Terms & Conditions of Use

This website (the “Website”) is provided by Agilis Investment Management LLP (the “Firm” and hereinafter also referred to as “we” or “our”), a firm authorised and regulated by the UK Financial Conduct Authority (“FCA”) and which appears in the FCA register under Reference Number 759159. The Firm is registered as a limited liability partnership under Company number OC412048 with its registered office at 20 Eastbourne Terrace, London W2 6LG, United Kingdom.

By accessing or using this Website, you accept and agree to comply with these Terms and Conditions of Use ("Terms") and have read and accepted the terms of our Privacy Policy. These Terms are a binding agreement between you and the Firm, and govern your access and use of this Website, which includes any text, graphics, user interfaces, information, data, tools, products, services and other content (collectively, the "Content") available on or through this Website.  You may contact the Firm by e-mail at clientservices@agilisim.com with any questions about these Terms.

 

1. Use of this Website

The Firm grants you a limited right to use this Website. Your right to use this Website is subject to your agreement to abide by these Terms in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of this Website. We may revoke your right to use all or any portion of this Website at any time and for any reason. You may not violate or attempt to violate the security of this Website.

If for any reason any part of these Terms is deemed to be unenforceable then the validity of the remaining terms shall not be affected. All disclaimers, terms, conditions as set out in this Website shall form part of these Terms.

 

2. Intended Recipients

This Website is not directed at, or intended for use by, any person in any jurisdiction or country where such communication or use would be contrary to local law or regulation.  

In the United Kingdom, this Website is directed only at persons who are: (i) investment professionals within the meaning of Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, as amended ("FP Order"); (ii) high net worth companies and certain other entities falling within Article 49 of the FP Order; (iii) capable of being categorised as professional clients meeting the criteria laid down in Annex II of the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”); or (iv) any other persons to whom such communication may lawfully be made. It must not be used, or relied upon, by any other persons.

The Website is not intended for the account of U.S. persons (as defined in Regulation S under the United States Securities Act of 1933, as amended (the "Securities Act")) other than persons who are "qualified purchasers" (as defined in the United States Investment Company Act of 1940, as amended) and/or "accredited investors" (as defined in Rule 501(a) under the Securities Act).

 

3. No Offer or Solicitation

This Website is not intended and must not be construed as an offer or solicitation to purchase, or an offer to sell, shares of any fund or another investment product mentioned on this Website (“Investment”) in any jurisdiction. In particular, this Website is not intended as marketing of any alternative investment fund in any member state of the European Economic Area (“EEA”) for the purposes of the EU Directive 2011/61/EU on Alternative Investment Fund Managers, as amended and implemented in the EEA.

Any offer of Investment will only be made on the basis of the prospectus or offering memorandum relating to the relevant Investment. PROSPECTIVE INVESTORS SHOULD REVIEW THE PROSPECTUS OR OFFERING MEMORANDUM, INCLUDING THE RISK FACTORS, BEFORE MAKING A DECISION TO INVEST.  Prospective investors should rely only on the prospectus or offering memorandum in making a decision to invest, even if certain descriptions contained on this Website may be more detailed than those contained in the relevant prospectus or offering memorandum. Subscriptions may only be made on the terms of the relevant prospectus or offering memorandum and subject to completion of a subscription agreement. In addition, any Investment or transaction will be subject to applicable legal and regulatory restrictions, including the prospective investor meeting applicable eligibility criteria.

 

4. Nature of the Content

The Content is intended only for information purposes and convenient reference and is not intended to be complete.  It is not intended to provide, and should not be relied upon, for investment, accounting, legal or tax advice.  You should consult your own financial, tax, legal, accounting or other advisors about the issues discussed on this Website. The Content may not be suitable for all investors.   

Users of this Website should be aware that the Firm is not acting for, or advising them, and is not responsible for providing them with the protections available under the UK regulatory system. Compensation will not be available from the UK’s Financial Services Compensation Scheme.

