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Cookie Policy


IMPORTANT INFORMATION

Before you access the Stewart Investors website, we would like you to read &
understand some important information about the site, what data we collect and
how we use it. This information is set out in the terms and conditions below:

1. Important Information

2. Privacy Notice

3. Cookie Policy

Scroll down to view the relevant policy.

1. Important Information

It is important that you read this page. The use of www.stewartinvestors.com
(this “Website”) is subject to the following terms and conditions (the “Terms”).
After you have read and understood these Terms, you may click “I Agree” to
confirm that you agree to the Terms which create a binding legal agreement
between us. If you do not agree to these Terms, please refrain from using this
Website.

IMPORTANT INFORMATION ABOUT ACCESS TO THIS WEBSITE

This Website and the information on it is communicated by Stewart Investors
which is a trading name of First Sentier Investors (UK) Limited (when
communicating in the UK), which is authorised and regulated by the Financial
Conduct Authority of the United Kingdom, and of of First Sentier Investors
(Ireland) Limited (when communicating within the European Economic Area (EEA)) ,
which is authorised and regulated by the Central Bank of Ireland, and of First
Sentier Investors International IM Limited (when communicating outside the UK
and EEA) which is authorised and regulated by the Financial Conduct Authority of
the United Kingdom. This Website uses cookies as described in paragraph 16 of
these Terms and by agreeing to these Terms you consent to the use of cookies as
described in that paragraph.

In the UK, this website is issued by First Sentier Investors (UK) Funds Limited
which is authorised and regulated by the Financial Conduct Authority
(registration number 143359). Registered office Finsbury Circus House, 15
Finsbury Circus, London, EC2M 7EB number 2294743. In the EEA, this website is
issued by First Sentier Investors (Ireland) Limited which is authorised and
regulated in Ireland by the Central Bank of Ireland (registered number C182306)
in connection with the activity of receiving and transmitting orders. Registered
office: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland, number 629188.

This Website (and the information on it) is directed only at persons who are
Professional Clients or Eligible Counterparties for the purposes of the Markets
in Financial Instruments Directive (“MiFID”) or as otherwise defined under
applicable local regulations and at whom this Website (and any information on
it) may lawfully be directed in any relevant jurisdiction. Access to this
Website is not open to persons resident in, or citizens of any territory where,
to allow such access would require any registration, filing, application for any
licence or approval or other steps to be taken by Stewart Investors in order to
comply with local laws or other regulatory requirements in such overseas
territory. Please contact Stewart Investors if you require any further
information on your status.

Investing involves certain risks including that the value of investments and any
income from them may go down as well as up and are not guaranteed. Investors may
get back significantly less than the original amount invested. For further
information please expand the “Risk Warnings” section below. For a full
description of the terms of investment and the risks please see the Prospectus
and Key Investor Information Document which are available on the First Sentier
Investors UK website: http://www.firstsentierinvestors.com. If you are in any
doubt as to the suitability of our funds for your investment needs, please seek
investment advice.

Following a UK departure from the European Union, First Sentier Investors ICVC
(“OEIC”) has ceased to qualify as a UCITS scheme and is instead an Alternative
Investment Fund (“AIF”) for European Union purposes under the terms of the
Alternative Investment Fund Managers Directive (2011/61/EU). Accordingly, no
marketing activities relating to the OEIC are being carried-out by Stewart
Investors in the European Union (or the additional EEA states) and the OEIC is
not available for distribution in those jurisdictions. This website does not
constitute an offer or invitation or investment recommendation to distribute or
purchase shares in the OEIC in the European Union (or the additional EEA
states).

1. About this Website:

In the UK and outside the EEA, this Website is owned, maintained, operated and
communicated by Stewart Investors. Stewart Investors’ registered office is at
Finsbury Circus House, 15 Finsbury Circus, London, EC2M 7EB. In the EEA this
Website is owned, maintained, operated and communicated by Stewart Investors
which is a trading name of First Sentier Investors (Ireland) Limited which is
authorised and regulated by the Central Bank of Ireland (the “CBI”). First
Sentier Investor’s registered office is at 70 Sir John Rogerson’s Quay, Dublin
2, Ireland number 629188 (CBI registration number C182306). The information on
this Website constitutes a financial promotion and an invitation or inducement
to engage in investment activity and/or a marketing communication.

