view, monitor, and record activity through the Site without notice or permission from you. Any information obtained by monitoring, reviewing, or recording is subject to review by law enforcement organizations in connection with investigation or prosecution of possible criminal or unlawful activity through the Site as well as to disclosures required by or under applicable law or related government agency actions. Citywire will also comply with all court orders or subpoenas involving requests for such information. In addition to the foregoing, Citywire reserves the right to, at any time and without notice, modify, update, suspend, terminate, or interrupt operation of or access to the Site, or any portion of the Site in order to protect Citywire. 15. Governing Law; Void Where Prohibited. All offers for all functions, products or services, which are made on the Site, are void if they are prohibited by applicable law. You access the Site on your own volition and are responsible for compliance with all applicable laws with respect to your own access and use of the Site and its offerings. These Terms have been made in and will be construed and enforced in accordance with the laws of the State of New York, U.S.A. as applied to agreements entered into and completely performed in the State of New York (without effect to its conflicts of law provisions). 16. Arbitration. Subject to the right of Citywire to seek injunctive relief, disputes will be will be resolved by binding, individual arbitration under the American Arbitration Association pursuant to its Commercial Arbitration Rules or pursuant to its International Centre for Dispute Resolution (ICDR) Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having competent jurisdiction thereof. There is no judge or jury in arbitration, and court review of an arbitration award is limited. For any arbitration, the arbitrator(s) selected shall have a minimum of ten years of experience with and knowledge of the subject matter of the claim and dispute. The place of arbitration shall be in New York, New York. The arbitrator shall be bound by the provisions of these Terms and base the award on applicable law and judicial precedent. The arbitrator may award money or equitable relief in favor of only the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim. Similarly, an arbitration award and any judgment confirming it apply only to that specific case; it cannot be used in any other case except to enforce the award itself. However, the arbitrator(s) may award to the prevailing party all of its costs and fees. “Costs and fees” mean all reasonable pre-award expenses of the arbitration, including the arbitrator’s fees, administrative fees, travel expenses, out-of-pocket expenses such as copying and telephone, court costs, witness fees, and attorneys’ fees. Upon rendering a decision, the arbitrator(s) shall state in writing the basis for the decision, including the findings of fact and conclusions of law upon which the decision is based. The decision of the arbitrator(s) shall be final and binding upon the parties, and shall not be subject to appeal. You and Citywire have agreed to execute this Agreement in the English language, and all dispute settlement proceedings and communications, written and oral, between you and Citywire shall be conducted in the English language. 17. Injunctive Relief. Notwithstanding the arbitration provision above, you acknowledge that any breach, threatened or actual, of these Terms, including, without limitation, with respect to unauthorized use of Citywire’s proprietary assets and especially, any Content, will cause irreparable injury to Citywire. Such injury would not be quantifiable in monetary damages and Citywire would not have an adequate remedy at law. You therefore agree that Citywire shall be entitled, in addition to other available remedies, to seek and be awarded an injunction or other appropriate equitable relief from a court of competent jurisdiction restraining any breach, threatened or actual, of your obligations under any provision of this Terms. Accordingly, you hereby waive any requirement that Citywire post any bond or other security in the event any injunctive or equitable relief is sought by or awarded to Citywire to enforce any provision of these Terms. 18. Waiver and Severability. Failure to insist on strict performance of any of the terms and conditions of these Terms will not operate as a waiver of any subsequent default or failure of performance. No waiver by Citywire of any right under these Terms will be deemed to be either a waiver of any other right or provision or a waiver of that same right or provision at any other time. If any part of these Terms are determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and the liability limitations set forth above, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most clearly matches the intent of the original provision and the remainder of these Terms shall continue in effect. 19. Notice; Consent to Electronic Communications: When you visit this Site or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on this Site. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. 20. Entire Agreement. You and Citywire are independent contractors. No joint venture, partnership, employment, or agency relationship exists between you and Citywire as a result of these Terms or your utilization of the Site. These Terms represents the entire agreement between you and Citywire with respect to your individual use of the Site. These Terms may not be assigned, transferred, conveyed, delegated, or granted by you to another party or person without the prior written consent of Citywire

