Any communications contained on this website are issued by: (i) Systematica Investments Limited (“SIL”) acting solely in its capacity as general partner of Systematica Investments LP (“SILP”), (ii) Systematica Investments GP Limited and acting through its Geneva branch (“SIGPL”), (iii) Systematica Investments Singapore Pte. Limited (“SISPL”) and/or (iv) Systematica Investments UK LLP (“SIUK”), (each and together “Systematica Investments”). Systematica Investments shall mean: (i) for all purposes, except for issue into the United States or issue to U.S. persons, issue into Australia or to Australian persons, issue into Singapore or to Singaporean persons, or issue into Switzerland or to Swiss persons, SIUK; (ii) only for the purposes of issue into the United States or issue to U.S. persons, SIL acting solely in its capacity as general partner of SILP; (iii) for the purposes of issue into Australia or to Australian persons or issue into Singapore or to Singaporean persons, SISPL; and (iv) only for the purposes of issue into Switzerland or to Swiss persons, SIGPL acting through its Geneva branch.
SIL is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser under the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”). SIL is registered with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a commodity trading advisor and a commodity pool operator and is a member of the U.S. National Futures Association (the “NFA”) in such capacities and is approved by the NFA as a swap firm. SIL as general partner of SILP is licensed and regulated by the Jersey Financial Services Commission (the “JFSC”) under the Financial Services (Jersey) Law 1998 (the “FSJL”) to conduct fund services business in and from within Jersey. The JFSC does not take any responsibility for the financial soundness of the Funds (as defined below) or for the correctness of any statements made or expressed herein. The JFSC is protected by the FSJL against liability arising from the discharge of its functions under that law. SIGPL is licensed and regulated by the JFSC under the FSJL to conduct fund services business in and from within Jersey and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm, and its Geneva branch is authorised by the Swiss Financial Market Supervisory Authority FINMA (“FINMA”) as a branch of a Manager of Collective Assets. SIUK is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”) and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. SISPL is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to “wholesale investors” in Australia (as that term is defined in the Corporations Act 2001 (Cth)), is regulated by the Monetary Authority of Singapore (the “MAS”) under the laws of Singapore, which differ from Australian laws, and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. Each of SIUK, SISPL and SIGPL is registered with the SEC as an investment adviser under the Advisers Act. Such registrations, memberships, approvals, authorizations and licenses do not imply that any of the SEC, the CFTC, the NFA, the JFSC, FINMA, the FCA or the MAS have approved any applicable Systematica Investments entity’s qualifications to provide the advisory services set forth in this document.
For the purposes of this disclaimer the “funds” referred to will include each of the funds described herein as well as any other funds, sub-funds, managed accounts, special purpose vehicles or investment vehicles in respect of which SIL has been appointed to act as or shall be appointed to act as, investment manager (each, a “Fund” and together, the “Funds”).
In respect of any content on this website operated by SIUK, the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional clients” as defined in the FCA’s Handbook of Rules and Guidance (the “FCA Handbook”); and (b) are persons who may lawfully receive access to such information under the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “PCISE Order”) and/or Chapter 4.12B of the FCA Handbook’s Conduct of Business Sourcebook (the persons described in (a) and (b) above together, the “Relevant Persons”). Access by persons who are not Relevant Persons is strictly unauthorised.
In respect of content on this website operated by Systematica Investments (excluding SIUK), the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional investors” as defined in the Alternative Investment Fund Managers Regulation (SI 2013/1773) (as amended); and (b) are persons who may lawfully access such information under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2001 (the “FPO”) including by virtue of being investment professionals within the meaning of Article 19(5) of the FPO (the persons described in (a) and (b) above together, the “Permitted Persons”). Access by persons who are not Permitted Persons is strictly unauthorised.
Where communications contained on this website are issued by SIL, the following applies. Communications contained on this website have been prepared in accordance with the requirements of the FSJL and any other legislation, regulations and orders which may be applicable from time to time, together with the requirements of any relevant codes of practice and guidance issued by the JFSC from time to time (the “JFSC Regulatory Requirements”). The information contained in such communications is directed by SIL exclusively at persons who are professional clients or eligible counterparties for the purposes of the JFSC Regulatory Requirements, or, if to U.S. persons (as defined under Regulation S promulgated under the U.S. Securities Act of 1933, as amended (the “Securities Act”)), to U.S. persons who are both accredited investors (as defined under Regulation D promulgated under the Securities Act) and qualified purchasers (as defined in the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”)).
Where communications contained on this website are issued by SISPL, such communications have been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the relevant offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to “wholesale investors” under the Corporations Act 2001 (Cth).
The interests in the Funds have not been filed with or approved or disapproved by any regulatory authority of the United States or any state thereof, nor has any such regulatory authority passed upon or endorsed the merits of an offering of a Fund or the accuracy or adequacy of communications contained on this website. Any representation to the contrary is unlawful.
PURSUANT TO AN EXEMPTION FROM THE COMMODITY FUTURES TRADING COMMISSION IN CONNECTION WITH ACCOUNTS OF QUALIFIED ELIGIBLE PERSONS, THIS BROCHURE OR ACCOUNT DOCUMENT IS NOT REQUIRED TO BE, AND HAS NOT BEEN, FILED WITH THE COMMODITY FUTURES TRADING COMMISSION. THE COMMODITY FUTURES TRADING COMMISSION DOES NOT PASS UPON THE MERITS OF PARTICIPATING IN A TRADING PROGRAM OR UPON THE ADEQUACY OR ACCURACY OF THE COMMODITY TRADING ADVISOR DISCLOSURE. CONSEQUENTLY, THE COMMODITY FUTURES TRADING COMMISSION HAS NOT REVIEWED OR APPROVED THIS TRADING PROGRAM OR THIS BROCHURE OR ACCOUNT DOCUMENT.
The distribution of information or documents contained in communications on this website may be further restricted by law. No action has been or will be taken by SIL or any Fund to permit the possession or distribution of the information or documents contained in communications on this website in any jurisdiction (other than as expressly stated by Systematica Investments) where action for that purpose may be required. Accordingly, documents and information contained in communications on this website may not be distributed, or forwarded to recipients, in any jurisdiction except under circumstances that will result in compliance with any applicable laws and regulations. It is the responsibility of the recipient of information or documents contained in communications on this website (or its agent or adviser, as the case may be) to ensure that any individuals (whether employed by them or otherwise) who receive the information herein do so in accordance with applicable law and regulation. Persons to whom documents and information contained in communications on this website are communicated should inform themselves about and observe any such restrictions.
Recipients of any communications contained on this website should note that electronic communication, whether by email, website, SWIFT or otherwise, is an unsafe method of communication. Emails and SWIFT messages may be lost, delivered to the wrong address, intercepted or affected by delays, interference by third parties or viruses and their confidentiality, security and integrity cannot be guaranteed. None of the Funds or Systematica Investments bear any liability or responsibility therefor.
Distribution and Selling Restrictions: The distribution of documents and information contained in communications on this website and the offering or purchase of interests in the Funds may be restricted in certain jurisdictions. No persons receiving a copy of documents or information contained in communications on this website in any such jurisdiction may treat such information or documents as constituting marketing or an invitation to them to subscribe for interests in the Funds. Accordingly, documents and information contained in communications on this website do not constitute marketing, an offer or solicitation by anyone in any jurisdiction in which such marketing, offer or solicitation is not lawful or in which the person marketing or making such offer or solicitation is not qualified to do so or to anyone to whom it is unlawful to market or make such offer or solicitation. It is the responsibility of any persons in possession of documents or information contained in communications on this website, including individuals who may be employed by or a consultant to the recipient, to inform themselves of, and to observe, all applicable laws and regulations of any relevant jurisdiction. If any recipient, including individuals, is or becomes aware that the receipt of documents or information contained in communications on this website by them contravenes any law or regulation, they must destroy it or return it to Systematica Investments immediately. Prospective applicants for interests in the Funds should inform themselves as to the legal requirements of so applying and any applicable exchange control regulations and taxes in the countries of their respective citizenship, residence or domicile.
Information for investors in the European Economic Area (the “EEA”) and the United Kingdom (“UK”): Investors that are resident, domiciled or with a registered office in any Member State of the EEA or the UK should note that access to this website is restricted to “professional investors” within the meaning of Directive 2011/61/EU (as amended and as implemented into local law or regulations in each EEA Member State, and in respect of the UK, as it forms part of UK law by virtue of the European Union (Withdrawal) Act 2018 (as amended), “AIFMD”). Access by persons that are not “professional investors” within the meaning of AIFMD is strictly unauthorised.
Information for investors in Switzerland: Any distribution or offer of interests in the Funds in Switzerland is exclusively made to, and directed at, qualified investors (“Qualified Investors”), as defined in the Swiss Collective Investment Schemes Act of 23 June 2006, as amended, and its implementing ordinance. Accordingly, the Funds have not been and will not be registered with FINMA for distribution to non-qualified investors. Any Funds which are Delaware limited partnerships are not distributed in Switzerland and are not available for subscription by investors in Switzerland. If a Swiss representative has been appointed in respect of a Fund, offering materials relating to interests in that Fund may be obtained by Qualified Investors in Switzerland from the Swiss representative and/or authorised distributors. Swiss representative (where appointed): Mont-Fort Funds AG, 63 Chemin Plan-Pra, 1936 Verbier, Switzerland. Swiss paying agent (where appointed): Helvetische Bank AG, Seefeldstrasse 215, CH-8008 Zurich, Switzerland. In respect of the distribution of interests in the Funds in and from Switzerland, the place of performance and jurisdiction is the registered office of the Swiss representative. Systematica Investments GP Limited, Geneva Branch is affiliated with the Swiss Arbitration Centre (formerly known as the Swiss Chambers’ Arbitration Institution) for the provision of ombudsman services under the Swiss Federal Act on Financial Services.
Information for investors in Australia: To the extent that communications contained on this website are issued by SISPL, such communications has been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to ‘wholesale investors’ under the Corporations Act 2001 (Cth).
Information for investors in Singapore: The Funds are not authorised or recognised by the MAS and interests in any Funds are not allowed to be offered to the retail public. Communications contained on this website and any other communication or material in connection with the offer, sale, invitation for subscription or purchase of interests in any Fund may not be circulated or distributed, nor may interests in any Fund be offered, sold or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to the public or any member of the public in Singapore other than a person who is an accredited investor or an institutional investor (each as defined under the Securities and Futures Act (Chapter 289) of Singapore) (“SFA”) or unless otherwise permitted under any applicable exemption. Communications contained on this website and any other communications or material in connection with the offer or sale, or invitation for subscription or purchase, of interests may not be circulated or distributed, nor may interests be offered or sold, or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to persons in Singapore other than in accordance with the conditions set out in the applicable provisions of the SFA. Communications contained on this website and any other communication or material issued in connection with the offer or sale is not a prospectus as defined in the SFA and has not been registered as a prospectus with the MAS. Accordingly, statutory liability under the SFA in relation to the content of prospectuses would not apply. Each prospective investor should consider carefully whether the investment is suitable for him.
