Legal Information

This Website is provided by Samson Rock Capital LLP and Samson Rock Capital LLC (collectively, “Samson Rock”).

By accessing or using this Website, you accept and agree to comply with these Terms and Conditions of Use (“Terms”). These Terms are a binding agreement between you and Samson Rock, and govern your access and use of this Website, which includes any text, graphics, user interfaces, information, data, tools, products, services and other content (collectively, the “Content”) available on or through this Website. You may contact Samson Rock by e-mail at src.legal@samsonrock.com with any questions about these Terms.

1. Use of this Website

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

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

2. Intended Recipients

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

   In the United Kingdom, this Website is directed only at persons who are: (i) investment professionals within the meaning of Article 19 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (“FP Order”); (ii) high net worth companies and certain other entities falling within Article 49 of the FP Order; or (iii) any other persons to whom such communication may lawfully be made. It must not be used by, or relied upon, any other persons.

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

3. No Offer or Solicitation

   This Website is not intended and must not be construed as an offer or solicitation to purchase, or an offer to sell, shares of any fund or another investment product mentioned on this Website (“Investment”) in any jurisdiction. In particular, this Website is not intended as premarketing or marketing of any alternative investment fund in any member state of the European Economic Area for the purposes of the EU Directive 2011/61/EU on Alternative Investment Fund Managers; the Directive (EU) 2019/1160 on Cross-border Distribution of Collective Investment Undertakings or Regulation (EU) 2019/1156 on facilitating cross-border distribution of collective investment undertakings. Any offer of Investment will only be made on the basis of the prospectus or offering memorandum relating to the relevant Investment. PROSPECTIVE INVESTORS SHOULD REVIEW THE PROSPECTUS OR OFFERING MEMORANDUM, INCLUDING THE RISK FACTORS, BEFORE MAKING A DECISION TO INVEST. Prospective investors should rely only on the prospectus or offering memorandum in making a decision to invest, even if certain descriptions contained on this Website may be more detailed than those contained in the relevant prospectus or offering memorandum. Subscriptions may only be made on the terms of the relevant prospectus or offering memorandum and subject to completion of a subscription agreement. In addition, any Investment or transaction will be subject to applicable legal and regulatory restrictions, including the prospective investor meeting applicable eligibility criteria.

4. Nature of the Content

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

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

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

5. Certain Risks

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

6. Limitations of Liability

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

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

7. Indemnification

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

8. Third Party Websites

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

9. Intellectual Property and Copyright

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

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

10. Amendments to these Terms

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

11. Law and Jurisdiction

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

Samson Rock Capital LLP

Stewardship Code Disclosure

The Stewardship Code (“the Code”), published by the Financial Reporting Council, sets out principles of engagement for professional investors in relation to the companies in which they invest. The Financial Conduct Authority (“FCA”) requires Samson Rock LLP (“Samson Rock” or the “Firm”) to disclose the nature of its commitment to the Code or, where it does not commit to the Code, its alternative approach to this.

The Code aims to enhance the quality of engagement between asset managers and companies to help improve long-term risk-adjusted returns to shareholders and promote the efficient exercise of governance responsibilities, and, effective from 1 January 2020, has been updated to apply to a broader range of investment strategies, other than purely listed equity, and to reflect the growth of environmental factors, particularly climate change, as well as social and governance factors (together, “ESG”) as material issues for asset managers to consider when making investment decisions and undertaking stewardship.

Adherence to the Code is voluntary. As a FCA authorised, Samson Rock has a fiduciary duty to act in the best interests of its clients. The Firm aims to generate and protect returns in accordance with the relevant fund private placement memorandum.

Although Samson Rock supports the overall objectives of the Code, it has chosen not to commit to the Code for the following reasons:

• Samson Rock pursues an event-driven strategy and invests globally in equityrelated instruments. Within this investment universe and only in a small minority of cases, the Firm has infrequent and limited interaction with the management of companies with whom it invests on behalf of its clients.

• The nature of the Firm’s investment strategy does not allow it to systematically and formally engage with investee companies through voting rights.

• The Firm’s investment time horizon is short to medium term in nature.

As such, Samson Rock considers it appropriate not to commit to the Code. This policy will be kept under review.

Shareholder Rights Directive II (“SRD II”) Disclosure

SRD II aims to improve stewardship and corporate governance by firms including full scope Alternative Investment Fund Managers (“AIFMs”) that invest in shares traded on a regulated market in the European Economic Area (“EEA”) as well as ‘comparable’ markets situated outside of the EEA.

In accordance with FCA’s Conduct of Business Sourcebook (“COBS”) 2.2B.5R, Samson Rock is required to either develop and publicly disclose an engagement policy that meets the requirements of or to publicly disclose a clear and reasoned explanation of why it has chosen not to develop an engagement policy that meets the SRD II requirements.

Samson Rock has decided that, whilst it supports the aims of SRD II, it has chosen not to comply with the Directive at present. Samson Rock pursues an equity event driven, European focused, market neutral strategy with an active trading approach. Its investment strategy involves medium and short-term investment. The Firm does not seek to engage with investee companies in the manner envisaged by SRD II and Samson Rock does not consider that it would be constructive for the Firm or its investee companies if the Firm were to actively engage with them.

For further details on any of the above information, please contact src.compliance@samsonrock.com

Pillar 3 Disclosure

Introduction

Regulatory Context

The Pillar 3 disclosure for Samson Rock Capital LLP (“Samson Rock” or the “Firm”) has been prepared in accordance with the Capital Requirements Directive (Directive 2103/36/EU) (“CRD IV”), as transposed by the Financial Conduct Authority (“FCA”) in its Prudential Sourcebook for Banks, Building Societies and Investment Firms (‘BIPRU’) specifically, BIPRU 11.

The regulatory framework consists of three ‘Pillars’:

• Pillar 1 sets out the minimum capital amount that meets Samson Rock’s relevant risks.

• Pillar 2 requires Samson Rock to assess whether its Pillar 1 capital is adequate to meet its risks. This is achieved through the Samson Rock’s Internal Capital Adequacy Assessment Process (ICAAP) and is subject to an annual review by the Firm’s Executive Committee.

• Pillar 3 seeks to encourage market discipline by requiring firms to disclose certain information on their risks, capital and risk management processes for the benefit of the market.

The principal purpose of this document is to satisfy our regulatory disclosure requirements and to promote transparency between Samson Rock and other market participants.

Verification

The disclosures have not been audited and do not form part of the annual audited financial statements and should not be relied upon in making any judgement about the financial position of Samson Rock.

Any disclosures, relating to profitability and remuneration, refer to the Firm’s most recently completed financial year i.e. 1 July 2020 – 30 June 2021.

Any disclosures, relating to capital resources and requirements, refer to the quarter-end following the Firm’s most recently completed financial year i.e. 30 September 2021.

Frequency

The Pillar 3 disclosure is updated on an annual basis, and more frequently as appropriate.

Materiality

The firm regards information as material if its omission could change the assessment of a user relying on that information for the purpose of making economic decisions. If the Firm deems a certain disclosure to be immaterial, it may be omitted from this statement.

Confidentiality

The Firm regards information as proprietary if sharing that information with the public would undermine its competitive position. Further, information is considered confidential where there are obligations binding the Firm to confidentiality with its clients, suppliers and counterparties. If the Firm deems a certain information to be confidential, it may be omitted from this statement.

BIPRU 11.5.1 Disclosure: Risk Management Objectives and Policies

The Firm has a risk management objective to develop policies, systems and controls to mitigate risk within its risk appetite.

Samson Rock’s Executive Committee is ultimately responsible for the management of the business, including defining the Firm’s business strategy and risk appetite.