Privacy Policy Citywire Privacy Policy Citywire Financial Publishers Limited (“Citywire”, “we”, “us”, “our”) is the operator and copyright holder of certain websites (“the websites”) including but not limited to citywire.co.uk. For a full list of websites operated by us, please follow this link. Citywire is an independent publisher of financial information and a data provider. This privacy policy (“Privacy Policy”) tells you what personal information we collect about you, how we collect it, and what we will do with it. It applies when you: Visit our websites Order services from our websites Create an account to use our websites Update your profile and other account details Subscribe to or receive our newsletter, magazines, and other marketing messages ‘Follow’, ‘like’, post to, or interact with our social media accounts, including Facebook, LinkedIn, Twitter, and YouTube Submit correspondence to us, make an enquiry, provide feedback or make a complaint by post, over the phone, by email or on our website Register for and/or attend our virtual and physical events Are a fund manager who we rate for Citywire Fund Manager Ratings Complete questionnaires or surveys Register for a magazine, subscribe to our newsletter and mailing lists Submit a CV and/or an application to a job vacancy Have a face-to-face meeting with us Otherwise interact with us This Privacy Policy also explains what rights you have to access or change your personal information. Our websites are not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 18. If you are under the age of 18, please do not access our websites at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 18. About us We are Citywire Financial Publishers Limited, a company registered in England under company number 03828440, with our registered address as set out below. You can contact us as follows: FAO: Data Protection Officer Address: Citywire Financial Publishers Limited, 3 Spring Mews, London, SE11 5AN, United Kingdom Email: privacy@citywire.co.uk Visitors to our websites Personalisation, website usage and Third-Party Analytics We collect certain information about how you use and access our websites even where you have not created a Citywire account or logged in. This might include: information about your device, operating system and IP address; your login information; your browser type and version; information about your visit, including URL, clickstream (i.e. your journey to, through and from our site), length of visits to certain pages, and page interaction information. We collect this information by, for example, using cookies and other similar technologies, and we sometimes use third party services such as Google Analytics to analyse website user activity on our behalf. Cookies are small pieces of information that are stored on your hard drive and not on our websites. While we may use cookies to track your use of our websites and services, this information does not identify you personally and you remain anonymous, even if you have previously submitted personal information to us through the websites or otherwise. You can see what cookies we are using for personalisation at any time here. Your Citywire account and profile To read some of our content and use our services we may ask you to create a Citywire account (your profile). To do this we ask you provide us with your email address (in the case of our professional websites this should be your work email address), a password, your name, job title/position, company you work for (if applicable), and other information prompted on the registration page. We ask that you provide accurate information: we may use publicly available information on the Internet to verify that your email address is valid, along with other information you provide at the time of registration. The information you provide is stored in our secure databases and is used to create, maintain, and/or add to your user profile. How we use your profile When you visit our websites we use a cookie to assign you a randomly generated unique identifier. We log your activity on our websites against this identifier in our databases. Once in our databases, this information will be added to your user profile and we use this data to provide you with access to our websites in a manner convenient and optimal to you, deliver you content and advertisements that are relevant to you and improve your user experience. Sharing Your Profile We only share your personal information with service providers and other third parties we work with to deliver our services to you. We do not share your personal information with third party advertisers, unless you have given us your consent to do so. We may share, however, an aggregated and anonymised version of this information with companies that advertise, or may advertise, on our websites. By allowing companies to advertise on our websites we are able to offer you content for free. Third-party marketing content If you are (a) a professional reader of Citywire or (b) a consumer reader who has opted in to receive third party marketing about our selected partners, we may send marketing emails to you on behalf of asset managers and other financial institutions containing their relevant marketing and advertising messages. We never pass your details to them directly, but may use trusted third-party data processing companies to send such marketing emails on our behalf or to manage our email suppression lists. We ensure that they handle your data securely and delete it from their systems when no longer needed for the purpose we have shared it with them. For more information on our third-party data processing companies, please see section titled “Sharing and disclosing your information” below or email privacy@citywire.co.uk. You may unsubscribe from emails relating to our selected partners at any time in the ‘My Account’ section of the websites, by using the embedded links set out in the emails or by replying to the relevant emails you receive from us. Do Not Track In compliance with California AB370, effective January 1, 2014, Citywire’s practices in responding to “do not track” signals and collecting user information over time and across a network of websites when you visit our websites are as follows: We do not honor the request of “do not track” signals sent by your browser when you visit the Site. Additionally, we may collect user information about your online activities over time and across different websites, or authorise third parties to do so. Citywire Emails and Marketing We will send you our daily newsletters and emails about our news, events, new website features or services that we believe may interest you if you are (a) a professional account holder or (b) a consumer account holder and you have opted-in to receive our daily newsletters and