SIL, as general partner of SILP (SIL together with SILP and each of their subsidiaries and affiliates, the “Systematica Group”), was appointed as investment manager of the Funds on or after 1 January 2015 following the “spin-out” of the Systematica Group. Any Fund performance information in communications contained on this website relating to dates prior to 1 January 2015 illustrates the performance of the Funds whilst the predecessors of the Systematica Group were appointed as investment manager to the Funds. There is no guarantee that past performance of the Funds will be replicated under the management of the Systematica Group.
Communications contained on this website are not intended to constitute, and should not be construed as, investment advice, investment recommendations or investment research. Current and prospective investors acknowledge that no member of the Systematica Group has conducted or will conduct the activity of reception and transmission of orders in relation to the interests of the Funds, whether for the Funds, investors or otherwise. Potential investors in the Funds should seek their own independent financial, tax, legal and other advice. Communications contained on this website have been made available to you for informational purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to herein or for any other purpose. Communications contained on this website are not intended as and are not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. Before making any investment decision you should obtain independent legal, tax, accounting or other professional advice, as appropriate, none of which is offered to you by the members of the Systematica Group or any of their affiliates. None of the members of the Systematica Group or any of their affiliates accepts any duty of care to you in relation to any investment in the Funds.
The terms of investment in any of the Funds described herein or any other Fund are solely as set out in the relevant Fund’s prospectus or private placement memorandum (including any supplements thereto), as the case may be, application forms and/or memorandum and articles of association or limited partnership agreement or instrument of incorporation, as the case may be (collectively, the “Fund Documents”). Before acquiring an interest in any Fund, each prospective investor is required to confirm that it has carefully reviewed the various risks of an investment in the Fund, as set out in the Fund Documents, and is required to acknowledge and agree to the existence of any actual and potential conflicts of interests described in the Fund Documents and waive, to the fullest extent permitted by any applicable law, any claim with respect to the existence of any such conflicts.
Communications contained on this website may contain simulated performance results achieved by means of the retroactive application of Systematica Investments’ investment methodology, or the real-time application of a hypothetical capital allocation to such strategy. Hypothetical performance results have many inherent limitations, some of which are described below. No representation is being made that any particular trading program will or is likely to achieve profits or losses similar to those shown. In fact, there are frequently sharp differences between hypothetical performance results and the actual results subsequently achieved by any particular trading program. One of the limitations of hypothetical performance results is that they are generally prepared with the benefit of hindsight. In addition, hypothetical trading does not involve financial risk, and no hypothetical trading record can completely account for the impact of financial risk in actual trading. For example, the ability to withstand losses or to adhere to a particular trading program in spite of trading losses are material points which can also adversely affect actual trading results. There are numerous other factors related to the markets in general or to the implementation of any specific trading program which cannot be fully accounted for in the preparation of hypothetical performance results and all of which can adversely affect actual trading results.
Although the information in communications contained on this website is believed to be materially correct as at the date of issue, no representation or warranty is given as to the accuracy of any of the information provided. Furthermore, no representation or warranty is given in respect of the correctness of the information contained herein as at any future date. Certain information included in communications contained on this website is based on information obtained from third-party sources considered to be reliable. Any projections or analysis provided to assist the recipient of communications contained on this website in evaluating the matters described therein may be based on subjective assessments and assumptions and may use one among many alternative methodologies that produce different results. Accordingly, any projections or analysis should not be viewed as factual and should not be relied upon as an accurate prediction of future results. Furthermore, to the extent permitted by law, SIL, SILP, SIUK, SISPL, SIGPL, the Funds, and their branches, affiliates, agents, service providers and professional advisers assume no liability or responsibility and owe no duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in communications on this website or for any decision based on it.
PAST, PROJECTED AND/OR SIMULATED PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. Past, projected and/or simulated performance may not be a reliable guide to future performance. The actual performance realised by any given investor will depend on numerous factors and circumstances. Communications contained on this website may include returns for various indices. These indices are not intended to be direct benchmarks for a particular Fund, nor are they intended to be indicative of the type of assets in which a particular Fund may invest. The assets invested in by any of the Funds will likely be materially different from the assets underlying these indices, and will likely have a significantly different risk profile. The target returns, volatility and Sharpe ratio figures quoted are targets only and are based over the long term on the performance projections of the investment strategy and market interest rates at time of modelling and therefore may change.
Interests in the Funds and other investments and investment services to which communications contained on this website relate are only available to the persons referred to in the relevant paragraphs above, and other persons should not act on the information contained therein.
Any decision to purchase securities or interests with respect to any of the Funds described herein must be based solely upon the information contained in the Fund Documents, which must be received and reviewed prior to any investment decision. Any person subscribing for an investment must be able to bear the risks involved (including the risk of a total loss of capital) and must meet the suitability requirements relating to such investments. Some or all alternative investment programmes may not be suitable for certain investors.
Among the risks we wish to call to the particular attention of current and prospective investors are the following: (1) each Fund’s investment programme is speculative in nature and entails substantial risks; (2) the investments of each Fund may be subject to sudden and large falls in price or value and there could be a large loss upon realisation of a holder’s investment, which could equal the total amount invested; (3) as there is no recognised market for many of the investments of the Funds, it may be difficult or impossible for a Fund to obtain complete and/or reliable information about the value of such investments or the extent of the risks to which such investments are exposed; (4) the use of a single adviser group could mean a lack of diversification and, consequently, higher risk, and may depend upon the services of key personnel, and if certain or all of them become unavailable, the Funds may prematurely terminate; (5) an investment in a Fund is illiquid and there is no secondary market for the sale of interests in a Fund and none is expected to develop; (6) there are restrictions on transferring interests in a Fund; (7) SIL and its affiliates may receive performance-based compensation, which may result in riskier investments, and the Funds’ fees may offset trading profits; (8) the Funds are subject to certain conflicts of interest; (9) certain securities and instruments in which the Funds may invest can be highly volatile; (10) the Funds may be leveraged; (11) a substantial portion of the trades executed for the Funds take place on non-U.S. exchanges; (12) changes in rates of exchange may also have an adverse effect on the value, price or income of the investments of each Fund; and (13) the Funds are not mutual funds pursuant to, and are therefore not subject to, regulation under the Investment Company Act.
As announced in June 2022, the investment management business of First Quadrant, LLC (“First Quadrant”) was acquired by SIL acting solely in its capacity as general partner of SILP, with certain clients of First Quadrant transferring to SIL before the end of 2022. The information contained in documents and information contained in communications on this website may relate to, or contain, information in respect of, First Quadrant and its management of the assets of certain accounts and investment strategies referred to herein. This information may be subject to updating, completion and amendment. Any performance data and other information in communications contained on this website illustrates the performance of the relevant accounts and strategies (as applicable), and/or provides information in relation to them, in respect of the period during which First Quadrant was appointed as investment manager. The members of the Systematica Group take no responsibility for any such data or information which has not been checked or verified independently by any of the members of the Systematica Group. There is no guarantee that past performance of the relevant accounts and strategies (to the extent managed by First Quadrant) will be replicated under the management of the Systematica Group.
Any communications contained on this website are issued by: (i) Systematica Investments Limited (“SIL”) acting solely in its capacity as general partner of Systematica Investments LP (“SILP”), (ii) Systematica Investments GP Limited and acting through its Geneva branch (“SIGPL”), (iii) Systematica Investments Singapore Pte. Limited (“SISPL”) and/or (iv) Systematica Investments UK LLP (“SIUK”), (each and together “Systematica Investments”). Systematica Investments shall mean: (i) for all purposes, except for issue into the United States or issue to U.S. persons, issue into Australia or to Australian persons, issue into Singapore or to Singaporean persons, or issue into Switzerland or to Swiss persons, SIUK; (ii) only for the purposes of issue into the United States or issue to U.S. persons, SIL acting solely in its capacity as general partner of SILP; (iii) for the purposes of issue into Australia or to Australian persons or issue into Singapore or to Singaporean persons, SISPL; and (iv) only for the purposes of issue into Switzerland or to Swiss persons, SIGPL acting through its Geneva branch.
SIL is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser under the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”). SIL is registered with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a commodity trading advisor and a commodity pool operator and is a member of the U.S. National Futures Association (the “NFA”) in such capacities and is approved by the NFA as a swap firm. SIL as general partner of SILP is licensed and regulated by the Jersey Financial Services Commission (the “JFSC”) under the Financial Services (Jersey) Law 1998 (the “FSJL”) to conduct fund services business in and from within Jersey. The JFSC does not take any responsibility for the financial soundness of the Funds (as defined below) or for the correctness of any statements made or expressed herein. The JFSC is protected by the FSJL against liability arising from the discharge of its functions under that law. SIGPL is licensed and regulated by the JFSC under the FSJL to conduct fund services business in and from within Jersey and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm, and its Geneva branch is authorised by the Swiss Financial Market Supervisory Authority FINMA (“FINMA”) as a branch of a Manager of Collective Assets. SIUK is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”) and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. SISPL is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to “wholesale investors” in Australia (as that term is defined in the Corporations Act 2001 (Cth)), is regulated by the Monetary Authority of Singapore (the “MAS”) under the laws of Singapore, which differ from Australian laws, and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. Each of SIUK, SISPL and SIGPL is registered with the SEC as an investment adviser under the Advisers Act. Such registrations, memberships, approvals, authorizations and licenses do not imply that any of the SEC, the CFTC, the NFA, the JFSC, FINMA, the FCA or the MAS have approved any applicable Systematica Investments entity’s qualifications to provide the advisory services set forth in this document.
For the purposes of this disclaimer the “funds” referred to will include each of the funds described herein as well as any other funds, sub-funds, managed accounts, special purpose vehicles or investment vehicles in respect of which SIL has been appointed to act as or shall be appointed to act as, investment manager (each, a “Fund” and together, the “Funds”).
In respect of any content on this website operated by SIUK, the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional clients” as defined in the FCA’s Handbook of Rules and Guidance (the “FCA Handbook”); and (b) are persons who may lawfully receive access to such information under the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “PCISE Order”) and/or Chapter 4.12B of the FCA Handbook’s Conduct of Business Sourcebook (the persons described in (a) and (b) above together, the “Relevant Persons”). Access by persons who are not Relevant Persons is strictly unauthorised.
In respect of content on this website operated by Systematica Investments (excluding SIUK), the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional investors” as defined in the Alternative Investment Fund Managers Regulation (SI 2013/1773) (as amended); and (b) are persons who may lawfully access such information under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2001 (the “FPO”) including by virtue of being investment professionals within the meaning of Article 19(5) of the FPO (the persons described in (a) and (b) above together, the “Permitted Persons”). Access by persons who are not Permitted Persons is strictly unauthorised.