Although the Content is believed to be correct and accurate at the time of publication, the Firm makes no representation or warranty as to the accuracy or completeness of any such information or content.  Any analysis contained on this Website is based upon a number of assumptions. Changes in such assumptions could produce materially different results. The Content is not intended to forecast or predict future events. All opinions, projections and estimates constitute the judgment of the author as of the date on which this Website was last updated. The Firm assumes no duty or responsibility to update this Website, and any views, forecasts, estimates or opinions expressed on this Website may change without notice.

 

5. Certain Risks

Investing entails certain risks, including the possible loss of the entire capital invested. The Investments and services of the Firm may entail substantial risks and may not be suitable for certain or all investors. An Investment may expose you to a significant risk of losing all of the property or other assets invested. Some, but not all, of these risks will be contained in the relevant prospectus or offering memorandum. Potential investors should familiarise themselves with these risks and obtain advice from their own financial, accounting, legal, tax and other advisors and only make investment decisions based on the investor’s own objectives, experience and resources. 

 

6. Limitations of Liability

The Firm assumes no responsibility or liability for the correctness, accuracy, timeliness or completeness of the Content, for any viruses contained in, or attached to, this Website or for any loss, damage or lost opportunities resulting from the use of the Content. 

To the maximum extent permitted by applicable law or regulatory requirements, neither the Firm nor any of its affiliates, members, directors, employees or other representatives shall be liable for any errors, inaccuracies or omissions on this Website or for any loss or damage resulting from its use, whether caused by negligence or otherwise. This limitation of liability includes any damages, losses, costs, claims, liabilities or expenses arising out of or in connection with the use of this Website howsoever arising (whether under contract, tort, statute or otherwise arising). This limitation of liability shall apply to all damages, losses, costs, claims, liabilities and expenses of any kind whether direct or indirect and consequential, including (but without limitation) any  indirect, special, indirect or consequential damages arising out of or in connection with the access of, use of, performance of, browsing in or linking to other sites from the Website, legal costs or expenses, direct loss of profit, direct loss of anticipated savings, loss of data, indirect loss of profit, indirect loss of anticipated savings, loss of revenue, loss of business, loss of use of money, loss of opportunity or loss of or damage to property and/or any wasted expenditure and third-party claims.

 

7.  Indemnification

As a condition of your use of this Website, you agree to indemnify and hold the Firm harmless from and against any and all claims, losses, liability, costs and expenses (including but not limited to legal fees) arising from your use of this Website, or from your violation of these Terms.

 

8. Third Party Websites

Any links to third-party websites are provided solely for your convenience and do not constitute any endorsement, partnership, joint-venture, sponsorship or approval of the materials appearing in such sites. The Firm accepts no responsibility for the content of such third-party websites.

 

9. Intellectual Property and Copyright

The entire content of this Website is subject to copyright and intellectual property rights of the Firm with all rights reserved. The Content may not be redistributed in whole or in part, stored in a retrieval system, modified, linked into, republished, uploaded, transmitted in any form or by any means electronic or mechanical, or by photocopying, recording or otherwise without the express prior written permission of the Firm. 

The names, logos, or identifying marks relating to the products and services of the Firm are proprietary trademarks/ service marks and may not be used in any way without express prior written consent of the Firm. If you download or print out a hard copy of individual pages and/or sections of the Website, you may not remove any copyright or other proprietary notices.

 

10. Amendments to these Terms

We may update and modify these Terms from time to time.  Such modifications shall be effective immediately upon posting to this Website. You should review this page from time to time to take notice of any modifications we make.

 

11. Law and Jurisdiction

These Terms and any and all disputes or claims arising out of or in connection with them (whether contractual or non-contractual) shall be governed by and shall be construed in accordance with English law. All disputes arising out of or in connection with these Terms (whether contractual or non-contractual) shall be subject to the exclusive jurisdiction of the English courts. A condition of using this Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.