such other Citywire marketing messages. You can opt out of receiving such messages at any time in the ‘My Account’ section of the websites, by using the embedded links set out in our emails or by replying to the relevant emails you receive from us. You can also use the ‘My Account’ section to choose to subscribe to any of our other more specific news emails that you want to receive. If you are a professional reader of our websites, we may use the information you have provided us with, along with the information we have collected from your website activities, to subscribe you to email newsletters that we feel would be relevant to you. You can opt out of these in the same way as all other newsletters. If, as a consumer reader of our websites, you opt in to receive direct marketing from us we will send you carefully selected emails marketing our events and other products. These will never be excessive or irrelevant to you and you can opt out of receiving them at any time via the ‘My Account’ section of the website, by using the embedded links set out in our emails, by replying to the relevant emails you receive from us, or by emailing privacy@citywire.co.uk. As part of our marketing efforts, we may also match personal information that you provide to us directly with other information about you obtained from or held by third party sources (such as social media platforms). We may use this personal information to inform our marketing strategy and to tailor and show advertisements more relevant to you. Social media interactions We will use your personal information to interact with you on social media platforms including Facebook, LinkedIn, Twitter, and YouTube, for example, to respond to comments and messages, post, ‘retweet’ and ‘like’ posts. When you interact with us on social media platforms, we may collect information you share with us on such platforms and also keep records of our interactions. User and customer support We will use your personal information to provide customer service and support, deal with enquiries or complaints about our websites and services, and to manage our relationship with you, which will include notifying you about changes to our website terms and conditions or this Privacy Policy. We may also share your information with our third-party service providers as necessary to provide such customer support. If you contact us with a complaint or query, we may keep a record of any phone number/email address used to call/email our customer service team as well as the correspondence and the period of time it took for us to deal with a query or any request you had. We may also record your levels of satisfaction with the services we have provided. We will also collect any information contained in any other correspondence between us. Events registration and participation This section is applicable to both virtual and physical events, unless we explicitly refer to one of them. If you sign up to attend one of our events we will ask you to provide your personal and professional details, such as your name, surname, title, job title/position, company you work for (if applicable) as well as your contact details. This is so we can assess your suitability to attend our event, contact you to let you know if you meet our criteria, and share with you all logistical information. If you register for one of our events we will use this information internally for liaising with you and ensuring that you are added to appropriate workshops and seminars at the event. If you are coming to one of our physical events we may ask you for further information such as your dietary requirements, passport details and any special needs or requirements in accordance with the Discrimination Act 2010. This information (in particular so-called “special categories” of particularly sensitive personal information such as, for example, information about your race or ethnicity, or your health and genetic data) will be treated with the utmost respect and will only be used for logistical purposes to make sure you have a comfortable and enjoyable experience at our event. We have in place appropriate safeguards which we are required by law to maintain when processing such data. We process special categories of personal information only with your explicit consent, where it is needed for reasons of substantial public interest for equal opportunities monitoring, or where we need it to carry out our legal obligations. Sharing your event information We may pass some of the information we collect at registration to our event sponsors so that they know who will be attending the event. We will always let you know in advance about the identity of such event sponsors. They may contact you after the event for feedback via call or email and send you marketing via email. We are not responsible for their privacy practices and their interactions with you – it is up to you whether you remain in contact with them. We may share your job title and company name with potential sponsors so they know the calibre of people that attend our events. Surveys at events At the events we may ask you to complete surveys. At physical events we conduct surveys via electronic tablets or on paper. These may be used to gain feedback on our events or allow us to find out more about the type of funds or assets you have under management (if relevant). Some may give you a chance to tell us about your organisation and if you think there is anyone else there that would like to attend one of our future events. This information is added to your user profile and aids us in continuing to offer you relevant content and to invite you to future events. We also sometimes run surveys at our events on behalf of the event sponsors. If this is the case, we will check that you are happy to share your answers and other personal data with the relevant sponsor. For more information about how we use and share survey data, please see the section titled “Questionnaires and Surveys” below. Recording at our events There will be a photographer and/or videographer at our events. If you are filmed, photographed, and/or recorded as part of any of our events, your image or likeness may be used for future event show guides, in promotional material, sponsor