Where communications contained on this website are issued by SIL, the following applies. Communications contained on this website have been prepared in accordance with the requirements of the FSJL and any other legislation, regulations and orders which may be applicable from time to time, together with the requirements of any relevant codes of practice and guidance issued by the JFSC from time to time (the “JFSC Regulatory Requirements”). The information contained in such communications is directed by SIL exclusively at persons who are professional clients or eligible counterparties for the purposes of the JFSC Regulatory Requirements, or, if to U.S. persons (as defined under Regulation S promulgated under the U.S. Securities Act of 1933, as amended (the “Securities Act”)), to U.S. persons who are both accredited investors (as defined under Regulation D promulgated under the Securities Act) and qualified purchasers (as defined in the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”)).
Where communications contained on this website are issued by SISPL, such communications have been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the relevant offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to “wholesale investors” under the Corporations Act 2001 (Cth).
The interests in the Funds have not been filed with or approved or disapproved by any regulatory authority of the United States or any state thereof, nor has any such regulatory authority passed upon or endorsed the merits of an offering of a Fund or the accuracy or adequacy of communications contained on this website. Any representation to the contrary is unlawful.
PURSUANT TO AN EXEMPTION FROM THE COMMODITY FUTURES TRADING COMMISSION IN CONNECTION WITH ACCOUNTS OF QUALIFIED ELIGIBLE PERSONS, THIS BROCHURE OR ACCOUNT DOCUMENT IS NOT REQUIRED TO BE, AND HAS NOT BEEN, FILED WITH THE COMMODITY FUTURES TRADING COMMISSION. THE COMMODITY FUTURES TRADING COMMISSION DOES NOT PASS UPON THE MERITS OF PARTICIPATING IN A TRADING PROGRAM OR UPON THE ADEQUACY OR ACCURACY OF THE COMMODITY TRADING ADVISOR DISCLOSURE. CONSEQUENTLY, THE COMMODITY FUTURES TRADING COMMISSION HAS NOT REVIEWED OR APPROVED THIS TRADING PROGRAM OR THIS BROCHURE OR ACCOUNT DOCUMENT.
The distribution of information or documents contained in communications on this website may be further restricted by law. No action has been or will be taken by SIL or any Fund to permit the possession or distribution of the information or documents contained in communications on this website in any jurisdiction (other than as expressly stated by Systematica Investments) where action for that purpose may be required. Accordingly, documents and information contained in communications on this website may not be distributed, or forwarded to recipients, in any jurisdiction except under circumstances that will result in compliance with any applicable laws and regulations. It is the responsibility of the recipient of information or documents contained in communications on this website (or its agent or adviser, as the case may be) to ensure that any individuals (whether employed by them or otherwise) who receive the information herein do so in accordance with applicable law and regulation. Persons to whom documents and information contained in communications on this website are communicated should inform themselves about and observe any such restrictions.
Recipients of any communications contained on this website should note that electronic communication, whether by email, website, SWIFT or otherwise, is an unsafe method of communication. Emails and SWIFT messages may be lost, delivered to the wrong address, intercepted or affected by delays, interference by third parties or viruses and their confidentiality, security and integrity cannot be guaranteed. None of the Funds or Systematica Investments bear any liability or responsibility therefor.
Distribution and Selling Restrictions: The distribution of documents and information contained in communications on this website and the offering or purchase of interests in the Funds may be restricted in certain jurisdictions. No persons receiving a copy of documents or information contained in communications on this website in any such jurisdiction may treat such information or documents as constituting marketing or an invitation to them to subscribe for interests in the Funds. Accordingly, documents and information contained in communications on this website do not constitute marketing, an offer or solicitation by anyone in any jurisdiction in which such marketing, offer or solicitation is not lawful or in which the person marketing or making such offer or solicitation is not qualified to do so or to anyone to whom it is unlawful to market or make such offer or solicitation. It is the responsibility of any persons in possession of documents or information contained in communications on this website, including individuals who may be employed by or a consultant to the recipient, to inform themselves of, and to observe, all applicable laws and regulations of any relevant jurisdiction. If any recipient, including individuals, is or becomes aware that the receipt of documents or information contained in communications on this website by them contravenes any law or regulation, they must destroy it or return it to Systematica Investments immediately. Prospective applicants for interests in the Funds should inform themselves as to the legal requirements of so applying and any applicable exchange control regulations and taxes in the countries of their respective citizenship, residence or domicile.
Information for investors in the European Economic Area (the “EEA”) and the United Kingdom (“UK”): Investors that are resident, domiciled or with a registered office in any Member State of the EEA or the UK should note that access to this website is restricted to “professional investors” within the meaning of Directive 2011/61/EU (as amended and as implemented into local law or regulations in each EEA Member State, and in respect of the UK, as it forms part of UK law by virtue of the European Union (Withdrawal) Act 2018 (as amended), “AIFMD”). Access by persons that are not “professional investors” within the meaning of AIFMD is strictly unauthorised.
Information for investors in Switzerland: Any distribution or offer of interests in the Funds in Switzerland is exclusively made to, and directed at, qualified investors (“Qualified Investors”), as defined in the Swiss Collective Investment Schemes Act of 23 June 2006, as amended, and its implementing ordinance. Accordingly, the Funds have not been and will not be registered with FINMA for distribution to non-qualified investors. Any Funds which are Delaware limited partnerships are not distributed in Switzerland and are not available for subscription by investors in Switzerland. If a Swiss representative has been appointed in respect of a Fund, offering materials relating to interests in that Fund may be obtained by Qualified Investors in Switzerland from the Swiss representative and/or authorised distributors. Swiss representative (where appointed): Mont-Fort Funds AG, 63 Chemin Plan-Pra, 1936 Verbier, Switzerland. Swiss paying agent (where appointed): Helvetische Bank AG, Seefeldstrasse 215, CH-8008 Zurich, Switzerland. In respect of the distribution of interests in the Funds in and from Switzerland, the place of performance and jurisdiction is the registered office of the Swiss representative. Systematica Investments GP Limited, Geneva Branch is affiliated with the Swiss Arbitration Centre (formerly known as the Swiss Chambers’ Arbitration Institution) for the provision of ombudsman services under the Swiss Federal Act on Financial Services.
Information for investors in Australia: To the extent that communications contained on this website are issued by SISPL, such communications has been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to ‘wholesale investors’ under the Corporations Act 2001 (Cth).
Information for investors in Singapore: The Funds are not authorised or recognised by the MAS and interests in any Funds are not allowed to be offered to the retail public. Communications contained on this website and any other communication or material in connection with the offer, sale, invitation for subscription or purchase of interests in any Fund may not be circulated or distributed, nor may interests in any Fund be offered, sold or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to the public or any member of the public in Singapore other than a person who is an accredited investor or an institutional investor (each as defined under the Securities and Futures Act (Chapter 289) of Singapore) (“SFA”) or unless otherwise permitted under any applicable exemption. Communications contained on this website and any other communications or material in connection with the offer or sale, or invitation for subscription or purchase, of interests may not be circulated or distributed, nor may interests be offered or sold, or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to persons in Singapore other than in accordance with the conditions set out in the applicable provisions of the SFA. Communications contained on this website and any other communication or material issued in connection with the offer or sale is not a prospectus as defined in the SFA and has not been registered as a prospectus with the MAS. Accordingly, statutory liability under the SFA in relation to the content of prospectuses would not apply. Each prospective investor should consider carefully whether the investment is suitable for him.
SIL, as general partner of SILP (SIL together with SILP and each of their subsidiaries and affiliates, the “Systematica Group”), was appointed as investment manager of the Funds on or after 1 January 2015 following the “spin-out” of the Systematica Group. Any Fund performance information in communications contained on this website relating to dates prior to 1 January 2015 illustrates the performance of the Funds whilst the predecessors of the Systematica Group were appointed as investment manager to the Funds. There is no guarantee that past performance of the Funds will be replicated under the management of the Systematica Group.
Communications contained on this website are not intended to constitute, and should not be construed as, investment advice, investment recommendations or investment research. Current and prospective investors acknowledge that no member of the Systematica Group has conducted or will conduct the activity of reception and transmission of orders in relation to the interests of the Funds, whether for the Funds, investors or otherwise. Potential investors in the Funds should seek their own independent financial, tax, legal and other advice. Communications contained on this website have been made available to you for informational purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to herein or for any other purpose. Communications contained on this website are not intended as and are not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. Before making any investment decision you should obtain independent legal, tax, accounting or other professional advice, as appropriate, none of which is offered to you by the members of the Systematica Group or any of their affiliates. None of the members of the Systematica Group or any of their affiliates accepts any duty of care to you in relation to any investment in the Funds.
The terms of investment in any of the Funds described herein or any other Fund are solely as set out in the relevant Fund’s prospectus or private placement memorandum (including any supplements thereto), as the case may be, application forms and/or memorandum and articles of association or limited partnership agreement or instrument of incorporation, as the case may be (collectively, the “Fund Documents”). Before acquiring an interest in any Fund, each prospective investor is required to confirm that it has carefully reviewed the various risks of an investment in the Fund, as set out in the Fund Documents, and is required to acknowledge and agree to the existence of any actual and potential conflicts of interests described in the Fund Documents and waive, to the fullest extent permitted by any applicable law, any claim with respect to the existence of any such conflicts.
Communications contained on this website may contain simulated performance results achieved by means of the retroactive application of Systematica Investments’ investment methodology, or the real-time application of a hypothetical capital allocation to such strategy. Hypothetical performance results have many inherent limitations, some of which are described below. No representation is being made that any particular trading program will or is likely to achieve profits or losses similar to those shown. In fact, there are frequently sharp differences between hypothetical performance results and the actual results subsequently achieved by any particular trading program. One of the limitations of hypothetical performance results is that they are generally prepared with the benefit of hindsight. In addition, hypothetical trading does not involve financial risk, and no hypothetical trading record can completely account for the impact of financial risk in actual trading. For example, the ability to withstand losses or to adhere to a particular trading program in spite of trading losses are material points which can also adversely affect actual trading results. There are numerous other factors related to the markets in general or to the implementation of any specific trading program which cannot be fully accounted for in the preparation of hypothetical performance results and all of which can adversely affect actual trading results.
Although the information in communications contained on this website is believed to be materially correct as at the date of issue, no representation or warranty is given as to the accuracy of any of the information provided. Furthermore, no representation or warranty is given in respect of the correctness of the information contained herein as at any future date. Certain information included in communications contained on this website is based on information obtained from third-party sources considered to be reliable. Any projections or analysis provided to assist the recipient of communications contained on this website in evaluating the matters described therein may be based on subjective assessments and assumptions and may use one among many alternative methodologies that produce different results. Accordingly, any projections or analysis should not be viewed as factual and should not be relied upon as an accurate prediction of future results. Furthermore, to the extent permitted by law, SIL, SILP, SIUK, SISPL, SIGPL, the Funds, and their branches, affiliates, agents, service providers and professional advisers assume no liability or responsibility and owe no duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in communications on this website or for any decision based on it.