This Website contains information about investment funds which are offered by
Stewart Investors (the “Funds”) and which are registered, or have otherwise been
notified, for public distribution and marketing in certain jurisdictions in the
European Union / EEA. Please note that the fact of such registration does not
mean that any regulator has determined that such Funds are suitable for all or
any investors. The Funds referred to on this Website may not be suitable
investments for you and you should therefore seek professional investment advice
before making a decision to invest in any of the Funds. A prospectus and Key
Investor Information Document (“KIID”) for each of the Funds is available on
this Website. Contact details of the facilities where such documents are
available are also set out on the web-page for the relevant Fund.

2. Selling Restrictions:

The distribution of the information on this Website may be restricted by law in
certain countries. This Website, and the information on it, are not addressed to
any person resident in the territory of any country or jurisdiction where such
distribution would be contrary to local law or regulation. By choosing to view
or make use of this Website you do so on the basis that you have informed
yourself of any regulatory or other consequences of your doing so.


3. No Advice:


The information on this Website is provided for information only and does not
constitute, and should not be construed as, investment advice or a
recommendation to buy, sell or otherwise transact in any investment including
the Funds. The information on this Website is provided solely on the basis that
you will make your own investment decisions and Stewart Investors has not taken
any account of your particular investment objectives or financial situation in
preparing the information on this Website. In addition, nothing in this Website
shall, or is intended to, constitute financial, legal, accounting or tax advice.
We strongly recommend that you seek professional investment advice before making
any investment decision. Stewart Investors neither provides investment advice
to, nor receives and transmits orders from, investors in the Funds.

Stewart Investors neither provides investment advice to, nor receives and
transmits orders from, investors in the Funds nor does it carry on any other
activities with or for such investors that constitute “Regulated Activities”,
“investment services” or “ancillary services” for the purposes of the Financial
Conduct Authority Rules.

4. Price and Performance Information:

All prices provided on this Website are indicative only. Such prices or values
may not reflect actual prices or values that would be available in the market at
the time provided or at the time you may decide to purchase or sell an interest
in a particular Fund. Stewart Investors accepts no responsibility for updating
such price information.

Past performance is not a reliable indicator of future performance. The value of
investments and the income from them can go down as well as up and investors may
not get back the amount originally invested and may lose all of their
investment. Exchange rate changes may cause the value of overseas investments to
rise or fall. To the extent that any information on this Website refers to a
particular tax treatment, such treatment depends on the individual circumstances
of the investor and may be subject to change in the future.

5. Risk Warnings:

Any investment involves substantial risks. Further information about the types
of risks associated with investment in the Funds referred to on this Website can
be found on the First Sentier Investors website:
http://www.firstsentierinvestors.com

The offering documents for each Fund (available on the above website) also
contain risk warnings which are specific to the relevant Fund and which you
should consider carefully before taking any decision to invest.

6. Offering Documents:

The terms of any investment in a Fund are governed by the documents establishing
such terms. In the event of any inconsistency between the information on this
Website and the terms specified in, or established pursuant to, the documents
establishing the terms of issue or contract, the terms so specified or
determined shall prevail. An application for interests in any of the Funds
should only be made having fully and carefully read the relevant prospectus, the
latest financial reports and other offering documents for the relevant Fund
which are available on this Website and upon request from the fund
representative in your jurisdiction.

7. Information on this Website:

Information on this Website: Stewart Investors has taken reasonable care to
ensure that the information contained on this Website is accurate, current,
complete, fit for its intended purpose and compliant with relevant legislation
and regulations and, where applicable, the laws of the country of your residence
as at the date of issue. However, errors or omissions may occur due to
circumstances beyond Stewart Investors’ control and no warranty is given, or
representation made, regarding the accuracy, validity or completeness of the
information on this Website and no liability is accepted by such persons for the
accuracy or completeness of such information. You must conduct your own due
diligence and investigations rather than relying on any of the information in
this Website. Any person who acts upon, or changes his or her investment
position in reliance on, the information contained on this Website does so
entirely at his or her own risk.