Definition of Professional Client in the UK

(1) An entity required to be authorised or regulated to operate in the financial markets. The following list includes all authorised entities carrying out the characteristic activities of the entities mentioned, whether authorised by an EEA State or a third country and whether or not authorised by reference to a directive:

(a)  a credit institution;

(b) an investment firm;

(c) any other authorised or regulated financial institution;

(d) an insurance company;

(e) a collective investment scheme or the management company of such a scheme;

(f) a pension fund or the management company of a pension fund;

(g) a commodity or commodity derivatives dealer;

(h) a local;

(i) any other institutional investor;

(2) In relation to MiFID or equivalent third country business a large undertaking meeting two of the following size requirements on a company basis:

(a) balance sheet total of EUR 20,000,000;

(b) net turnover of EUR 40,000,000;

(c) own funds of EUR 2,000,000;

(3) In relation to business that is not MiFID or equivalent third country business a large undertaking meeting any of the following conditions:

(a) a body corporate (including a limited liability partnership) which has (or any of whose holding companies or subsidiaries has) (or has had at any time during the previous two years) called up share capital or net assets of at least £5 million (or its equivalent in any other currency at the relevant time);

(b) an undertaking that meets (or any of whose holding companies or subsidiaries meets) two of the following tests:

(i) a balance sheet total of EUR 12,500,000;

(ii) a net turnover of EUR 25,000,000;

(iii) an average number of employees during the year of 250;

(c) a partnership or unincorporated association which has (or has had at any time during the previous two years) net assets of at least £5 million (or its equivalent in any other currency at the relevant time) and calculated in the case of a limited partnership without deducting loans owing to any of the partners;

(d) a trustee of a trust (other than an occupational pension scheme, SSAS, personal pension scheme or stakeholder pension scheme) which has (or has had at any time during the previous two years) assets of at least £10 million (or its equivalent in any other currency at the relevant time) calculated by aggregating the value of the cash and designated investments forming part of the trust's assets, but before deducting its liabilities; (e) a trustee of an occupational pension scheme or SSAS, or a trustee or operator of a personal pension scheme or stakeholder pension scheme where the scheme has (or has had at any time during the previous two years):

(i) at least 50 members; and

(ii) assets under management of at least £10 million (or its equivalent in any other currency at the relevant time);

(4) A national or regional government, including a public body that manages public debt at national or regional level, a central bank, an international or supranational institution (such as the World Bank, the IMF, the ECP, the EIB) or another similar international organisation; and

(5) Another institutional investor whose main activity is to invest in financial instruments (in relation to the firm's MiFID or equivalent third country business) or designated investments (in relation to the firm's other business). This includes entities dedicated to the securitisation of assets or other financing transactions.

Stewardship Disclosure

Agilis Investment Management LLP (the “Firm”) supports the principles enshrined in the Financial Reporting Council's Stewardship Code which sets out good practice for investor engagement. The FCA requires all authorised asset managers to publicly disclose either a statement of compliance with the Stewardship Code or where they do not commit, their alternative investment strategy.

The Financial Conduct Authority and the Financial Reporting Council have acknowledged that certain aspects of the Stewardship Code are not directly relevant to all managers. The Firm’s investment strategy involves making global investments in a variety of asset classes and jurisdictions. The Firm will rely on publicly disseminated data to inform our investment decisions.Consequently, compliance with the Stewardship Code is not relevant to the Firm because there is no interaction with the management of companies with respect to assets managed or advised by the Firm.

The Firm will continue to review the Code's applicability. 

Pillar 3 and Remuneration Disclosure - 31 March 2018

Agilis Investment Management LLP (the “Firm”) is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is a UK domiciled discretionary investment manager to professional clients and unregulated collective investment schemes. The Firm is a full scope Alternative Investment Fund Manager ("AIFM") and categorised as a collective portfolio management investment firm by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s Pillar 3 disclosure fulfils the Firm’s obligation to disclose to market participants’ key pieces of information on a firm’s capital, risk exposures and risk assessment processes.

We are permitted to omit required disclosures if we believe that the information is immaterial such that omission would be unlikely to change or influence the decision of a reader relying on that information. In addition, we may omit required disclosures where we believe that the information is regarded as proprietary or confidential. In our view, proprietary information is that which, if it were shared, would undermine our competitive position. Information is considered to be confidential where there are obligations binding us to confidentiality with our customers, suppliers and counterparties.