and media partner coverage in print, online or social media channels. Questionnaires and Surveys At Citywire we value your opinion and we often run surveys and questionnaires in person, via email or telephone. These are primarily conducted for our own purposes such as to allow us to study how our websites and services are used and to stay engaged with our audience, but are also sometimes conducted by us on behalf of third parties. When they are carried out on behalf of third parties we will always state that this is the case at the beginning of the survey, inform you about the identity of the third party and give you the right to object to our sharing of your personal data (such as name and email address) with such third parties. In certain circumstances we may also share anonymised and aggregated survey data with such third parties to protect your privacy. When we conduct the surveys for our own purposes, the answers you give may be aggregated and anonymised and used for both internal and external presentations and news stories. Survey information will also be stored in our database and added to your user profile. Magazine registration In order to send you a hard copy of one of our magazines we ask you to provide us with your contact details such as your name and postal address. This is shared with our printers, courier services, and other service providers for logistical purposes but we never share it with any other companies for marketing purposes. The address will be added to your user profile in our database and may be used for geographical profiling. As with our other communications, you can always opt out of receiving our magazines and other materials via post. You can do so by sending an email to us at privacy@citywire.co.uk. Face to face meetings At Citywire we like to engage with our audience and we will sometimes request the chance to meet you and ask you questions. We will usually record and then transcribe any meeting that we have with you. Any opinions that you express will be stored in our database and will be linked to your user profile. Please also note that if you visit our offices, your image and voice may be captured by our CCTV cameras which we use for security purposes. Citywire Fund Manager Ratings Citywire operate a ratings system based on the performance of fund managers. As part of this, if you are an active fund manager, you may be contacted by Citywire staff for your photograph, a short biography, date of birth, career history and any other relevant information. They will ask you if you are happy for us to use and publish this information as part of your manager profile. If you agree, then this information will be added to our database and published online. We will regularly check in with you that this information is up to date and that you are happy with our continued publication of it. Recruitment If you submit a CV or job application to Citywire, whether directly or via an agent or recruiter, you may share with us additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work, your national security number, your passport or other identity document details, and any other such similar information. We will collect and use this information to process your job application and we may contact your recruiter, current and former employers and/or referees to obtain further information about you and your application. Compliance with policies, procedures, and laws We may collect and use your personal information to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud as well as to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees. Legal basis for using your personal information We will only use and otherwise process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we collect and use your personal information. In almost every case the legal basis will be one of the following: consent: for example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you; our legitimate business interests: where it is necessary for us to understand our readers, promote our services, and operate a safe and lawful business, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this legal basis when we conduct certain market analysis to understand our readers in sufficient detail so we can improve our services; performance of a contract with you (or in order to take steps prior to entering into a contract with you): for example, where you have asked us to provide one of our services to you and we need to use your contact details and financial information in order to deliver this service; or compliance with law: where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation. Sharing and disclosing your information In connection with the purposes described above, we will share your personal information when relevant with third parties such as: our suppliers, business partners and service providers we work with to deliver our services to you and to market and advertise our services; any selected third parties and sponsors that you consent to our sharing your information with; our corporate affiliates and other members of our group of companies; regulators and governmental bodies and other authorities who require reporting of processing activities in certain circumstances; prospective sellers and buyers of our business or assets, only in the event that we decide to sell or buy any business or assets; and other third parties, including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law. Where we do share your information with third parties, we will require such third parties to comply with this Privacy Policy and maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts). Data transfers Citywire is a global business with offices in London, Munich, Singapore, Milan and New York. We have EU approved Model Contract Clauses in place between all of our entities so you have adequate protection if your data is transferred to a country which has not been assessed by the European Commission as having adequate legal protection. As many of our external third parties are based outside the European Economic Area (EEA), their processing of your personal information will involve a transfer of data outside the EEA, including to countries which have less strict, or no data protection laws, when compared to those in the European Union. Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy Policy. In these cases, we rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses”) to ensure your information is subject to adequate safeguards in the recipient country. Please contact us using the contact details at the top of this Privacy Policy if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. Our security and retention of your information We want our users and members to feel confident using our services and are committed to protecting the information that we collect by using appropriate technological and operational security measures. For example, information transmitted to us over the internet is secured using Secure Socket Layer (SSL) technology and industry standard firewalls. We also ensure information once received is stored securely and only accessible with the correct authorisation. We retain your information only for as long as is necessary to provide you with the services that you have requested from us, for as long as we reasonably require to retain the information for our lawful business purposes, or where we are legally permitted to do so. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. Data Protection Officer Citywire’s data protection officer’s details and credentials are below: Data Protection Officer Citywire Financial Publishers Limited 87 Vauxhall Walk Vauxhall SE11 5HJ United Kingdom +44 207 840 2461 privacy@citywire.co.uk Your rights to your personal data You have certain rights in respect of the information that we hold about you, including: the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Policy; the right to ask us not to process your personal data for marketing purposes; the right to request access to the information that we hold about you; the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect; the right to withdraw your consent for our use of your information in reliance of your consent, which you can do by contacting us using any of the details at the top of this Privacy Policy; the right to object to our using your information on the basis of our legitimate interests or those of a third party, and there is something about your particular situation which makes you want to object to processing on this ground; the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances; in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence. If you have any concerns about the way we have processed your personal information, we request that you initially contact us (using the contact details above) so that we can investigate, and hopefully resolve, your concerns. Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing communications. How to exercise your rights If you wish to exercise your ‘Right to Access’, ‘Right to be Forgotten’, or any other right under the General Data Protection Regulation, then please get in touch with us at privacy@citywire.co.uk or call +44 207 840 2250. You can also write to us - Data Protection Officer Citywire Financial Publishers Limited 3 Spring Mews London SE11 5AN United Kingdom We will comply with your requests unless we have a lawful reason not to do so. What we need from you to process your requests We may need to request specific information from you to help us confirm your identity and to enable you to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Third-party links and websites Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Changes to this Privacy Policy and your duty to inform us of changes We may make changes to this Privacy Policy from time to time. We will post any changes to our site, or notify you of any material changes by e-mail. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Policy. This Privacy Policy was last updated on 22nd September 2020.

Cookies We use cookies to help authenticate and personalise your use of our site, however, if you wish to restrict the cookies set by Citywire or any third party sites, you can disable cookies in your internet browser. Your browser help function should let you know how, but keep in mind that restricting a If you need further information on cookies, their use and how to manage them, please visit http://www.aboutcookies.org which provides comprehensive information about cookies. Citywire uses a number of third party suppliers for functionality including tracking information, advertising (including based on geo-location) and media which may also set cookies from the Citywire website. More information about all these cookies and those set by Citywire are described below. Citywire cookies Authentication CWAuth04 & CWAuth05 & CWS & CWS02This encrypted cookies can be used to determine whether a user has signed into Citywire Accounts network and has been authenticated. 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Advertising/Targeting Cookies Our site sponsors will use cookies for reasons such as limiting the amount of times you see a certain advertisement, make the advertising more relevant to you and to collect performance metrics such as clicks on the advertisement and how many times it has been seen. Third party cookies are set by outside organisations. Citywire does not control the use of third party cookies and cannot access them. The third party organisations that place cookies, including your browser (such as Google) and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies. Citywire strongly advises to check the third party websites for more information about these cookies. We do not accept any responsibility or liability for third party policies. Further information on these cookies can be found below, on their own websites DCM (Doubleclick) Sizmek Flashtalking Integral Ad Science Smartology Adform MOAT Vzaar Ceros Teads SurveyGizmo Issuu Soundcloud How do I change my cookie settings? Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org. Find out how to manage cookies on popular browsers: Google Chrome Microsoft Edge Mozilla Firefox Microsoft Internet Explorer Opera Apple Safari To find information relating to other browsers, visit the browser developer's website. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. This Cookie Policy was last updated on 1st of October 2019