PLEASE READ THE FOLLOWING IMPORTANT INFORMATION:

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This website is not directed at you if Blackfriars Asset Management Limited (“Blackfriars”) is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use which would be contrary to local law or regulation. This website and its contents are not intended to sell services or products over the Internet but for Internet viewers' convenience and information.

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The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorised. In particular, the information herein is not for distribution. It does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States of America or to or for the benefit of any US Person as such term is defined under the United States Securities Act of 1933, as amended.

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The information displayed on this website contains material that may be interpreted by the relevant authorities in the country from where you are viewing the website as investment advertising or an offer to purchase securities. Accordingly, the information on this website is only intended to be viewed by persons who fall outside the scope of any law that seeks to regulate investment advertising in the country of your residence or in the country where the website is being viewed. Users of this website are therefore assumed to have the knowledge and experience in business and financial matters to enable them to evaluate the merits of, and risks of, any of the activities referred to in this website. Persons of any other description should not enter this website or rely on any information contained therein. If you are uncertain about your position under the laws of the country in which the website is being viewed, then you should seek clarification by obtaining legal advice from a lawyer practising in the country of your residence or in the country in which the website is being viewed before completing this question.

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1. Risk warnings

Blackfriars does not offer any services to retail clients. 

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Investments may fall and rise, and investors may lose a substantial portion or even all of their investment. Past performance is not necessarily a guide to future performance.

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Investments denominated in foreign currencies can result in the risk of loss from currency movements and movements in the value, price or income derived from the investments themselves.

Investment in emerging markets involves risks which may not be typically associated with investing in more developed markets.

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To the extent permitted by relevant law and regulation, Blackfriars expressly disclaims any and all liability which may derive from this website or any other information provided by Blackfriars in connection with this website and any errors therein or omissions therefrom.

The description of the services provided by Blackfriars on this website is written in general terms. The services referenced within this website should not be regarded as an offer nor solicitation for such services in any jurisdiction where such offer or solicitation is unlawful. 

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This website is based upon information that is considered to be reliable, but Blackfriars does not represent or warrant that it is accurate or complete, nor should it be relied upon as such.

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All risk controls mentioned define a company axiom and consensus. They stand as investment guidelines and not as investment rules. Occasional deviation from the parameters given may result.

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2. Use of Links
The Blackfriars website may contain hyperlinks to websites operated by third parties. Blackfriars does not control the content or accuracy of information on such websites and does not otherwise endorse the material placed on such sites. The hyperlinks are provided for your reference only. Blackfriars will incur no liability for any content, service, product or material offered through any linked site. You access any third-party linked websites at your own risk.

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3. Copyright
The copyright and all other rights in this website's material are owned by the company listed on the web page, or the material is included with the rights owner's permission. You may review and copy material on this website for your own private or domestic use only. All other copying or use is prohibited.

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4. Governing Law
You agree that in the event of any dispute of any nature that may arise between you and Blackfriars, these terms and conditions shall be governed by and construed exclusively in accordance with the law of England and Wales. You agree to be subject to the exclusive jurisdiction of the courts of England and Wales. 

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Blackfriars Asset Management Limited is authorised and regulated by the Financial Conduct Authority in the United Kingdom.

Blackfriars Asset Management Limited (“Blackfriars”) is incorporated in England & Wales as a private company limited by shares under the Companies Act 2006 with its registered office at Landmark 4th Floor, 78 Cannon Street, London EC4N 6HL. Blackfriars is authorised and regulated by the Financial Conduct Authority (“FCA”) with firm reference number 180892.

This privacy policy statement is about how Blackfriars collects and processes personal information.

1.     General

Blackfriars collects and processes your personal information where you are

• a representative (such as an employee or a director) of one of our customers or potential customers;

• a beneficial owner of one of our customers or potential customers;

• a representative (such as an employee or a director) of one of our suppliers or potential suppliers; or

• a visitor to our offices, websites, or events.

Personal information is information that relates to you or allows Blackfriars to identify you. 

2.     Scope of processing

2.1   Types of personal information processed

Blackfriars collects and processes as little personal information about you as is necessary.

If you are a representative or beneficial owner of one of Blackfriars’s customers or potential customers, Blackfriars may collect and process the following information about you:

• your name, address, and date of birth; 

• “Know your customer” data necessary for the onboarding and monitoring of customers, which may include copies of your identity documents and other documents to validate your identity;

• your email addresses and telephone numbers;

• your employer’s name;

• recordings of telephone conversations between you and Blackfriars;

• your marketing preferences.

If you are a visitor to Blackfriars’s offices, websites, or events, Blackfriars may collect and process the following information about you:

• your name and address;

• your email addresses and telephone numbers;

• your employer’s name;

• technical data regarding your use of Blackfriars’s websites, such as your IP addresses, your devices and browsers, and your activities while on its websites;

• your marketing preferences.

If you are a representative of one of Blackfriars’s suppliers or potential supplies, Blackfriars may collect and process the following information about you:

• your name and address;

• your email addresses and telephone numbers;

• your employer’s name;

• recordings of telephone conversations between you and Blackfriars;

• your marketing preferences.

2.2   Sources of your personal information

Blackfriars may obtain personal information about you from the following sources:

• directly from you;

• from your employer (where your employer is a customer of Blackfriars or a supplier to Blackfriars);

• from financial service providers or exchanges;

• from credit reference agencies, government agencies, publicly accessible registers, and the providers of sanction lists maintained by HM Treasury, the UN, the SECO, and the EU.

2.3   Period for which your personal information is stored

The period for which Blackfriars stores your personal information is determined according to our statutory record-keeping obligations, the purpose for which we process your personal information, and the possibility of legal or regulatory claims that might be brought against Blackfriars.

2.4   Purposes for processing your personal information

Blackfriars processes your personal information for the following reasons:

• customer registration;

• management and administration of Blackfriars’s relationships with its customers, suppliers, and visitors;

• product and business development;

• risk management, including credit and operational risk and fraud risk;

• marketing and market research;

• compliance with statutory and regulatory disclosure and reporting obligations;

• compliance with law, including the orders of courts and regulatory bodies;

• protecting Blackfriars's interests in legal and regulatory proceedings;

• protecting the security of Blackfriars, its employees, and its customers.

2.5   Lawful bases for the processing of your personal information

Blackfriars relies on the following lawful bases for the processing of your personal information:

• Blackfriars has a legitimate interest;

• Blackfriars has a legal obligation;

• Blackfriars needs to perform a public task;

• you have consented (note that you can withdraw your consent at any time by contacting Blackfriars’s compliance officer – see section 4 below).

2.6   Sharing of your personal information

Blackfriars may share your personal information with:

• other parties involved in the transactions and trading that Blackfriars engages in as part of its services to customers (including affiliates of Blackfriars, counterparties to its transactions and trades, exchanges, clearing houses, depositaries, and custodians);

• government agencies and regulatory bodies in accordance with statutory and regulatory obligations, such as the Financial Conduct Authority, the European 

• Securities and Markets Authority, the National Crime Agency, the Information Commissioner and the Financial Ombudsman Service, and including government agencies and regulatory bodies of affiliates of Blackfriars such as FINMA and the Swiss National Bank;

• external organisations, including affiliates of Blackfriars that provide ordinary business and IT services to Blackfriars, including services for fraud prevention, hosting and securing our information systems and our CRM databases, marketing, email hosting, data backups, ID verification, and sanction lists verification (Blackfriars will not permit these suppliers to use your personal information for their own purposes);

• a new owner or potential new owner of Blackfriars’s business where Blackfriars is considering or decides to sell its business (your information will be transferred to the new owner to enable the continuation of the business).

Where Blackfriars shares your personal information, this may sometimes be with organisations based in countries outside the UK and the European Economic Area. This international transfer of your personal information will be undertaken in compliance with applicable data protection law and will be generally under standard contractual terms approved by the European Commission.

3.     Data security

Blackfriars protects the privacy of individuals in line with applicable data protection law. Blackfriars takes numerous precautions to ensure this, such as the implementation of technical and organisational security measures (e.g. the use of firewalls, personal passwords as well as encryption and authentication technologies, access restrictions, awareness-raising and training of employees, appointing a data protection adviser).

4.     Rights

You have the following rights regarding your personal information (subject to certain limitations and exceptions):

• to require Blackfriars to provide you with a copy of your personal information, and further details about its use of your personal information;

• to require Blackfriars to correct inaccuracies in your personal information;

• to require Blackfriars to erase your personal information or to restrict its use;

• to object to Blackfriars’s use of your personal information;

• to require Blackfriars to transfer your personal information to a third party.

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If you wish to exercise any of your rights, please write to Blackfriars together with a clearly legible copy of a valid official identity document (for example, passport, identity card, or driving licence) at the following address: 

Blackfriars Asset Management Limited

Landmark 4th Floor

78 Cannon Street

London EC4N 6HL

Where Blackfriars is processing your personal information on the lawful basis of consent, you can at any time withdraw your consent to this processing by writing to Blackfriars in the manner described above. Please note that withdrawal of consent only has an effect on the future.

5.     Complaints

If you have any queries regarding Blackfriars’s data protection practices or if you wish to complain about them, you should do so in writing. For details please refer to Blackfriars’s entry on the FCA Register which can be found here: https://register.fca.org.uk/s/firm?id=001b000000MfHVMAA3.

If you are not satisfied with Blackfriars's response, you can contact the Information Commissioner's Office (https://ico.org.uk/), which is our data protection supervisory authority.

6.     Updating of the privacy policy statement

This privacy policy statement was last updated in November 2022. It explains in general terms the way your personal data is processed by Blackfriars. This privacy policy statement does not constitute a part of any contract between Blackfriars and you. This privacy policy statement may be updated from time to time. In the event of such an amendment, you will be informed in an appropriate manner depending on how Blackfriars usually communicates with you, for example, via the website www.blackfriarsam.com. 

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1. Introduction

This document sets out the policy relating to conflicts of interest at Blackfriars Asset Management Limited (“Blackfriars”). In accordance with the requirements under MiFID II, including the MiFID Organisational Requirements Regulation and the Senior Management Arrangements, Systems and Controls (“SYSC”) part of the Financial Conduct Authority (“FCA”) Handbook, specifically SYSC 10, this policy: 

1. identifies the circumstances which constitute or may give rise to a conflict of interest potentially entailing a risk to the interests of one or more clients; 

2. specifies procedures to be followed and measures to be adopted in order to prevent or manage such conflicts and 

3. communicates this information to all employees, directors, contractors, temporary staff and secondees (each a “relevant person"). 

2. Regulatory background

MiFID II and SYSC 10 require investment firms to establish, implement and maintain effective written conflicts of interest policy set out in writing and appropriate to the size and organisation of the firm and the nature, scale and complexity of its business. 

Where the firm is a member of a group, as Blackfriars is, the policy must also take into account any circumstances of which the firm is or should be aware, which may give rise to a conflict of interest arising as a result of the structure and business activities of other members of the group. 

A firm must manage conflicts of interest fairly, both between itself and its clients and between a client and another client and must implement rules to protect itself and its clients from conflicts of interest. 

A firm is required to take all appropriate steps to identify and prevent or manage conflicts of interest between: 

a) the firm (including its managers, employees, or any person directly or indirectly linked to them by control) and a client of the firm; or 

b) one client of the firm and another client, 

that or may arise in the course of the firm providing any services in the course of carrying on regulated activities, including those caused by the receipt of inducements from third parties or by the firm’s own remuneration and other incentive structures. 

It is not enough that the firm may gain a benefit if there is not also a possible disadvantage to a client or that one client to whom the firm owes a duty may make a gain or avoid a loss without there being a concomitant possible loss to another such client. 

3. Types of Conflicts of Interest

Conflicts may arise whether the firm or a relevant person, or a person directly or indirectly linked by control to the firm:

• is likely to make a financial gain, or avoid a financial loss, at the expense of the client; 

• has an interest in the outcome of a service provided to the client or of a transaction carried out for the client, which is distinct from the client's interest in that outcome; 

• has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client; 

• carries on the same business as the client; or 

• receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monetary or non-monetary benefits or services. 

The conflict of interest may result from the firm carrying on or providing a regulated service or ancillary service, as previously detailed, or engaging in any other activity. 

4. Situations in which conflicts of interest could arise

Blackfriars provides brokerage services to its clients. There are, therefore, various situations in which conflicts of interest could arise. The purpose of this section is to set out typical situations in which conflicts of interest may arise and are managed in the course of Blackfriars’s day-to-day business so that relevant persons covered by this policy are better equipped to identify, report and assist in eliminating or managing conflicts of interest. 

Appropriate measures may include the following: 

a)     procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients; 

b)     the separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict or who otherwise represent different interests that may conflict, including those of Blackfriars; 

c)     the removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities; 

d)     measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out services or activities; 

e)     measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest; and 

f)      disclosure to clients and their consent to the conflict. 

Suppose the adoption or the practice of one or more of those measures and procedures does not ensure the requisite level of independence. In that case, Blackfriars will adopt such alternative or additional measures and procedures as are necessary and appropriate. 

5. Managing conflicts 

If a relevant person identifies an actual or potential conflict of interest, they must report it to the Compliance Officer. Full details of the actual or potential conflict of interest should be reported to enable the Compliance Officer to make a ruling on the implications and instruct any mitigating action that must be taken. All details of such events and actions will be recorded by the Compliance Officer and distributed to the relevant individuals at the group level. 

It is the responsibility of the Compliance Officer, in conjunction with the Board, to set clear standards for the firm and to identify any potential conflicts of interest and define how Blackfriars should manage them, taking a broad view of the risks posed to the business and to clients. 

In conjunction with the Board, the Compliance Officer will design controls to reduce the impact of conflicts, such as those set out in Section 4. 

A compliance testing program is used to make sure that all conflicts which have been identified are managed effectively and in accordance with this policy. 

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6. Disclosure of Conflicts 

If arrangements made by Blackfriars to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a client will be prevented, Blackfriars will disclose the general nature and source of the conflict of interest to the client before undertaking business for the client. 

The disclosure will: 

a)     be made in a written, durable medium; 

b)     clearly state that the organisational and administrative arrangements established by the firm to prevent or manage that conflict are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the client will be prevented; 

c)     explain the risks that arise as a result of the conflict of interest and the steps taken to mitigate these risks; 

d)     provide sufficient detail to enable that client to make an informed decision in relation to the service in the context in which the conflict of interest arises; and 

e)     refer specifically to: 

        i.     Blackfriars’s terms of business; 

        ii.     This Conflicts of Interest Policy

7. Record keeping

Blackfriars will keep an up-to-date record of all actual or potential conflicts in a conflicts register. The register will include details of the service or activity carried out by or on behalf of the firm in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen or, in the case of an ongoing service or activity, may arise. 

The Best Execution policy is available upon request and is also provided as part of the client take-on process. 

1. Introduction 

The purpose of this policy is to give you some background information about how we handle any complaints about the service we provide to you. 

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2. Receiving a complaint 

All of our staff receive ongoing training to help ensure that they do their job properly and effectively. They also receive guidance on how to identify a complaint from a client. We are committed to handling any complaints we receive fairly, consistently and promptly. When we receive a complaint, it is immediately notified to our Compliance Officer. The Compliance Officer will look into your complaint and try to obtain as much information about what has happened as soon as possible. In any event, we will acknowledge your complaint promptly, and then keep you up-to-date with our progress with it. 

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3. Responding to your complaint 

Before we reply to you about your complaint, we will ensure that it is looked into by somebody here who: 

• is competent to look into the matter you have complained about; 

• is impartial; 

• is in a position of authority to settle the complaint; and 

• will address the subject of your complaint adequately and, where the complaint is upheld, will offer appropriate redress. 

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4. The next step

We will keep you up to date with our progress with your complaint and do our utmost to resolve it as speedily as possible. We will try and provide you with a final response to your complaint within eight weeks of its receipt. If we are not in a position to provide you with a final response, we will explain to you why we cannot provide it and advise you when it will be sent. 

If you are still unhappy about the way in which we have handled your complaint, you may refer it to the Financial Ombudsman Service, with whom we will cooperate fully in the handling of the complaint. You must do this within six months of the dispatch of our final response to you. At the time of our final response, we will also send you a copy of the Financial Ombudsman Service’s explanatory leaflet. This will also be provided to you within eight weeks of our receipt of your complaint if we are unable to provide you with the final response within the eight-week timeframe.

Most websites use "cookies' to identify users and enhance their browsing experience. Cookies are small text files that are downloaded on to a user's device by websites that the user visits. Blackfriars uses cookies to provide you with an optimised online experience and to let us know how and when pages of our websites are visited, what our visitors' technology preferences are and whether our website functions correctly. They make use of the site easier and may allow us to deliver content that is tailored to your interests. These cookies and other similar technologies are encrypted and cannot be read.

The types of cookies used by Blackfriars are:

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1. Strictly Necessary Cookies:

These are essential in enabling you to navigate the website and make use of its features. They are placed on your device and cannot be refused and can only be blocked by changing the settings in your browser.

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2. Performance Cookies:

These are cookies that collect information and are used to recognize you when you return to the site and personalize the content that you see. These are not essential to the site’s performance.

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3. Analytical or Customization Cookies

These are cookies that collect information about how a user accesses and navigates the site. These allow us to improve the site’s functionality and personalize the site to your interests.

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This privacy policy statement may be updated from time to time so please check back from time to time to see if it has changed.

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If you wish to raise any queries or complaints about this Cookie Policy please contact:

The Data Protection Officer, Blackfriars Asset Management Limited, Landmark 4th Floor, 78 Cannon Street, London EC4N 6HL

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