 

Risk Management

The Firm's Partners determine its business strategy and the level of risk acceptable to the Firm. In conjunction with the Chief Operating Officer they have designed and implemented a risk management framework that recognises the risks that the business faces and how those risks may be monitored and mitigated and assess on an ongoing basis. The Firm has in place controls and procedures necessary to manage those risks.

The Firm considers the following as key risks to its business:

Business risk – This risk represents a fall in assets under management or the loss of key staff which may reduce the fee income earned by the Firm and hinder its ability to finance its operations and reimburse its expenses. Business risks are assessed and mitigated as part of the Internal Capital Adequacy Assessment Process (”ICAAP”).

Market risk - The risk is the exposure to foreign exchange fluctuations due to investment management and performance fees being denominated in currencies other than sterling. The Firm operates currency bank accounts permitting it to receive/pay currency directly.

Operational risk – This risk covers a range of operational exposures from the risk of the loss of the key personnel to the risk of the provision of investment advice. Legal and reputational risks are also included within the category of operational risk. Operational risks and how they can be mitigated are assessed as part of the ICAAP.

Credit risk – This risk relates to the exposure to the Funds for non-payment of management and performance fees and counterparty exposure relating to the Firm’s bank balances and any other debtors. This is monitored by the Firm’s Chief Financial Officer and the Chief Operating Officer.

 

Regulatory Capital

The Firm is a Limited Liability Partnership and its capital arrangements are established in its Partnership deed. Its capital contains only members’ capital contributions.

The Firm is small with a simple operational infrastructure. Its market risk is limited to foreign exchange risk on its accounts receivable in foreign currency, and credit risk from management and performance fees receivable from the funds under its management.

Pillar 1 capital is the higher of:

1. the base capital requirement of €125,000;
2. the sum of market and credit risk requirements; and 3. the Fixed Overhead Requirement (“FOR”).

In addition, the Firm, on account of its classification as a full-scope AIFM, is subject to a parallel "own funds" requirement as follows:

The higher of:

1. the funds under management requirement, subject to a minimum of €125,000; and

2. the own funds based on fixed overheads requirement;

Plus whichever is applicable of:

a. the professional negligence capital requirement; or

b. the PII capital requirement.

Although the foregoing “own funds” requirement is not a component of the “Three Pillars” regime, it is likely that the Firm’s “own funds” requirement will exceed its Pillar 1 requirement.

Pillar 2 capital is calculated by the Firm as representing any additional capital to be maintained against any risks not adequately covered under the requirement in Pillar 1 as part of its ICAAP. When making this calculation, the Firm also takes into account the own funds requirement detailed above, in particular where the own funds exceeds Pillar 1 capital (and the extent to which the Firm is able to use capital instruments to fulfill both requirements).

It is the Firm’s experience that its Pillar 1 capital requirement normally consists of the FOR, although market and credit risks are reviewed monthly. The Firm applies a standardised approach to credit risk, applying 8% to the Firm risk weighted exposure amounts, consisting mainly of investment management and performance fees due but not paid, and bank balances. Having performed the ICAAP, the Firm has concluded that no additional capital is required in excess of its Pillar 1 capital requirement.

As at the date of this disclosure the Firm’s regulatory capital position is:

Capital Item £'000
Tier 1 Capital 274
Total capital resources, net of deductions 163

The Firm’s ICAAP assesses the adequacy of its internal capital to support current and future activities. This process includes an assessment of the specific risks to the Firm, the internal controls in place to mitigate those risks and an assessment of whether additional capital mitigates those risks. The Firm also considers a wind down scenario to assess the capital required to cease regulated activities.