PAST, PROJECTED AND/OR SIMULATED PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. Past, projected and/or simulated performance may not be a reliable guide to future performance. The actual performance realised by any given investor will depend on numerous factors and circumstances. Communications contained on this website may include returns for various indices. These indices are not intended to be direct benchmarks for a particular Fund, nor are they intended to be indicative of the type of assets in which a particular Fund may invest. The assets invested in by any of the Funds will likely be materially different from the assets underlying these indices, and will likely have a significantly different risk profile. The target returns, volatility and Sharpe ratio figures quoted are targets only and are based over the long term on the performance projections of the investment strategy and market interest rates at time of modelling and therefore may change.
Interests in the Funds and other investments and investment services to which communications contained on this website relate are only available to the persons referred to in the relevant paragraphs above, and other persons should not act on the information contained therein.
Any decision to purchase securities or interests with respect to any of the Funds described herein must be based solely upon the information contained in the Fund Documents, which must be received and reviewed prior to any investment decision. Any person subscribing for an investment must be able to bear the risks involved (including the risk of a total loss of capital) and must meet the suitability requirements relating to such investments. Some or all alternative investment programmes may not be suitable for certain investors.
Among the risks we wish to call to the particular attention of current and prospective investors are the following: (1) each Fund’s investment programme is speculative in nature and entails substantial risks; (2) the investments of each Fund may be subject to sudden and large falls in price or value and there could be a large loss upon realisation of a holder’s investment, which could equal the total amount invested; (3) as there is no recognised market for many of the investments of the Funds, it may be difficult or impossible for a Fund to obtain complete and/or reliable information about the value of such investments or the extent of the risks to which such investments are exposed; (4) the use of a single adviser group could mean a lack of diversification and, consequently, higher risk, and may depend upon the services of key personnel, and if certain or all of them become unavailable, the Funds may prematurely terminate; (5) an investment in a Fund is illiquid and there is no secondary market for the sale of interests in a Fund and none is expected to develop; (6) there are restrictions on transferring interests in a Fund; (7) SIL and its affiliates may receive performance-based compensation, which may result in riskier investments, and the Funds’ fees may offset trading profits; (8) the Funds are subject to certain conflicts of interest; (9) certain securities and instruments in which the Funds may invest can be highly volatile; (10) the Funds may be leveraged; (11) a substantial portion of the trades executed for the Funds take place on non-U.S. exchanges; (12) changes in rates of exchange may also have an adverse effect on the value, price or income of the investments of each Fund; and (13) the Funds are not mutual funds pursuant to, and are therefore not subject to, regulation under the Investment Company Act.
As announced in June 2022, the investment management business of First Quadrant, LLC (“First Quadrant”) was acquired by SIL acting solely in its capacity as general partner of SILP, with certain clients of First Quadrant transferring to SIL before the end of 2022. The information contained in documents and information contained in communications on this website may relate to, or contain, information in respect of, First Quadrant and its management of the assets of certain accounts and investment strategies referred to herein. This information may be subject to updating, completion and amendment. Any performance data and other information in communications contained on this website illustrates the performance of the relevant accounts and strategies (as applicable), and/or provides information in relation to them, in respect of the period during which First Quadrant was appointed as investment manager. The members of the Systematica Group take no responsibility for any such data or information which has not been checked or verified independently by any of the members of the Systematica Group. There is no guarantee that past performance of the relevant accounts and strategies (to the extent managed by First Quadrant) will be replicated under the management of the Systematica Group.
DISCLOSURE
Citigroup
Events disclosed in connection with Rule 506(e)
1. Regulatory action initiated by Commodity Futures Trading Commission against Citigroup, Inc. (“Citigroup”) and Citigroup Global Markets Ltd. (“CGML”) for violation of Section 4a(b)(2) of the Commodity Exchange Act and Commission regulation 150.2 in that Citigroup, via its wholly owned subsidiaries, held aggregated net long positions in wheat contracts that exceeded the all months speculative position limits established by the commission as a result of trading on the Chicago Board of Trade (“CBOT”). In addition, CGML individually held net long positions in wheat contracts that exceeded the all months speculative position limits established by the commission as a result of trading on the CBOT. Action resulted in the issuance of consent order to cease and desist and civil monetary penalty in the amount of $525,000. Without admitting or denying the findings, respondents consented to cease and desist and a civil monetary penalty in the amount of $525,000. (Resolution Date: 09/21/2012).
2. Regulatory action initiated by Board of Governors of the Federal Reserve System (the “Federal Reserve”) against Citigroup and CitiFinancial Credit Company (“Citifinancial” and together with Citigroup, “Citi”) resulting in issuance of a consent order to cease and desist (the “Consent Order”). The Consent Order made no finding on any issues of fact or law nor any explicit allegation concerning Citi. The Consent Order described a consent order that the Office of the Comptroller of the Currency (the “OCC”) and Citibank, N.A. (the “Bank”), which is owned and controlled by Citigroup, entered into addressing areas of weakness identified by the OCC in residential mortgage loan servicing, loss mitigation, foreclosure activities, and related functions. The Consent Order also stated that the OCC’s findings, which the Bank neither admitted nor denied, raised concerns that Citi did not adequately assess the potential risks associated with such activities of the Bank. The Consent Order stated it is the common goal of the parties to maintain effective corporate governance and oversight over the consolidated organization relating to the weaknesses identified by the OCC consent order. In addition, the Consent Order stated that it is the further goal of the parties to effectively manage their legal, reputational, and compliance risks. The Consent Order required Citi and their institution-affiliated parties to cease and desist and take specified affirmative action, including that Citi or Citigroup’s board: (i) take steps to ensure the bank complies with the OCC consent order; (ii) submit written plans to strengthen risk management, internal audit, and compliance programs concerning certain mortgage loan servicing, loss mitigation, and foreclosure activities conducted through CitiMortgage, Inc. or Citifinancial; and (iii) periodically submit written progress reports detailing the form and manner of all actions taken to secure compliance with the OCC consent order. Citi agreed to consent to a settlement with the Federal Reserve. In the settlement, Citi agreed to consent to the entry of the Consent Order, without the Consent Order constituting an admission by Citi or any of theirs subsidiaries of any allegation made or implied by the Federal Reserve in connection with the matter (Resolution Date: 04/13/2011).
3. Civil judicial action initiated by the Securities and Exchange Commission (the “SEC”) against Citigroup for violations of Section 17(a)(2) of the U.S. Securities Act of 1933 (the “Securities Act”), Section 13(a) of the U.S. Securities Exchange Act of 1934 (the “Exchange Act”), and Exchange Act rules 12b-20 and 13a-11 in connection with disclosures made between July 2007 and October 2007 about the subprime exposure in Citibank’s investment banking unit. As alleged in the complaint, a violation of Section 17(a)(2) of the Securities Act may be established by a showing of negligence. The specific allegations are that Citigroup misled investors when it stated that it had reduced the investment bank’s subprime exposure from $24 billion at the end of 2006 to $13 billion or slightly less than that amount, while, in fact, the investment bank’s subprime exposure also included approximately $43 billion of “super senior” tranches of subprime collateralized debt obligations and related instruments called “liquidity puts.” On July 19, 2010, Citigroup submitted a consent to judgment which was presented by the SEC in the United States District Court for the District of Columbia (the “Court”) on July 29, 2010. In the consent, Citigroup consented to the entry of final judgment as to defendant Citigroup without admitting or denying the matters set forth therein (other than those relating to the jurisdiction of the court and the subject matter of the action). The final judgment resolved the allegations set forth in a complaint filed by the SEC, described above. The Court entered the final judgment where Citigroup was permanently enjoined from violating Section 17(a)(2) of the Securities Act, Section 13(a) of the Exchange Act, and Exchange Act rules 12b-20 and 13a-11. Citigroup agreed to pay disgorgement in the amount of $1 and a civil monetary penalty of $75 million. Citigroup paid the disgorgement and civil penalty on October 22, 2010. In a related matter, the SEC settled an administrative cease-and-desist proceeding relating to Exchange Act Section 13(a) and Exchange Act Rules 12b-20 and 13a-11 with a current employee of Citigroup and a former employee of Citigroup (Resolution Date: 10/19/2010).
4. Regulatory action initiated by the Federal Reserve against Citifinancial for failure to comply with SEC. 202.7(d)(1) of Federal Reserve Board Regulation B (“Regulation B”) and 15 U.S.C. 1691 et seq., which prohibit a creditor from requiring the signature of a co-applicant if the applicant qualifies based on his or her creditworthiness, engaging in unsafe and unsound practices under 12 U.S.C. 1818(i)(2)(b) in connection with its underwriting and lending practices with respect to certain loans subject to 15 U.S.C. 1639 and Federal Reserve Board Regulation Z (“Regulation Z”), and engaging in unsafe and unsound practices under 12 U.S.C. 1818(i)(2)(b) relating to its actions to allegedly mislead examiners in connection with examiner interviews of Citifinancial employees. Citigroup and Citifinancial consented to the imposition of an order to cease and desist and order of assessment of a civil money penalty. The order required Citifinancial and its institution-affiliated parties to cease and desist from practices and policies that violate SEC. 202.7(d)(1) of Regulation B and from unsafe and unsound practices in connection with Citifinancial’s underwriting and lending activities, SEC. 202.7(d)(1) of Regulation B, and comply with all applicable consumer protection laws, rules and regulations. Citifinancial was required to submit a restitution plan to the Federal Reserve concerning the alleged Regulation B and Regulation Z violations and pay a civil monetary penalty of $70 million subject to a partial credit of up to $20 million to the extent that restitution payments were made. The total funds available for restitution were expected to exceed $50 million. Finally, the order imposed certain remedial measures in the areas of compliance, audit, training, internal controls and interactions with regulatory authorities (Resolution Date: 5/27/2004).
5. Case No. SEU-2006-002. The State of Hawaii’s Commissioner of Securities, Department of Commerce and Consumer Affairs conducted an investigation to determine whether Citigroup Global Markets Inc. (“CGMI”) engaged in any violation of the Hawaii Uniform Securities Act, Hawaii Revised Statutes and other applicable authority with respect to a Hawaii investor’s claim that his telephone order to purchase penny stock was misplaced by a CGMI securities salesperson, which allegedly resulted in a settlement balance that was larger than the investor expected. In April 2013, without admitting or denying the allegations, CGMI entered into a consent agreement with the Hawaii Commissioner of Securities, in which CGMI agreed to make a restitution payment to the investor in the amount of $33,240 and $9,000 to the state for the cost of the investigation.