The Executive Committee:

• Oversees and manages Samson Rock’s other Committees;

• Adopts and periodically reviews the Firm’s governance frameworks; and

• Acts as the ultimate escalation point on all matters concerning the business.

The Risk Committee proposes frameworks and acts as an initial escalation point for market, credit/counterparty and liquidity risk types.

The Firm’s operational and regulatory risks are managed by the Firm’s Operating Committee.

The Firm’s Investment Committee is responsible for capital allocation and strategic changes to the portfolio management risk framework.

Samson Rock’s Chief Risk Officer/Chief Operating Officer (“CRO/COO”), with the support of the compliance and operations teams, is responsible for the implementation and enforcement of the Firm’s Risk Management Policy.

Executive Committee members are updated on risk issues on a regular basis.

BIPRU 11.5.2 Disclosure: Scope and Application of the Requirements

Samson Rock is authorised and regulated by the FCA and as such is subject to minimum regulatory capital requirements. The Firm is categorised as a Collective Portfolio Management Investment Firm (“CPMI”) Firm by the FCA for capital purposes.

Samson Rock is a full-scope UK Alternative Investment Fund Manager (“AIFM”) of a non-EEA Alternative Investment Funds (“AIFs”).

The Firm is required to comply with certain requirements applicable to BIPRU firms and is a solo regulated entity.

BIPRU 11.5.3 Disclosure: Capital Resources (Own Funds)

Capital Adequacy is assessed formally and on a regular basis.

As a CPMI Firm and as a full-scope AIFM, Samson Rock is subject to regulatory capital requirements.

As of 30 September 2021, the capital resources of the business consist of Tier 1 capital with no deductions. The total value of the Firm’s Tier 1 capital resources was £1,500,000, comprising of LLP Members’ capital.

BIPRU 11.5.4 Disclosure: Compliance with BIPRU 3, BIPRU 4, BIPRU 7 and the overall Pillar 2 rule

BIPRU 3 Credit Risk

The Firm is exposed to credit risk through its cash deposits and debtors.

Samson Rock calculates the credit risk under the simplified approach (BIPRU 3.5) i.e. 8% of the risk weighted credit exposure.

BIPRU 4 The IRB Approach

The Firm does not adopt the Internal Ratings Based (“IRB”) approach and therefore, this is not applicable.

BIPRU 7 Market Risk

The Firm’s market risk is primarily limited to foreign exchange risk, due to management and performance fees being received in currencies other than its base currency, and any related hedging activity.

Overall Pillar 2 Rule

The Firm’s ICAAP includes a forward-looking assessment of the risks that the Firm might be subject to in periods of stress. The ICAAP is formally reviewed by the Executive Committee annually and will be revised should there be any material changes to the Firm’s business or risk profile.

BIPRU 11.5.5

This disclosure applies to firms adopting the IRB approach to credit risk set out in BIPRU 11.5.4R (3) therefore, this is not applicable.

BIPRU 11.5.6

This disclosure applies to firms adopting the IRB approach to credit risk set out in BIPRU 11.5.4R (3) therefore, this is not applicable.

BIPRU 11.5.7

This disclosure is not required as the Firm does not maintain a Trading Book.

BIPRU 11.5.8 Disclosure: Credit Risk and Dilution Risk

The number and magnitude of credit exposures relating to the Firm’s business is limited.

The Firm considers that the risk of default by its clients with respect to payments of management and performance fees is immaterial. Additionally, all material cash resources are held at financial institutions with high credit quality.

Under the simplified approach, the Firm calculated its total credit risk requirement to be £70,000.

BIPRU 11.5.9

This disclosure is not required as the Firm does not make Value Adjustments and Provisions for Impaired exposures that need to be disclosed under BIPRU 11.5.8R (9).

BIPRU 11.5.10 Disclosure: Firms calculating risk weighted exposure amounts in accordance with the standardised approach

This disclosure is not required as the Firm uses the simplified method of calculating Risk Weights (BIPRU 3.5).

BIPRU 11.5.11 Disclosure: Firms calculating risk weighted exposure amounts using the IRB approach

This disclosure is not required as the Firm has not adopted the IRB approach for calculating Risk Weights.

BIPRU 11.5.12 Disclosure: Market Risk

In respect of its business activities, the Firm has non-trading book exposure to foreign currencies, i.e. cash deposits held in foreign currencies and other assets or liabilities held in foreign currencies, such as debtors, on the Firm’s balance sheet (BIPRU 7.5.).

Under the simplified approach, the Firm calculated its total market risk requirement to be £42,000.

BIPRU 11.5.13 Disclosure: Use of VaR model for calculation of market risk capital requirement

This disclosure is not required as the Firm does not use a VaR model for calculation of Market Risk Capital Requirement.

BIPRU 11.5.15 Disclosure: Non-trading book exposures in equities

This disclosure applies to credit institutions operating a Trading Book as such, this disclosure is not required as the Firm does not have a Non-Trading Book Exposure to Equities.

BIPRU 11.5.16 Disclosure: Exposures to interest rate risk in the non-trading book

This disclosure applies to credit institutions operating a Trading Book. The Firm does not have material exposure to interest rate risk. The Firm has no external borrowings and cash deposits earn/pay fixed interest rates. The income/expense relating to interest is immaterial.

BIPRU 11.5.17 Disclosure: Securitisation

This disclosure applies to credit institutions operating a Trading Book. Thus, this disclosure is not required as the Firm does not securitise its assets.

BIPRU 11.5.18R Disclosure on Remuneration

The Firm is required to disclose certain information, at least annually, regarding its Remuneration Policy and practices with respect to Code Staff i.e. Senior Managers and risk takers whose professional activities may have a material impact on the risk profile of the Firm.

Samson Rock’s disclosure is made in accordance with its size, internal organisation and the nature, scope and complexity of its activities.

Samson Rock does not have a separate remuneration committee. The Firm’s Remuneration Policy and practices are overseen by its Executive Committee.

The Firm’s ability to award variable remuneration is dependent on the overall performance of the Firm and on the individual/team’s performance. All variable remuneration is adjusted in line with capital and liquidity requirements.

The aggregate remuneration for Code Staff for the financial year ending 30 June 2021 was £30,412,695.

Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Samson Rock Capital LLP (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

How we collect information about you

We may collect personal data about you through:

• information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;

• information that we obtain in relation to any transactions between you and us;

• recording and monitoring of telephone conversations and electronic communications with you as described below; or

• the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.

Why we collect information about you

We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

What are the consequences of failing to provide your personal information?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

The types of personal data we may collect and use

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials (including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health).

Do we use automated decision-making processes?

No.

Do we share your personal information with third parties?

We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

• our affiliates or other entities that are part of our group or with our clients;

• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;

• our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;

• service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;

• credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;

• any person, as directed by you; or

• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

Transfers of personal information to countries outside of the European Economic Area (EEA)

Due to the international nature of our business, your personal data may be transferred to countries outside of the united Kingdom, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the UK General Data Protection Regulation, the Data Protection Act 2018 or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

For how long do we keep your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

What are your rights?

You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

• to request access to your information;

• to request rectification of inaccurate or incomplete information;

• to request erasure of your information (a “right to be forgotten”);

• to restrict the processing of your information in certain circumstances;

• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);

• where relevant, to request the portability of your information;

• where you have given consent to the processing of your data, to withdraw your consent; and

• to lodge a complaint with the competent supervisory authority.

How to contact us

If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Chief Marketing Office by telephone on 44 203 994 1803 by email at src.legal@samsonrock.com or by writing to Samson Rock Capital LLP, 2 Stephen Street, London, W1T 1AN, United Kingdom.

Complaining to ICO

You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.

Use of cookies

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

Recording and monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of:

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

• ensuring compliance with our regulatory obligations; or

• detecting and preventing the commission of financial crime.

Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.