Information posted on this Website is current only as at the date it is first
posted and may no longer be true or complete when viewed by you. Stewart
Investors cannot guarantee that content will be accurate, complete and current
at all times. To the extent that any information on this Website relates to a
third party, such information has been provided by that third party and is the
sole responsibility of such third party and Stewart Investors accepts no
liability for such information. All content on the Website is subject to
modification from time to time without notice. Please contact Stewart Investors
for further information regarding the validity of any information contained on
this Website.


To the extent that this Website contains any expression of opinion or forecast,
such opinion or forecast is based on sources believed by Stewart Investors to be
reliable, but is not guaranteed or warranted as to its current validity,
accuracy or completeness. Opinions expressed represent the opinions of Stewart
Investors at the date of publication only, reflecting prevailing market
conditions and certain assumptions (which may not prove to be valid), are
subject to change and should not be relied on by users of the Website.

Certain content (the “Restricted Content”) on this Website including, but not
limited to, webcasts shall be made available only on the granting of permission
by Stewart Investors or a third party appointed by Stewart Investors. Stewart
Investors reserves the right, in its absolute discretion, not to grant access to
such Restricted Content. Where you are granted access to such Restricted
Content, such access is granted for your personal use only. You must treat this
Restricted Content as confidential and you must not disclose it to any third
party or allow any third party to access such Restricted Content. Stewart
Investors may revoke access to the Restricted Content in its absolute discretion
at any time without notice.

8. Material Interests:

Stewart Investors, its affiliates and its or their directors, officers,
employees or agents may have holdings in the Funds and/or underlying investments
of the Funds and may otherwise be interested in transactions in those Funds.
Further details about the policies that Stewart Investors has adopted in order
to avoid or to manage such conflicts in a way that ensures fair treatment for
Stewart Investors’ clients are available from Stewart Investors on request.

9. Linked Websites:

Links to websites operated by third parties are provided for information only
and do not constitute any form of advice, endorsement or recommendation of such
websites or the material on them. Stewart Investors accepts no responsibility
for information contained on any other sites which can be accessed by hypertext
link from this Website or for these sites not being available at all times.
Stewart Investors has not reviewed, and will not review or update, such websites
or information and any use that you make of such websites and information is at
your own risk. Please note that when you click on any external site hypertext
link you will leave this Website.

10. Liability:

No warranty is given that the contents of this Website are compatible with all
computer systems or browsers or that this Website shall be available on an
uninterrupted basis. Stewart Investors does not accept any liability for any
damages or losses arising from changes or alterations made to this Website by
unauthorised third parties.

The internet is not a completely reliable transmission medium and neither
Stewart Investors nor any of its affiliates accept any liability for any data
transmission errors such as data loss or damage or alteration of any kind or for
the security or confidentiality of information transmitted across the internet
to or from Stewart Investors or any of its affiliates. Any such transmission of
information is entirely at your own risk and any material downloaded from this
Website is downloaded at your own risk.

The information on this Website is provided “as is”. To the extent permitted by
law, Stewart Investors, its affiliates and its and their directors, officers,
employees and agents expressly exclude all conditions, warranties,
representations and other terms which might otherwise be implied by statute,
common law or the law of equity. Stewart Investors and its affiliates will only
be liable to you in respect of any direct losses arising from your use of, or
inability to use, this Website in the event of Stewart Investors’ gross
negligence, wilful default or fraud. In no event will Stewart Investors or any
of its affiliates be liable to any person for any indirect, special or
consequential damages arising out of any use of, or inability to use, this
Website or the information contained on it or on any other hyper-linked site
including, without limitation, any lost profits, business interruption, loss of
programs or data on your equipment or otherwise, even if Stewart Investors is
expressly advised of the possibility or likelihood of such damages. This does
not affect Stewart Investors’ liability for any loss or damage which cannot be
excluded or limited under applicable law. Nothing in these Terms is intended to
exclude or restrict any duty or liability that Stewart Investors has to its
clients under applicable local regulatory rules or which may not be excluded or
restricted as a matter of applicable law.