6. Matter No. 2012-0090 (Oct. 26, 2012). The Massachusetts Securities Division alleged that CGMI violated Mass. Gen. Laws Ch. 110, Section 204(a)(2)(f), 204(a)(2)(g), 204(a)(2)(j), and 950 CMR Section 12.204(1)(a) for allegedly failing to supervise certain research analysts, during the period between December 1, 2011 and May 2, 2012. Without admitting or denying the allegations, CGMI consented to a cease and desist order, censure, civil penalty in the amount of $2,000,000, and an undertaking to review written supervisory policies and procedures related to Citigroup Investment Research (“CIR”) electronic surveillance program and training provided to CIR equity research analysts, CIR supervisors, and CIR compliance personnel.
7. I08-345 (Mar. 31, 2011). The State of Nevada alleged that CGMI failed to ensure compliance with its supervisory requirements when one of its sales representatives improperly set up brokerage accounts for a customer between 1995 and 2008. Without admitting or denying the allegations, CGMI consented to an order to cease from future violations, and to pay both costs of investigation in the amount of $25,000 and a fee for inspection of records in the amount of $1,000.
8. 2010-0329-S (December 15, 2010). The State of New York Insurance Department (2010-0329-S) alleged that Citicorp Insurance Agency, Inc. (“CIAI”) and Citicorp Investment Services (“CIS”), both of which merged into CGMI, and SBHU Life Agency, Inc. (“SBHU”) violated Section 51.5(c) of the New York Regulation 60 by failing to present complete, accurate and/or timely disclosure statements to applicants in replacement transactions (from January 1, 2003 through December 31, 2007). CIAI, CIS and SBHU did not adequately process and resolve certain client complaints pertaining to the sale of life insurance policies or annuity contracts. Certain sales of life insurance policies or annuity contracts were inconsistent with CIAI, CIS and SBHU’s internal suitability standards. Action resulted in a stipulation agreement among the parties. CIAI, CIS and SBHU consented to the imposition of a civil penalty of $2 million and to take certain remedial actions described by the stipulation agreement.
9. 10-0477 CA (Oct. 26, 2010). The Indiana Securities Division alleged that CGMI violated Indiana Code Section 23-2-11 and 710 Ind. Admin. Code 1-17 by failing to adequately supervise a registered representative. It was alleged that the representative, for a period from September 2004 to May 2005, engaged in a scheme, along with a CGMI customer, to misappropriate funds from cemeteries in Indiana over which the customer had acquired control. While denying liability and without the entry of any findings of fact or conclusions of law, CGMI consented to an order of a fine in the amount of $400,000, restitution in the amount of $142,000, and costs of investigation in the amount of $175,000.
10. I07-044-JN (Oct. 22, 2010). The State of Nevada alleged a violation of NRS 205.960(1)(a) by CGMI. CGMI allegedly failed to properly supervise certain accounts handled by its representatives between 1999 and 2004 with respect to a brokerage account, which should have been opened as qualified escrow accounts or qualified trusts, and as such, failed to follow its policies and procedures with respect to the supervision and approval of such accounts. Without admitting or denying the findings, CGMI consented to an order to cease future violations and to pay $125,000 for costs of investigation.
11. AP-10-22 (Oct. 20, 2010). The Missouri Securities Division alleged that CGMI violated Missouri law (Section 409.4-412, (d)(9), RSMO. (Cum. Supp. 2009)) by failing to reasonably supervise a registered representative. The representative was alleged to have made improper recommendations, over a period of time from 2000 to 2007, relating to the retirement accounts and investments of a customer. Without admitting or denying the allegations, CGMI consented to an order of censure, restitution in the amount of $195,000, a fine in the amount of $75,000, and costs of investigation in the amount of $3,750.
12. IC10-CAF-12 (May 3, 2010). The State of Texas alleged that CGMI failed to deliver to the Director of the Inspections & Compliance Division of the Texas State Securities Board, notice of five client arbitrations/complaints as required per an undertaking with the Securities Commissioner and failed to enforce written policies and procedures designed to achieve compliance with the Texas Securities Act. In so doing, CGMI allegedly failed to enforce written procedures designed to achieve compliance with the Texas Securities Act. Without admitting or denying the findings, CGMI consented to an order of reprimand, and an administrative fine in the amount of $130,000.
13. Complaint – 08 CIV 10753 (RMB) (S.D.N.Y. Dec. 11, 2008); Sec Lit Rel. No. 20824. The SEC finalized a settlement with CGMI that provided nearly $7 billion to tens of thousands of customers who invested in auction rate securities before the market for those securities froze in February of 2008. The settlement resolved the SEC’s charges that CGMI allegedly misled investors regarding the liquidity risks associated with Auction Rate Securities (“ARS”) that it underwrote, marketed and sold. Previously, on August 7 and 8, 2008, the SEC’s Division of Enforcement announced a preliminary settlement with CGMI. According to the SEC’s complaint, filed in federal court in New York City, CGMI misrepresented to customers that ARS were safe, highly liquid investments that were comparable to money markets. According to the complaint, in late 2007 and early 2008, CGMI knew that the ARS market was deteriorating, causing CGMI to have to purchase additional inventory to prevent failed auctions. At the same time, however, CGMI was alleged to have known that its ability to support auctions by purchasing more ARS had been reduced, as the credit crisis stressed CGMI’s balance sheet. The complaint alleged that CGMI failed to make its customers aware of these risks. In mid-February 2008, according to the complaint, CGMI decided to stop supporting the ARS market, leaving tens of thousands of CGMI customers holding tens of billions of dollars in illiquid ARS. The settlement, which was subject to court approval, restored approximately $7 billion in liquidity to CGMI customers who invested in ARS.
Sec Lit Rel. No. 21585 (June 30, 2010). The SEC announced that CGMI satisfied its obligations under the settlement (discussed above). CGMI was required to offer to purchase ARS at par value from individual, charitable, and small business customers. Nearly 100% of these customers accepted the offer. CGMI purchased ARS from its eligible customers in the amount of $6.38 billion. The settlement also required CGMI to use “best efforts” to provide opportunities for liquidity to institutional customers. To assist in its analysis of whether CGMI had in fact used “best efforts,” the SEC retained an outside expert with extensive knowledge of the ARS market. From the time of the ARS market failure in February 2008 through May 31, 2010, Citigroup institutional customer holdings were reduced by $8.46 billion or 46% (from $18.55 billion to $10.09 billion). In compliance with its obligations, Citigroup implemented broad-based liquidity measures for its institutional investors. Citigroup also met its other settlement obligations, including compensating investors who sold ARS below par value, reimbursing investors for excess interest costs associated with loans taken out due to ARS illiquidity, and participating in special arbitration proceedings before the Financial Industry Regulatory Authority. CGMI also submitted periodic reports to, and met quarterly with, the SEC staff regarding its progress on meeting the settlement obligations. To ensure compliance with the terms, the settlement provided for a potential deferred penalty if CGMI did not meet its settlement obligations. The SEC determined that based on CGMI’s compliance with the settlement, as well as other factors, no penalties would be pursued.
August 7, 2008. In a related matter, CGMI reached agreements with state regulatory authorities from the 50 states and with the North American Securities Administrators Association in relation to allegations that Citigroup mislead clients by falsely assuring that ARS securities were safe and liquid. As part of the settlement, CGMI agreed to reimburse investors who sold auction rate securities at a discount, consent to a special public arbitration procedure to resolve claims of consequential damages, undertake to expeditiously provide liquidity solutions to all other institutional investors, and to reimburse refinancing fees to state municipal issuers who issued auction rate securities through CGMI between August 2007 and February 2008. In addition, CGMI agreed to pay a $50 million penalty to the states and an additional $50 million penalty to the State of New York.
14. SEC-2007-00047 (Nov. 7, 2008). The Virginia Division of Securities & Retail Franchising alleged that CGMI violated (i) Securities Rule 21 VAC 5-20-260 D (2) by failing to perform frequent examinations of all customer accounts to detect and prevent irregularities or abuses and (ii) Rule 21 VAC 5-20-260 D (4) by failing to review and receive written approval by the designated supervisor of the delegation by any customer of discretionary authority with respect to the customer’s account to the broker-dealer or to a stated agent or agents of the broker-dealer and the prompt written approval of each discretionary order entered on behalf of that account. The investigative matter involved CGMI and one associated agent of CGMI. CGMI neither admitted nor denied the violations. A collaborative settlement was entered where CGMI paid penalties in the amount of $10,000 and investigative costs in the amount of $12,000.
15. In July 2007, the State of New Jersey Bureau of Securities (the “N.J. Bureau”) alleged that CGMI violated N.J.S.A. 49:3-58(a)(2)(xi) due to its failure, during the time period March 2003 through January 2004, to reasonably supervise and establish and enforce procedures necessary to detect and prevent unsuitable trading and the alteration of customer profiles by certain employees at the branch office in Short Hills, New Jersey. Further, the N.J. Bureau alleged that CGMI violated N.J.S.A. 49:3-59 and N.J.A.C. 13:47a-1.10 due to its failure during the time period specified above to maintain books and records which accurately reflected the account profiles of certain of its clients. Without admitting or denying the allegations and solely for the purposes of this proceeding and any other proceeding brought by or on behalf of the N.J. Bureau, or to which the N.J. Bureau is a party, prior to hearing and without an adjudication of any issue of law or fact CGMI consented to restitution in the amount of $478,000 and a civil monetary penalty of $500,000.
16. In July 2007, the N.J. Bureau alleged that, from January 2000 through September 2003, CGMI failed: (i) to reasonably supervise certain persons associated with CGMI in violation of N.J.S.A. 49:3-58(a)(2)(xi) and (ii) to establish and/or enforce reasonable supervisory procedures for detecting and preventing deceptive market timing practices. Further, CGMI allegedly violated N.J.A.C. 13:47a-1.10 by failing to make and/or preserve accurate books and records relating to: (i) order communications and entry time for mutual fund trades, (ii) rejection and/or cancellation of mutual fund and variable annuity sub-account trades related to market timing, and (iii) shares orders and/or confirmations for transactions executed by certain persons associated with CGMI in variable annuity accounts and other insurance sub-accounts away from CGMI. CGMI consented to the entry of the order without admitting or denying the N.J. Bureau’s findings of fact or conclusions and solely for the purpose of resolving the matter without the expense and delay that formal administrative proceedings would involve. The civil monetary penalty of $5 million was paid in June 2007.
17. Case No. SEC-2005-41 (Mar. 7, 2006). Montana State Auditor and Commissioner of Securities alleged that CGMI submitted an application for registration on behalf of a registered financial consultant without ensuring the accuracy of the information contained therein. Without admitting or denying the findings of fact and conclusions of law, CGMI agreed to pay an administrative fine of $4,000, and consented to an order to provide proper supervision to ensure the accuracy of the registration application of an individual financial consultant registered in the State of Montana.