We have not identified credit risk exposure classes or the minimum capital requirements for market risk as we believe that they are immaterial. Concerning Pillar 1, it is the Firm’s experience that the Fixed Overhead Requirement establishes its capital requirements, and that market and credit risks are considered not to be material. Furthermore, the market and credit risks component excludes such risks related to the management of alternative investment funds. Our capital requirements are currently £693,000 (the higher of the minimum capital calculated in accordance with either ‘Pillar 1’ or ‘own funds’) which is well within the level of regulatory capital held.

We consider this amount to be sufficient regulatory capital to support the business and have not identified any areas which give rise to a requirement to hold additional risk based capital.

The Firm’s ICAAP is formally reviewed by the Partners annually, but will be revised should there be any material changes to the Firm’s business or risk profile.

 

Remuneration

Given the nature and small size of our business, remuneration for all employees is set by the Managing Partner of the Firm. The Firm formally reviews the performance of all employees and based thereon determines each employees overall level of remuneration and the split of that between base salary, bonus, etc. in compliance with the FCA Rules on remuneration.

Given that the Firm has only one business area, investment management, all remuneration disclosed is from this singular business area.

The Firm has defined “Code Staff” to be the Firm’s current FCA approved persons. The aggregate level of remuneration earned by the staff is disclosed in our audited financial statements.

There is also a requirement for a remuneration statement to form part of the annual report of any Alternative Investment Fund ("AIF") to which the Firm acts as AIFM and which is either domiciled in the European Economic Area ("EEA") or marketed in the EEA.

The Firm is subject to the AIFMD Remuneration Code ("the Code"), has applied proportionality and, pursuant to this application and where relevant, has disapplied various provisions of the Code. 

Research Costs

With the implementation of MiFID II in January 2018, Agilis Investment Management LLP (the “Firm”) is subject to a number of requirements with respect to receiving and using third party research for the benefit of its clients.

The Firm has committed to bearing the full cost of research and these expenses will not be passed on to our clients.

Privacy Policy

Agilis Investment Management LLP (the “Firm” and hereinafter also referred to as “we” or “our”) has developed a privacy policy to help ensure your personal information remains private at all times. Below, we have answered the key questions about our privacy policy so that you can understand how we collect, use and protect your personal information.

1. How do we collect information about you? How can you contact us?

We may collect personal information about you through:

(i) your completion of registration or subscription forms or as otherwise provided by you through this Website;

(ii) information you provide relating to your transactions with the Firm or its clients;

(iii) the use of Internet “cookies” (an information collecting device from a web server) to collect information about your visits to this Website as described further below; or

(iv) recording and monitoring of telephone conversations and electronic communications with you as described further below.

We control the personal data we collect from you in the above mentioned cases (“data controller”). You may contact us at clientservices@agilisim.com for any questions or requests with regards to the personal data we hold about you.

 

2. Why does the Firm collect information about you?

We may use such personal information for the purposes of administering the relationship between us, marketing of products and services, monitoring and analysing our activities, and complying with any legal or regulatory requirements. The Firm will use one of the permitted grounds under GDPR to collect your information. Such rights include circumstances where you have given your consent and instances where your consent is not required, such as where we are required to comply with a legal obligation, or where we or a third-party has a legitimate interest to collect personal information.

 

3. What are the Firm’s or a third-party’s legitimate interests to collect information about you?

The Firm or a third-party’s legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third-party have determined that there is a reasonable expectation for us or a third-party to collect or use your personal information for such purpose.

 

4. Does the Firm obtain personal information from third-parties or publicly accessible sources?

The Firm may, in some circumstances, ask third-parties (such as its service providers) to provide it with information on any prospective or existing clients. This could involve the services of a credit reference agency, the use of consultants or other third-parties acting as our agents in order to help us identify a client or prospective client or to confirm your contact details. Personal information may also be obtained from publicly available or accessible sources of information, such as investor databases, industry associations, networking services or online professional networks.