11. Access:

Stewart Investors reserves the right to suspend or withdraw access to any
page(s) included on this Website without notice at any time and accepts no
liability if, for any reason, these pages are unavailable at any time or for any
period.

12. Compliance with Law and Regulation:

When using this Website you must comply with all applicable local, national and
international laws including those related to data privacy, international
communications and exportation of technical or personal data. It may be illegal
to download the information contained on this Website in certain countries and
Stewart Investors, its affiliates and its and their directors, officers,
employees and agents disclaim all responsibility if you download any information
from this Website in breach of any law or regulation of the country in which you
reside.

13. Intellectual Property:


(a) Unless otherwise specified, Stewart Investors is the owner or the licensee
of all intellectual property rights in and to this Website, its content and the
information, imagery and data published on it including but not limited to
copyright and trade mark rights (whether registered or unregistered). Those
works are protected by copyright laws and treaties around the world. All such
rights, save as expressly granted, are reserved.

(b) Notwithstanding paragraph (a) above, no warranty or indemnity is given that
the use of the Website, or any information or material taken or downloaded from
the Website will not infringe the intellectual property rights of any third
party.

(c) Reproduction in any form of any part of the content, information, imagery or
data from, or underlying, this Website, save for in strict compliance with these
Terms, is prohibited without the prior written consent of Stewart Investors. All
such intellectual property rights shall continue to be held by Stewart Investors
or its licensors and no rights of any kind in such rights shall pass to you.

(d) The information held on this Website is for your own personal use only. You
may print off or download copies of, or extracts from, pages from this Website
for your personal reference but you must not modify those copies or extracts in
any way. Stewart Investors (and any identified contributors), as the authors of
material on this Website, must always be acknowledged.

(e) Notwithstanding paragraph (d) above, to the extent that you are a financial
advisor, you may use the information available on this Website and provide
copies of documents available on the Website to make recommendations to your
clients, however such information is not intended for direct use by members of
the public.

(f) Any unauthorised downloading, re-transmission or other copying or
modification of any of the contents of the Website may be in breach of statutory
or common law rights which could be the subject of legal action. Stewart
Investors disclaims all liability which may result from any unauthorised
reproduction or use of the information on the Website.

(g) All trade marks, service marks, company names or logos are the property of
their respective holders. The display of any trade names or trade marks on the
Website does not imply that any licence has been granted to any third party in
respect of the same. Any use by you of these marks, names and/or logos may
constitute an infringement of the holders’ rights.

14. The Internet:

Please note that there is no guarantee that any e-mail sent by you will be
received by us, or that the contents of any such e-mail will remain private
during internet transmission. Any information is sent at your own personal risk.

15. Data Protection:

Please see our Privacy Notice for information relating to how Stewart Investors
and other companies associated with it protect your personal data. In agreeing
to these Terms you agree to the terms of our Privacy Notice.

16. Cookies:

Cookies are small data files that are sent to and stored on your computer,
smartphone or other device used to access the internet, whenever you visit a
website. We use cookies to enable and improve certain functions on our website
and gain feedback on how our website is used. If you choose to switch certain
cookies off, it will affect how our website works.

Cookies are useful because they allow a website to recognise the device you are
using. As Stewart Investors and its associated companies are based in various
jurisdictions and operate different websites for each regional business, we use
cookies to store general information such as the region where you are based, the
language the site is being viewed in (for example English, Chinese) and the type
of client you are. This helps us to tailor our website to better suit your
requirements. The Cookies we use here are ‘session’ cookies and will be removed
every time you leave our website.

When you enter our website, you will be asked to accept some Terms and
Conditions and a Cookie will remember if you have accepted them. This means that
you don’t have to re-accept them on every visit. The Cookies we use here are
‘persistent’ as they remember your preferences. Every time we amend our Terms
and Conditions, or on an annual basis, a new Cookie will be set and you will be
asked to re-accept our Terms and Conditions.