18. Order No. 05-394 (Dec. 20, 2005). State of Rhode Island alleged that CGMI violated R.I. Gen. Laws Sec. 7-11-212(b)(8), due to its failure to reasonably supervise the sales representatives and activities at its Rhode Island branch offices. Allegedly, in the absence of proper supervision, certain CGMI sales representatives were involved in several unethical and dishonest practices that violated Rhode Island law. Without admitting or denying any findings or violations, CGMI entered into a consent order in which it agreed to cease and desist from any further violations of the Rhode Island Uniform Securities Act, and agreed to pay a civil penalty of $700,000.00 and investigation costs of $300,000.00. CGMI also agreed to retain an independent consultant to review current internal supervisory and compliance procedures of its Rhode Island offices and the current business practices of CGMI’s registered representatives in the Rhode Island offices.
19. SEC-2003-00038 (June 25, 2004). The Virginia State Corporation Commission, Division of Securities and Retail Franchising, alleged that CGMI violated commission Rule 21 VAC 5-20-260 B, due to its failure to exercise diligent supervision over the actions of two of its registered representatives. Without admitting or denying the allegations, CGMI consented to a penalty in the amount of fifty thousand dollars ($50,000.00) and agreed to pay the sum of twenty-two thousand four hundred eighty-six dollars ($22,486.00) to defray the costs of the investigation. The fines were paid on June 24, 2004.
20. CAF030018 (NASD Apr. 28, 2003). The SEC, the National Association of Securities Dealers (“NASD”), the New York Stock Exchange (“NYSE”) and other regulators alleged violations of Exchange Act Section 15(c), Rule 15c1-2 thereunder, Section 15(c)(1) of the Exchange Act, Rule 15c-1 thereunder, Section 15(c)(2) of the Exchange Act, Section 15(f) of the Exchange Act and Exchange Act 17(a)(1) and Rule 17a-3 thereunder, NASD Conduct Rules 2110, 2210(d)(1), 2210(d)(2), 3010, and 3110 by predecessor firm Salomon Smith Barney Inc. (“SSB”), now known as CGMI, arising out of certain of its business practices concerning (i) research during the period 1999 through 2001 and (ii) initial public offerings (“IPOs”) during the period 1996 through 2000. The NASD alleged that SSB engaged in certain business practices that created inappropriate influence by investment bankers over research analysts, thereby imposing conflicts of interest on them. It was further alleged that SSB published certain fraudulent research reports and other research reports that violated applicable legal or regulatory requirements for communications with the public. It was also alleged that SSB failed to maintain policies and procedures reasonably designed to prevent potential misuse of material, non-public information in certain circumstances. Regarding SSB’s handling of IPOs, it was alleged that SSB engaged in improper “spinning” and failed to maintain adequate books and records. Finally, it was alleged that SSB failed to supervise certain aspects of its research and IPO allocation activities.
21. On April 28, 2003, the SEC, the NASD, NYSE, the Attorney General of the State of New York, and several state securities regulators announced their acceptance of a global settlement with 10 firms, including SSB, completely and finally resolving the respective regulators’ investigation of the firms stemming from alleged conflicts of interest resulting from interactions between the firms’ research and investment banking departments. In connection with the April 28, 2003 announcement, SSB executed the following documents: a letter of acceptance, waiver, and consent with the NASD; a stipulation and consent with the NYSE; an assurance of discontinuance with the Attorney General of the State of New York; and a consent in connection with a complaint filed by the SEC in the United States District Court for the Southern District of New York on April 28, 2003 and a final judgment to be entered by the court. Solely for the purpose of settling each proceeding, prior to hearing, without adjudication of any issues of law or fact, and without admitting or denying the facts or conclusions alleged in the respective regulators’ documents, SSB consented to findings that SSB violated certain federal securities laws and regulations and NASD rules set forth above. Further, SSB agreed to implementation of certain structural reforms relating to the operation of the research and investment banking departments; appointment of an independent monitor to review compliance with such reforms; and monetary payments for procurement of “independent research” ($75 million) and for investor education ($25 million). In addition, SSB consented to the imposition of NASD censure and a total payment of $400 million, as specified in the final judgment to which SSB consented to be entered in a related action filed by the SEC, which includes $150 million as disgorgement that will be placed in a distribution fund and distributed to investors, $75 million for the procurement of independent research that SSB will make available to investors, and $25 million for investor education. Each settling state will receive a payment equal to $150 million multiplied by the percentage of the U.S. population resident in that state. SSB also consented to undertakings to implement certain structural reforms relating to the operation of its research and investment banking departments. Finally, SSB also agreed to participate in a voluntary initiative pursuant to which it will no longer make allocations of “hot” IPOs to corporate insiders
Events disclosed pursuant to SEC order
1. Case No. 11-CV-7387, Securities and Exchange Commission v. Citigroup Global Markets Inc. (S.D.N.Y. Aug. 5, 2014): On October 19, 2011, the SEC filed a complaint in the United States District Court for the Southern District of New York regarding Citigroup’s structuring and sale of the Class V Funding III CDO (Class V) (“CDO”). The complaint alleged that the marketing materials for the CDO were materially misleading because they suggested that Citigroup was acting in the traditional role of an arranging bank, when in fact Citigroup had allegedly exercised influence over the selection of the assets and had retained a proprietary short position of the assets it had helped select, which gave Citigroup allegedly undisclosed economic interests adverse to those of the investors in the CDO. On the same day the complaint was filed, the SEC and Citigroup announced a settlement of the SEC’s claims, subject to judicial approval, and the SEC filed a proposed final judgment pursuant to which Citigroup’s U.S. broker-dealer CGMI, without admitting or denying the allegations, agreed to disgorge $160 million and to pay $30 million in prejudgment interest and a $95 million penalty; the consent agreement required the issuance of an injunction against CGMI from violating Sections 17(a)(2) and (3) of the Securities Act. After a lengthy series of court proceedings, the court approved the settlement on August 5, 2014. CGMI received a waiver from the SEC of any disqualification under Rule 506 of Regulation D arising from the settlement. A more detailed description of CGMI’s settlement with the SEC and the relief granted is available at http://www.sec.gov/rules/other/2014/33-9657.pdf. The SEC’s complaint can be found at http://www.sec.gov/litigation/complaints/2011/comp-pr2011-214.pdf
2. On August 19, 2015, CGMI entered into a settlement agreement with the SEC in connection with two enforcement actions concerning CGMI’s surveillance of trading against certain restricted trading lists and principal trading by Automated Trading Desk Financial Services LLC in managed accounts. Without admitting or denying the SEC’s allegations that CGMI violated Section 15(g) of the Exchange Act and Section 206(4) of the U.S. Investment Advisers Act of 1940 (the “Advisers Act”) and Rule 206(4)-7 thereunder, CGMI has agreed to pay a $15 million civil penalty and comply with an undertaking to continue to retain a consultant to conduct a comprehensive assessment of CGMI’s trade surveillance program and order handling in relation to transactions for which CGMI acts as an investment adviser.
3. On January 26, 2017, CGMI entered into a settlement agreement with the SEC in connection with overcharges in certain advisory client accounts (the “Order”). The overcharges related primarily to the TRAK Fund Solution program, which was a wrap fee investment advisory program offered and sold to advisory clients from 1991 through 2011 by CGMI and its predecessor, Salomon Smith Barney. A much smaller number of advisory fee overcharges occurred in frozen advisory accounts and certain advisory accounts that were not migrated to the Morgan Stanley Smith Barney joint venture.
4. The SEC found that CGMI violated various provisions of the Advisers Act by overcharging or causing to be overcharged approximately 60,000 advisory client accounts an estimated amount of $18 million and by failing to keep proper books and records with respect to maintenance of client contracts. Those overcharges have, at the time of the Order, been reimbursed with interest, to the extent they have been identified. Pursuant to the Order, CGMI agreed to a censure, a cease and desist order, payment of disgorgement and pre-judgment interest in the amount of $4,000,000, payment of a civil money penalty in the amount of $14,300,000 and comply with certain undertakings related to fee billing, books and records and notice to advisory clients. CGMI received a waiver from the Division of Corporation Finance, acting for the SEC pursuant to delegated authority, of any disqualification under Rule 506 of Regulation D arising from the entry of the Order. The Order can be obtained at https://www.sec.gov/litigation/admin/2017/34-79882.pdf.
Other events
On August 17, 2015, pursuant to an administrative cease-and-desist order from the SEC, Citi Alternative Investments LLC (“CAI”) and CGMI entered into a settlement agreement with the SEC in connection with enforcement actions concerning material misstatements and omissions by CAI and CGMI between 2002 and 2007 in the offer and sale of securities in the ASTA and MAT funds and the Falcon Strategies funds. Without admitting or denying the SEC’s findings that CAI and CGMI willfully violated Sections 17(a)(2) and 17(a)(3) of the Securities Act, CGMI willfully violated Section 206(2) of the Advisers Act and CAI willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 and 206(4)-8 promulgated thereunder, CGMI and CAI have agreed to pay an approximate $140 million disgorgement penalty plus interest and cease and desist from committing any of the aforementioned violations.
SBAI
No responsibility, duty of care or liability whatsoever (whether in contract or tort or otherwise including, but not limited to, negligence) is or will be accepted by the Standards Board for Alternative Investments Limited (“SBAI”), the Board of Trustees of the SBAI, any member of the SBAI’s Investor Chapter (each an “Investor Chapter Member”) or a Core Supporter of the SBAI to Signatories, investors or any other person in connection with the Standards or any Conformity Statement or Disclosure Statement made by any Signatory. A Core Supporter can be a Signatory to the Standards, a member of the SBAI’s Investor Chapter or an investment consultant.
Neither the SBAI nor its Board of Trustees is a regulator of the alternative investment industry and their role does not extend beyond being a custodian of the Standards. None of the SBAI, its Board of Trustees, the Investor Chapter Members and the Core Supporters will seek to enforce compliance with the Standards by Signatories. The fact that a manager is a Signatory to the Standards is not and should not be taken as an endorsement of such manager by the SBAI, the Board of Trustees, any Investor Chapter Member or any Core Supporter or as a representation by the SBAI, the Board of Trustees, any Investor Chapter Member or any other Core Supporter that such Signatory operates in conformity with the Standards. In determining whether to accept a manager’s application to become a Signatory (or whether to revoke a manager’s status as a signatory), the Board of Trustees is entitled to rely on the information provided to it by such manager without further investigation or verification. Further, subject to any duties a Trustee may have under applicable law, it is not envisaged, or expected, that a Trustee will when participating in any such decision of the Board of Trustees take into consideration information which it may possess otherwise than in its capacity as a Trustee. For the avoidance of doubt, Trustees act as individuals.