 

5. Does the Firm share your personal information with any third-parties?

Yes, we may in certain circumstances, share your information with third-parties, such as:

  • Regulators, courts of law, governmental or law enforcement agencies, including the police whererequired, requested by or permitted to do so, or in connection with legal proceedings
  • Our website internet service provider where required
  • Any person if we determine it is necessary or desirable to comply with any law or to protect or defend our rights or property
  • Our service providers or those of the funds or accounts we manage
  • Any other party that you inform us about
  • Our affiliates or other entities that are part of our group
  • Any person to whom we have a right or duty to disclose personal data. For example, if we are required to provide certain transaction information to authorities or other official bodies to assist in the prevention of terrorism, money laundering and other crimes
  • Credit reference agencies or other third-parties acting as our agents in order to help us identify a client or confirm your contact details
  • Consultants such as for marketing analysis purposes
  • A third-party to whom we transfer any of our rights or obligations under any agreement, or who acquires an interest in any of the Firm’s assets, or in connection with a sale of its shares or the merger or consolidation or other transfer of the assets of the Firm, whether voluntarily or by operation of law, to such third-party, or who is otherwise deemed to be a successor or transferee
  • Any other person we reasonably think needs access to the data.

 

6. Does the Firm transfer personal information to countries outside of the European Economic Area (EEA)?

Because of the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by GDPR. In these circumstances, we will strive to ensure the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of GDPR, such as by requesting appropriate contractual undertakings in our legal agreements with service providers. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted through this Website. Any transmission of data is at your own risk.

 

7. For how long does the Firm retain personal information?

We will generally not retain information about you for longer than is necessary in relation to the purpose for which your data was collected. The applicable retention period may depend on various criteria, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right under GDPR to request the deletion of your information from our system. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five to seven years after the termination of any such relationship. From time to time, we will review the purpose for which we have collected information about you and decide whether to retain it, update it or securely delete if it no longer serves any purpose to us.

 

8. What are your rights under GDPR?

You have certain rights in respect of the personal data we hold about you and which you may exercise in accordance with GDPR. These rights are, generally:

  • the right to request access to your information
  • the right to request rectification of your information
  • the right to request erasure of your information
  • the right to restrict the processing or use of your information
  • the right to object to the processing or use of your information
  • where relevant, the right to request the portability of your information
  • where relevant, the right to withdraw your consent at any time
  • the right to lodge a complaint with a competent supervisory authority.

 

9. Is the provision of your personal information part of a statutory or contractual requirement or obligation? What are the possible consequences of failing to provide your personal information?

Information about you may be required to satisfy a statutory obligation or contractual requirement. As an FCA authorised and regulated entity, we are subject to legal and regulatory requirements that require us to collect your personal information, such as to comply with the law on anti-money laundering and terrorist financing or for compliance with the rules on the recording and monitoring of telephone conversations and electronic communications referred to below. Should the Firm decide to provide you with any service, you will also be required to provide us with personal information for the purpose of any contractual arrangements or transactions between us. A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other undertaking between us, or, where there is a suspicion of illegal activity, a reporting you to a regulatory or enforcement agency for investigation.

 

10. Does the Firm process your personal information using automated-decision making processes?

No.


[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Cookies Policy

Agilis Investment Management LLP (the “Firm” and hereinafter also referred to as “we” or “our”) may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this Website and to monitor use of this Website. You may set your browser to notify you when you receive a cookie. Many web browsers allow you to block cookies. If you do block cookies you may not be able to access certain parts of this Website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

You may have certain rights under applicable data protection laws which may include the right for you to receive a copy of the personal information we hold about you. For a copy of your personal information please write to us at the address provided below. We may charge you a nominal fee for complying with such a request in accordance with applicable law. In addition, you may have a right to request personal data provided on this Website is corrected, blocked or deleted if the data is factually incorrect, incomplete or irrelevant for the purposes described in these terms and conditions.

If you have any questions about the use of personal information, please contact us at clientservices@agilisim.com.

Telephone Conversation and Electronic Communications Recording and Monitoring

The Firm may record and monitor telephone conversations and electronic communications with you for the

purposes of:

(1) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;

(2) ensuring compliance with our regulatory obligations; and/or

(3) detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of five to seven years, or such other longer period as may be determined by the Firm.