We use analytics cookies to collect information on website activity (such as the
number of users who visit our website, the date and time of visits, the number
of pages viewed, navigation patterns, what country and what systems users have
used to access the site and, when entering our website from another website, the
address of that web site). This information on its own does not identify an
individual but it does provide us with statistics that can be used to analyse
and improve our website. These Cookies are ‘session’ cookies.


The browsers of most computers, smartphones and other web–enabled devices are
usually set up to accept cookies. If your browser preferences allow it, you can
configure your browser to accept all cookies, reject all cookies, or notify you
when cookies are set. Each browser is different, so check the "Help" menu of
your browser to learn about how to change your cookie preferences.
However, please remember that cookies are often used to enable and improve
certain functions on our website. If you choose to switch certain cookies off,
it will affect how our website works and certain functionality may not work.

More information about cookies can be found on allaboutcookies.org.

17. Amendment:

Stewart Investors may delete or make changes to these Terms and to the
information contained on this Website at any time. Where we make any changes to
these Terms, you will be required to accept such changes in order to continue to
use the Website. If you do not accept such revised Terms, you may no longer be
able to access this Website.

If any provision of these Terms is found by any court or authority of competent
jurisdiction to be illegal, void or invalid under the laws of any jurisdiction,
the legality, validity or enforceability of the remainder of these Terms in that
jurisdiction shall not be affected and the legality, validity and enforceability
of the whole of these Terms in any other jurisdiction shall not be affected.

19. Third Parties:

Stewart Investors’ affiliates shall have the benefit of the rights conferred on
them by these Terms but otherwise no person who is not a party to these Terms
may enforce its terms.

19. Applicable Law:

These Terms and any non-contractual obligations arising from or connected with
them shall be governed by, and these Terms shall be construed in accordance
with, the laws of England and Wales.

20. Jurisdiction:

You agree that in the UK and outside the EEA that English courts shall have
exclusive jurisdiction and in the EEA that Irish courts shall have exclusive
jurisdiction in relation to any legal action or proceedings arising out of or in
connection with these Terms (whether arising out of or in connection with
contractual or non-contractual obligations) (“Proceedings”) and waive any
objection to Proceedings in such courts on the grounds of venue or on the
grounds that Proceedings have been brought in an inappropriate forum. You
further agree that this paragraph operates for the benefit of Stewart Investors
and accordingly Stewart Investors shall be entitled to take Proceedings in any
other court or courts having jurisdiction.

21. Contact Us:

If you have any enquiries in relation to this Website or the information on it,
please contact Stewart Investors at enquiries@stewartinvestors.com

By clicking “I Agree” you:
(1) represent, warrant and undertake to us that you are resident in the country
selected when entering this Website;
(2) confirm that you have read and understood the Terms and agree to abide by
them on every occasion that you access this Website;
(3) confirm that you are accessing this Website in compliance with the laws and
regulations of your jurisdiction; and
(4) confirm you have read and understood our Privacy Notice .

Please click the "I have read and agree to the above information" button below
if you have read and understood this page and agree to abide by its contents,
otherwise click "Cancel" to leave the website.


2. PRIVACY NOTICE

Stewart Investors

Background


This Notice gives information on how the Stewart Investors group of companies
collect, use and protect the personal data held about investors, clients,
intermediaries and other business contacts.

This Notice describes how we will fulfil our obligations under applicable data
protection laws.

Information about us

Stewart Investors is a trading name for the companies listed below. References
in this Notice to Stewart Investors will include the following companies as well
as the EU and UK based group company investment funds that they manage (as
applicable):

First Sentier Investors (UK) Funds Limited*

First Sentier Investors (UK) IM Limited*

First Sentier Investors (UK) Services Limited

First Sentier Investors Europe Holdings Limited

First Sentier Investors International IM Limited*

First Sentier Investors (Ireland) Limited**

(together “we”, “us” or “our”)

*Authorised and regulated by the Financial Conduct Authority of the United
Kingdom

**Authorised by the Central Bank of Ireland

Information we may collect

Stewart Investors collects from time to time, personal data on investors,
clients, intermediaries and other business contacts from a number of sources,
including from: investor application forms; other Stewart Investors forms
(including website forms); client investment management agreements;
correspondence, conversations with clients, advisers, intermediaries; business
cards; third party service providers to our funds (for example, transfer agents,
administrators, distributors, custodians, paying agents); client advisers; other
third parties; and from public sources. This information may be collected
directly from investors, clients, intermediaries and business contacts, or
indirectly from third parties, as follows:

From you

We may collect from you and process the following personal data, depending on
the nature of our business relationship with you:

 * Your name; address (including proof of name and address); photo
   identification; contact details both personal and work (for example, your
   email and phone numbers); hobbies and interests; job title and company;
   nationality; citizenship; tax residency; date of birth; passport details;
   national insurance number and other tax details; adviser details; investment
   details; banking details; signed contracts with you; business cards, contact
   sheets and biographies; financial dealings; family connections; details of
   your company’s directors, secretaries, authorised signatories and
   identification documents; details of any complaints made; data received from
   due diligence activities (such as anti-money laundering, politically exposed
   persons and sanctions checks); responses to surveys and competitions; fraud
   enquiries (for example, information from police reports); images captured by
   CCTV cameras on our premises; recordings of telephone conversations and
   electronic communications with our staff.

 * By the use of cookies on this site in accordance with our Cookies Policy set
   out below.

From third parties

We may collect personal data about you from third parties, depending on the
nature of our business relationship with you, in particular:

 * Third party service providers to our funds (for example, transfer agents,
   registrars, administrators, distributors, custodians and paying agents) –
   information received includes personal details of investors obtained from
   fund application forms such as: name; address; contact details; nationality;
   national insurance number; date of birth; tax residency; adviser details;
   investment details; bank account details.

 * Your advisers (including independent financial advisers) – information
   received may include your name, address, gender, date of birth; bank details.

 * Our vendors such as Experian and World-Check – information received includes
   the results of “Know Your Client”, anti-money laundering, politically exposed
   persons and sanctions checks.

 * Publically available sources such as MandateWire and LinkedIn – information
   available includes contact details of institutional investors (MandateWire)
   and details of job title, company, former employers and roles, and
   connections (LinkedIn).

How we will use the information we collect

The information we collect and use will depend on the nature of our business
relationship with you, as follows:

 * In relation to prospective investors and clients, we may process personal
   data for identification purposes (prior to becoming an investor in our funds
   or a client of ours under an investment management agreement), for the
   purposes of anti-money laundering, counter terrorist financing, suitability
   and appropriateness assessments, “Know Your Client” and credit-worthiness
   checks, and for any other applicable legal or regulatory reasons. Failure to
   provide relevant information will mean that we will not be able to on-board a
   potential investor or client.

 * In relation to investors in our funds, we may process information collected
   for the purpose of account administration and other general business purposes
   (for example, for processing subscriptions and investments; maintaining the
   share register of investors, carrying out investor instructions; handling any
   complaints and enquiries; sending investor communications, including
   financial reports, valuations, corporate actions). In addition, in order to
   comply with regulatory obligations, we may collect and disclose certain
   information about our investors and certain related persons and their
   investments to HM Revenue & Customs and/or other relevant tax authorities
   overseas.

 * In relation to our investment management clients, we may process personal
   data for the purpose of managing and administering clients’ accounts,
   including providing valuations and periodic reports and informing clients of
   relevant information as required by the investment management agreement.

 * We may from time to time process personal data of investors and clients to
   comply with legal and regulatory requirements impacting our business. In
   particular, we may need in the context of our business: to obtain legal
   advice on legal and regulatory requirements; to report to relevant
   regulators; to comply with market opening and registration requirements in
   the conduct of our business.

 * In relation to intermediaries who introduce investors into our funds (such as
   distributors, platforms and independent financial advisers), we may process
   personal data to conduct market research, gauge product sales or product
   performance or assess the creditworthiness of intermediaries. In addition, we
   may process the personal data of investors introduced to our funds, as
   outlined above.

 * In relation to our general business contacts (including consultants and
   intermediaries who act for our mutual clients), we may process personal data
   for general business purposes such as: for public relations and corporate
   communications purposes; providing thought leadership articles;
   networking/relationship building; conducting market research and gathering
   industry statistics; evaluating products and services; and assisting with any
   queries.

 * Monitoring purposes: we may process personal data to analyse the performance
   of IT systems, monitor usage of resources and systems and to improve
   products, services and usability of our technology platform, including
   telephone calls and electronic communications with our staff which may be
   recorded for the purposes of retaining a record of communications, in the
   interests of security, for training and compliance monitoring purposes and/or
   to comply with legal or regulatory obligations.

 * Where you have provided your consent, we may process your personal data for
   the purposes of informing you (for example, by telephone, mail and email)
   about other products and services available from Stewart Investors and of
   marketing campaigns and event invitations.

We are entitled to use your personal data in these ways because:

 * We have legal and regulatory obligations that we have to discharge;
 * We may need to in order to establish, exercise or defend our legal rights or
   for the purpose of legal proceedings;
 * The use of your personal data as described is necessary for our legitimate
   business interests (or the legitimate interests of one or more of our
   affiliates);
 * The use of your personal data is necessary for the performance of a contract
   with you;
 * You have provided your consent to us processing your personal data (other
   than for marketing purposes); or
 * You have provided your consent to us processing your personal data for the
   purposes of informing you (for example, by telephone, mail or email) about
   other products and services available from Stewart Investors and of marketing
   campaigns and event invitations.

Disclosure of your information

 * We may disclose your personal data to any member of the Stewart Investors
   group, which means our affiliates, for internal business and administrative
   purposes (including to administer our products and services and for
   prudential and risk management purposes) and, where you have given your
   consent, to provide you with information on related products and services. We
   may also disclose personal data relating to our clients to members of our
   group to whom we sub-delegate our services (for example, trade order
   execution and portfolio management).
 * We may disclose your personal data to third parties that are specifically
   engaged by us to provide services to us, in which case we will require those
   parties to keep that information confidential and secure and to use it solely
   for the purpose of providing the specified services to us. The following is a
   list of the types of third parties who process your personal data on our
   behalf:
   * third party service providers to our funds (for example, transfer agents,
     administrators, distributors, custodians, paying agents and researchers
   * credit reference agencies, debt collection agencies and other companies for
     use in credit decisions, for fraud prevention, to pursue debtors and for
     the verification of identity
   * document execution vendors in relation to the execution of contracts with
     our clients
   * insurance brokers;
   * professional advisers (for example, accountants/tax advisors and legal
     advisors).
 * If you use a financial adviser (as indicated on your investor application
   form), then details of your investments and valuations may also be provided
   to such financial adviser.
   
 * We may disclose to relevant tax authorities, regulators, government
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Transfers outside the EEA

We may transfer your personal data to our overseas affiliates (including outside
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Where we transfer your personal data outside the EEA, we will ensure that it is
protected in a manner that is consistent with how your personal data will be
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protection laws. This can be done in a number of ways, for example:

 * the country that we send the data to might be approved by the European
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 * the recipient might have signed up to a contract based on “model contractual
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 * where the recipient is located in the US, it might be a certified member of
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 * where data protection laws permit us to transfer your personal data outside
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You can obtain more details of the protection given to your personal data when
it is transferred outside the EEA (including a copy of any standard data
protection clauses which we have entered into with recipients of your personal
data) by contacting communications@stewartinvestors.com

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Personal data held by us will be kept confidential. How long we hold your
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If you wish to contact us for any of the reasons below, please e-mail us at
communications@stewartinvestors.com


 * You have a right to access the information which we hold about you. If you
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 * We take reasonable steps to ensure that the personal data we collect, use or
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 * If you have previously consented to being sent information about other
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 * If you have any complaints in relation to the way we have used your
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   5AF (Tel: 0303 123 1113) or, if you are based in the EU or EEA, the Irish
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If you would like to receive further information from us about other products or
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Our web site may contain links to non- Stewart Investors web sites. While such
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ours. You should review any privacy policies on those linked websites. We are
not responsible for any linked websites.

Recording of telephone conversations and electronic communications


Please note that we are required to record telephone conversations (we will do
so without a warning) and to keep copies of electronic communications. We are
required to keep copies of these recordings and electronic communications for a
period of five years (or up to seven years at the request of a regulator).
Copies may be provided to you upon request by contacting
info@stewartinvestors.ie

Changes to our Privacy Notice

This Notice was updated in January 2021. We reserve the right to change this
Notice at any time. We will ensure that any changes to this Notice are added to
the Notice available on our website on their effective date.

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 * Home
 * Stories of sustainable investment
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WE INVEST IN HIGH QUALITY COMPANIES THAT ARE WELL POSITIONED TO CONTRIBUTE TO,
AND BENEFIT FROM, SUSTAINABLE DEVELOPMENT.


SUSTAINABLE FUNDS GROUP

--------------------------------------------------------------------------------

We believe that sustainability is a driver of investment returns and that fully
incorporating sustainability into the investment process is the best way to
protect and grow our clients’ capital over the long-term.

Our investment process is focused on the quality and sustainability positioning
of individual companies, which includes an assessment of a company's management,
financials and franchise.

The integrity and stewardship of company management is central to our assessment
of quality. Similarly, all Stewart Investors investment team members sign our
Hippocratic Oath, which includes the commitment to act in the interests of our
clients and society in that we will not pursue risk adjusted returns to the
extent that our actions will knowingly harm others.

This website provides information on the companies we invest in, our current
thinking on sustainable investment and what we have learned from investment
trips. We hope it explains clearly our investment philosophy and the benefits of
sustainable investing.

--------------------------------------------------------------------------------





A WORLD OF SUSTAINABLE COMPANIES

Explore how the companies in our strategies are contributing to sustainable
development.

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Portfolio Explorer



STORIES OF SUSTAINABLE INVESTMENT

Our investment process starts with a blank page, not a benchmark.

--------------------------------------------------------------------------------

Read more

<p></p> <table><thead><tr><th>ANNUAL PERFORMANCE (% IN GBP) TO 31 August
2019</th><th>12 MTHS TO 31/08/19</th><th>12 MTHS TO 31/08/18</th><th>12 MTHS TO
31/08/17</th><th>12 MTHS TO 31/08/16</th><th><strong>12 MTHS TO
31/08/15</strong></th></tr></thead><tbody><tr><td>Fund
return</td><td>23.1</td><td>-3.5</td><td>18.8</td><td>32.9</td><td>3.5</td></tr><tr><td>FTSE
Global Core Infrastructure 50/50 Total Return
Index</td><td>22.6</td><td>-1.9</td><td>17.8</td><td>31.0</td><td>1.5</td></tr></tbody></table>
<table><thead><tr><th>CUMULATIVE PERFORMANCE (% IN GBP) TO&nbsp;<strong>31
August 2019</strong></th><th>3 MTHS</th><th>6 MTHS</th><th>1 YR</th><th>3
YRS</th><th>5 YRS</th><th>10 YRS</th><th><strong>SINCE
INCEPTION</strong><br></th></tr></thead><tbody><tr><td>Fund
return</td><td>9.2</td><td>18.7</td><td>23.1</td><td>41.1</td><td>94.1</td><td>248.1</td><td>235.6</td></tr><tr><td>FTSE
Global Core Infrastructure 50/50 Total Return
Index</td><td>8.3</td><td>17.4</td><td>22.6</td><td>41.7</td><td>88.4</td><td>217.5</td><td>169.5</td></tr></tbody></table>
<p></p>
<p><strong>These figures refer to the past. Past performance is not a reliable
indicator of future results. For investors based in countries with currencies
other than GBP, the return may increase or decrease as a result of currency
fluctuations.</strong><br /></p> <p>All performance data for the First State
Global Listed Infrastructure Fund Class B (Accumulation) GBP as at 31 August
2019. Source for fund - Lipper IM / First State Investments (UK) Limited.
Performance data is calculated on a net basis by deducting fees incurred at fund
level (e.g. the management and administration fee) and other costs charged to
the fund (e.g. transaction and custody costs), save that it does not take
account of initial charges or switching fees (if any). Income reinvested is
included on a net of tax basis. Source for benchmark - FTSE, income reinvested
net of tax. Since inception performance figures have been calculated from 08
October 2007. </p>


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