None of the SBAI, the Board of Trustees of the SBAI, the Investor Chapter Members and the other Core Supporters accept any responsibility or liability for any loss or damage caused to any person who acts or refrains from acting as a result of anything contained in or omitted from the Standards or any Conformity Statement or Disclosure Statement made by any Signatory or in reliance on the provisions of or material in the Standards or any Conformity Statement or Disclosure Statement made by any Signatory, whether such loss or damage is caused by negligence or otherwise.
Each of (i) 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) (“EU GDPR”), (ii) the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR” and together with EU GDPR, “GDPR”), (iii) the Cayman Islands Data Protection Act (As Revised) (and any associated guidance and regulations, together, “DPA”), (iv) the Swiss Federal Act on Data Protection of 25 September 2020 (“FADP”), (v) the Singaporean Personal Data Protection Act of 2012 (No. 26 of 2012), as amended by the Personal Data Protection (Amendment) Act 2020 (“PDPA”), and (vi) the Personal Information Protection Law of the People’s Republic of China (“PIPL”, and together with GDPR, DPA, FADP and PDPA, and any associated ordinances and regulations, the “Data Protection Laws”) may be applicable, to the extent relevant, to the processing of personal data by each of Systematica Investments Services Limited, Systematica Investments UK LLP (“SIUK”), Systematica Investments Limited, Systematica Investments LP, Systematica Investments Holdings Limited, Systematica Investments GP Limited, including when acting through its Geneva branch, Systematica Investments US LLC, Systematica Investments Singapore Pte. Ltd and Systematica Investments Shanghai Co., Ltd (the “Systematica Entities”) in the course of their businesses, and certain other persons. This notice sets out information relating to those activities.
The Systematica Entities
To the extent applicable, the Systematica Entities are controllers of personal data for the purposes of the Data Protection Laws and will, in the course of each Systematica Entity’s business, process personal data. Information regarding such processing is set out herein.
Any person seeking information with respect to control or processing of personal data by any of the Systematica Entities or seeking to exercise any applicable rights afforded to them under the Data Protection Laws should contact the compliance department of SIUK at .
As applicable under the Data Protection Laws, any person wishing to is entitled to make a complaint with respect to any of the Systematica Entities’ control or processing of personal data. For example, under UK GDPR, such a complaint may be made to the Information Commissioner’s Office (“ICO”). The ICO is the UK supervisory authority for data protection issues. Contact details for the ICO may be found at www.ico.org.uk. Under DPA, such a complaint may be made to the Cayman Islands Ombudsman (“Ombudsman”). The Ombudsman is the Cayman Islands supervisory authority for data protection issues. Contact details for the Ombudsman may be found at www.ombudsman.ky.
The policies and procedures adopted by the Systematica Entities with respect to the control or processing of personal data may be amended from time to time. Similarly, the purposes for which the Systematica Entities may control or process personal data may change from time to time. If any changes would require a material amendment to the information set out herein, details of such changes will be made available in the current version of this document from time to time.
Summary of Personal Data
For the purposes of the applicable Data Protection Laws, personal data means any information about an individual from which that person can be identified, directly or indirectly. In the course of their business, the Systematica Entities may collect, use, store, transfer and process personal information from individuals, including former, current or prospective investors and other natural persons, and former, current and prospective employees, directors, officers or other representatives or agents of market counterparties, professional services and other service providers, trade associations, public bodies and other entities or undertakings. Such personal data is typically limited in scope, and includes, for example, the name and contact details of such individuals, as well as some technical data (such as internet protocol addresses), usage data and information about marketing and communication preferences. On occasions, the Systematica Entities may also process personal data of such individuals which includes other identifiers such as date of birth, social security number, tax identification number, passport, national identity or driver’s licence number. Personal data that the Systematica Entities collect may also include commercial information, such as records of products or services purchased, obtained or considered, or other purchasing histories or tendencies, including funds invested in, investments considered, or sources of wealth; and professional or employment-related information, such as investment experience, occupation, compensation, employer and title.
In addition, the Systematica Entities may also collect, use, store, transfer and process personal information concerning current or former applicants for positions of employment at or membership of, or current or former employees or members of, the Systematica Entities. Such personal data may include some or all of the following: name and contact details, information about employment and educational history, performance records, salary data, references, bank account details, identification data, tax information, social security numbers and information regarding immigration status. The Systematica Entities will endeavour to contact those former job applicants or former employees if the personal data processed in relation to the same is material, sensitive or particularly private in order to inform them of the continued processing of their personal data, the nature of that processing, the lawful basis upon which the processing is taking place, and their rights under the Data Protection Laws with respect to such processing.
In certain limited circumstances, the Systematica Entities may process special categories of personal data (which may include details about people’s racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about people’s health, genetic and biometric data and information about criminal convictions and offences).
Collection of Personal Data
The Systematica Entities may collect personal data through a range of means. These may include direct interactions (where a person provides personal data to the relevant Systematica Entity through correspondence or other direct methods of communication), through third-party service providers (for example, recruitment agents) or publicly available sources (where a Systematica Entity receives personal data through a publicly available source such as a website or publicly available registry).
Purposes for Collection and Use of Personal Data
The Systematica Entities will only process personal data in circumstances where they have established a lawful basis under the Data Protection Laws to do so. These circumstances include where the processing of the relevant data relates to a legitimate interest of the relevant Systematica Entity, further described below. In such circumstances the Systematica Entities will have established that the processing is necessary for the relevant purpose, and not inconsistent with the interests, rights or freedoms of a relevant data subject.
In accordance with the above, each Systematica Entity has determined that the lawful bases for its processing of personal data are the legitimate interests of the relevant Systematica Entity to undertake activities necessary and ancillary to the carrying on of an investment management business, including where necessary for the purposes of the relevant Systematica Entity carrying out its activities relating to any fund, vehicle or account in respect of which a Systematica Entity acts as investment manager, sub-investment manager, investment adviser or sub-investment adviser (the “Funds”), the administration of the Funds, the investment activities of the Funds, otherwise in furtherance of any contract entered into with respect to the activities of the Funds, to exercise and comply with the relevant Fund’s or Systematica Entity’s rights and obligations at law or under regulation where such obligations are not set out under the laws of any member state of the European Economic Area (“EEA”) or the United Kingdom, to establish, exercise or defend legal claims and in order to protect and enforce its (or another person’s) rights, property, or safety, or to assist others to do the same, and in order to provide information about its services and any investment products it offers.
In addition, each Systematica Entity may also control or process personal data where necessary to comply with legal or regulatory obligations applicable to them under the laws of the Cayman Islands, the United Kingdom, the European Union or any member state of the EEA or any other relevant jurisdiction, or in order to give effect to a contract, or to take necessary pre-contractual steps with a view to potentially entering into a contract (including in its capacity as an employer or a prospective employer), or where an individual has provided their consent to such processing, to the extent applicable.
Systematica Entities may from time to time control or process personal data for the purposes of operating their business, entering into contractual arrangements in the context of their investment management business, including in respect of the Funds marketing, and advertising the Funds and/or other investment vehicles and/or services related to the Systematica Entities. Any person who does not wish their personal data to be processed for marketing purposes may opt out of such processing by notifying the compliance department of SIUK at .
Any Systematica Entity will only use personal data for the purposes that it has been collected for, unless they reasonably consider that they need to use it for another reason and that reason is compatible with the original purpose of the control or processing. Any person requiring information with respect to any additional purpose for which personal data may be controlled or processed may obtain such information from the compliance department of SIUK. If a Systematica Entity needs to control or process personal data for an unrelated purpose, the relevant Systematica Entity will use its reasonable endeavours to notify affected persons and to explain the basis on which they are permitted to undertake the same.
The Systematica Entities may be legally obliged to process certain personal data in order to be able to perform services and business operations or to comply with contractual requirements. If individuals choose not to provide the Systematica Entities with the necessary personal data or to restrict the Systematica Entities from processing personal data, the Systematica Entities may not be able to meet their obligations or deliver the products or services requested. This may lead to cancellation of contracts; if this is the case, the relevant Systematica Entity will endeavour to contact the individuals to discuss this.
Disclosure of Personal Data
Each Systematica Entity may share personal data with certain third parties for the purposes set out above. The relevant third parties with whom such personal data may be shared include entities appointed to provide services to the Funds, the relevant Systematica Entity and their affiliates, including professional service providers such as banks, auditors, law firms, consultants and other third parties; regulatory, legal and tax authorities; and third parties in the event any Systematica Entity sells or transfers all or a portion of its business or assets (including in the event of a reorganisation, dissolution or liquidation). Further details of the third parties with whom personal data may be shared are available on request from the compliance department of SIUK. Wherever possible, personal data will only be disclosed by a Systematica Entity to a third party in circumstances where that third party has agreed to respect the security of personal data and treat it in accordance with applicable law. The Systematica Entities will seek to ensure that third parties to whom any personal data may be disclosed will not use personal data for their own purposes and only process personal data for specified purposes and otherwise in accordance with the instructions of the relevant Systematica Entity and/or with the Data Protection Laws.
Transfer of Personal Data outside the EEA, the United Kingdom, the Cayman Islands, Switzerland, Singapore or mainland China
The activities of the Systematica Entities are such that it may be necessary for personal data to be transferred and/or processed outside the EEA, the United Kingdom, the Cayman Islands, Switzerland, Singapore or mainland China.
In circumstances where a Systematica Entity transfers personal data outside the EEA, the United Kingdom, the Cayman Islands, Switzerland, Singapore or mainland China, they will seek to ensure a similar degree of protection is afforded to it by ensuring that personal data is generally transferred only to persons in countries outside the EEA, the United Kingdom, the Cayman Islands, Switzerland, Singapore or mainland China in one of the following circumstances:
- to persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, the relevant Secretary of State in the United Kingdom, the Ombudsman (in the Cayman Islands), the Federal Council (in Switzerland) or any other relevant authority, as applicable;
- to persons and undertakings based in the United States if they are part of the EU-U.S. Data Privacy Framework which requires them to provide similar protection to personal data shared between the EEA and the United States, as well as between the UK and the United States pursuant to the Data Protection (Adequacy) (United States of America) Regulations 2023 for the UK Extension to the EU-U.S. Data Privacy Framework (the UK-US Data Bridge) and between Switzerland and the United States pursuant to the Swiss-US Data Privacy Framework;
- to persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the European Commission, the relevant Secretary of State in the United Kingdom, the Ombudsman (in the Cayman Islands), the Federal Council (in Switzerland) or any other relevant authority, as applicable, and as supplemented where and if required; and
- only on one of the conditions allowed under the applicable Data Protection Laws in the absence of (i) a decision by the European Commission, the relevant Secretary of State in the United Kingdom, the Ombudsman (in the Cayman Islands), the Federal Council (in Switzerland) or any other relevant authority, as applicable, that has deemed a country to provide an adequate level of protection for personal data (i.e. an adequacy decision) or (ii) appropriate safeguards such as a contract that is compliant with the model contracts for the transfer of personal data to third countries approved by the European Commission, the relevant Secretary of State in the United Kingdom, the Ombudsman (in the Cayman Islands), the Federal Council (in Switzerland) or any other relevant authority, as applicable.
Further information on specific mechanisms utilised by Systematica Entities transferring personal data outside the EEA, the United Kingdom, the Cayman Islands, Switzerland, Singapore or mainland China and the countries to which such transfer may be made (which may include, but are not limited to The Bailiwick of Jersey, Switzerland, Singapore, the Cayman Islands and the United States, as applicable) may be obtained from the compliance department of SIUK upon request.
Data Security and Retention
To protect personal data from unauthorised access and use, the Systematica Entities take reasonable steps to use technical, administrative, organisational and physical security measures appropriate to the nature of the personal data they are processing. The Systematica Entities generally restrict access to personal data to those employees and agents who have been advised as to the proper handling of such information and who need to know such data in order to operate the business. Given the nature of information security, there is no guarantee that such safeguards will always be successful.
Each Systematica Entity will retain personal data for as long as necessary to fulfil the purposes for which it has been collected. This will include any period of retention required to satisfy any legal, regulatory, taxation, accounting, regulatory or reporting requirement applicable to the relevant Systematica Entity.
In determining the appropriate retention period for any personal data, the relevant Systematica Entity will consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of the data, the purpose for which the relevant data is being processed, the extent to which the purposes for which the relevant data is being processed can be achieved by other means and any applicable legal requirements. Without prejudice to the generality of the forgoing, the Systematica Entities have determined that they will retain records for at least 6 years.
Details of retention periods applicable to personal data subject to the Data Protection Laws are available upon request from the compliance department of SIUK. In some circumstances, a person may request that a Systematica Entity delete any personal data retained by it. Further, in some circumstances, a Systematica Entity may anonymize personal data for research or statistical purposes, in which case such information will no longer be linked to an individual and will not constitute personal data and may be retained and utilised indefinitely without further notice.
Rights of Persons
Under the Data Protection Laws, persons whose data is processed by a Systematica Entity will have certain rights. These rights include the right to access personal data, the right to require correction of personal data, the right to require erasure of personal data in certain circumstances, the right to restrict processing of personal data, the right to require a transfer of personal data, and the right to withdraw consent to the processing of personal data, to the extent applicable. In addition, if the processing of personal data is based on a legitimate interest of a Systematica Entity, a person will have the right to object to the processing of that personal data.
Any person seeking to exercise any such right should contact the compliance department of SIUK. In certain circumstances, the relevant Systematica Entity may charge reasonable fees if any such request is clearly unfounded, repetitive or excessive.
Links to External Websites
Our website may contain links to third party websites. Any access to and use of such third party websites is not governed by this Privacy Notice, but, instead, is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
The California Consumer Privacy Act
The California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”) imposes certain obligations on the Systematica Group and certain funds managed by the Systematica Group (together, “we” or “us”) and grants certain rights to California resident investors (“California Resident,” “you,” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California Resident or a household. It does not include de-identified information, aggregate consumer information or publicly available information (as defined in the CCPA).
Notice at Collection and Use of Personal Information
Personal Information We Collect
Depending on how you interact with us, we may collect the following categories of personal information from or about a California Resident: (i) identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers; (ii) additional information subject to California Civil Code Section 1798.80(e), such as a signature, education information, state identification number, credit card, bank account, assets, account balances, wire instructions, or other financial information; (iii) characteristics of protected classifications under federal or certain state laws, including, gender, age, national origin, citizenship or marital status; (iv) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth; (v) internet or other electronic network activity information, including interactions with our website or use of certain online tools; (vi) geolocation data]; (vii) professional or employment-related information, including occupation, compensation, employer, and title; (viii) inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds; and (ix) sensitive personal information under the CCPA such as your passport number, driver’s license, state identification card, and precise geolocation. We may disclose for a business purpose all or just a few of the above categories of personal information.
Purposes for Collecting and Using Personal Information
We may collect or use your personal information for the following business or commercial purposes: (i) performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions, and withdrawals, verifying information, processing payments or providing similar services; (ii) performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting and other operational matters; (iii) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, anti-terrorist financing, and conflict checks; (iv) enabling or effecting commercial transactions, including, using bank account details to remit funds and process distributions; (v) communicating with you; (vi) administering and improving our website; and (vii) internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
How Long We Keep Information
How long we keep your personal information will vary depending on the type of personal information and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal information). In general, we will retain your personal information for as long as we require it to perform our contractual rights and obligations or for periods required by our legal and regulatory obligations.
Sale or Sharing of Personal Information
We do not sell your personal information (as such terms are defined under the CCPA).
Sources of Personal Information
We may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites. In addition, we may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Disclosure of Personal Information
We do not sell your personal information (as such terms are defined under the CCPA). We do not knowingly sell or share the personal information of California residents under 16 years old.
In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:
| Category of Personal Information | Category of Third Party |
| Identifiers (for example your name, address, DOB, SSN, driver’s license, passport number and online identifiers) | · Counterparties and intermediaries (e.g., broker-dealers) in connection with investments and transactions, regulatory requirements or for operational purposes
· Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund · Professional services organizations, such as auditors or law firms · Providers or partners that support our business operations (such as payment services providers; etc.) |
| Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information) | · Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund
· Professional services organizations, such as auditors or law firms · Providers or partners that support our business operations (such as payment services providers; etc.)
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| Characteristics of protected classifications under certain federal or state laws (for example gender, age, national origin, citizenship or marital status) | · Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund
· Professional services organizations, such as auditors or law firms |
| Commercial Information (for example records of products or services purchased, obtained or considered or purchasing histories or tendencies including funds in which you are invested, investments considered or sources of wealth) | |
| Audio (e.g., voicemail), electronic, visual or similar information | · Professional services organizations, such as auditors or law firms |
In addition, we may disclose and, in the preceding 12 months, we may have disclosed all of the categories of personal information identified in “Personal Information We Collect” above, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in “Purposes for Collecting and Using Personal Information.” Additionally, we may disclose your personal information to third parties upon your request, at your direction or with your consent.
We may disclose or make available your personal information with our service providers such as our administrator, IT providers, or CRM provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in. or as otherwise permitted by, the CCPA.
Use and Disclosure of Sensitive Personal Information
As noted above in “Personal Information We Collect”, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions (“request to delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“right to limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit); (vii) correct inaccurate personal information (“request to correct”) that a business maintains about a consumer; and (viii) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties with whom we share personal information; and (e) the specific pieces of personal information we have collected about you.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information, including, generally, personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit a “request to know”, “request to correct” or a “request to delete” (“Consumer Rights Request”) each as described above, by calling us at +44 020 3180 5700, or through our website at the following link: https://www.systematica.com/contact-us/.
We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. When you submit a Consumer Rights Requests we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, phone number and email address, and we may require you to discuss the request with us over the phone. This measure is in place to help ensure that personal information is not disclosed to any person who does not have the right to receive it. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request. We will deliver responses to verifiable consumer requests, free of charge, either through your online account with one of our service providers, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time and to reflect changes in our personal information practices. We encourage you to review the most current Privacy Policy provided to you.
Contact for More Information
If you have any questions or concerns about this notice, please contact us at .
This Privacy Policy was last updated on 20 December 2024. A copy of the relevant online privacy policy can be found at https://www.systematica.com/.
COOKIES POLICY
This website uses cookies, which are tiny files that are downloaded to your computer or other device to improve your experience. Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure the marketing you see online is more relevant to you and your interests.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed.
This page describes what information the cookies gather, how we use that information and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored; however, preventing the cookies from being stored may downgrade or ‘break’ certain elements of the sites functionality.
THE TYPES OF COOKIES WE USE
There are generally two types of cookies that we use: “Performance” and “Functionality”. The following is a brief description of each cookie category.
1. Performance Cookies. These cookies collect information about how you have used the website, for example, information related to the unique username you have provided. These cookies may also be used to allow us to know that you have logged in so that we can serve you fresher content than a user who has never logged in. We also use cookies to track aggregate website usage and experiment with new features and changes on the website. The information collected is used to improve how the website works.
2. Functionality Cookies. These cookies allow us to remember how you’re logged in, whether you chose to no longer see advertisements, whether you made an edit to an article on the website while logged out, when you logged in or out, the state or history of website tools you’ve used. These cookies also allow us to tailor the website to provide enhanced features and content for you and to remember how you have customized the website in other ways, such as customizing the toolbars we offer in the right column of every page. The information these cookies collect may be anonymous, and they are not used to track your browsing activity on other sites or services.
The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
| Cookie Type | Name | Purpose |
|---|---|---|
| Functionality | disclaimer_agreed | To suppress the Disclaimer after users have dismissed it. |
| Functionality | Cookies_saw | To suppress the cookies notification ribbon after users have dismissed it |
| Functionality | Notification | To suppress notification pop-up from reappearing on the landing page. |
DISABLING COOKIES
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site.
THIRD PARTY COOKIES
In some cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
From time to time we may test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimizations our users appreciate the most.
MORE INFORMATION
For more information please contact us through our preferred contact method.
Email:
COOKIES POLICY
This website uses cookies, which are tiny files that are downloaded to your computer or other device to improve your experience. Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure the marketing you see online is more relevant to you and your interests.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed.
This page describes what information the cookies gather, how we use that information and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored; however, preventing the cookies from being stored may downgrade or ‘break’ certain elements of the sites functionality.
THE TYPES OF COOKIES WE USE
There are generally two types of cookies that we use: “Performance” and “Functionality”. The following is a brief description of each cookie category.
1. Performance Cookies. These cookies collect information about how you have used the website, for example, information related to the unique username you have provided. These cookies may also be used to allow us to know that you have logged in so that we can serve you fresher content than a user who has never logged in. We also use cookies to track aggregate website usage and experiment with new features and changes on the website. The information collected is used to improve how the website works.
2. Functionality Cookies. These cookies allow us to remember how you’re logged in, whether you chose to no longer see advertisements, whether you made an edit to an article on the website while logged out, when you logged in or out, the state or history of website tools you’ve used. These cookies also allow us to tailor the website to provide enhanced features and content for you and to remember how you have customized the website in other ways, such as customizing the toolbars we offer in the right column of every page. The information these cookies collect may be anonymous, and they are not used to track your browsing activity on other sites or services.
The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
| Cookie Type | Name | Purpose |
|---|---|---|
| Functionality | disclaimer_agreed | To suppress the Disclaimer after users have dismissed it. |
| Functionality | Cookies_saw | To suppress the cookies notification ribbon after users have dismissed it |
| Functionality | Notification | To suppress notification pop-up from reappearing on the landing page. |
DISABLING COOKIES
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site.
THIRD PARTY COOKIES
In some cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
From time to time we may test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimizations our users appreciate the most.
MORE INFORMATION
For more information please contact us through our preferred contact method.
Email: