DISCLAIMER AND TERMS OF REFERENCE

• Group H2O AM (“H2O AM”), is the name adopted to collectively identify all H2O legal entities.
• H2O AM is sometimes referred as “we”, “us”, “its “or “our”.
• The “Materials” is the term used to encompass all information available on or through the website, which includes without limitation: images, text, illustrations, designs, icons, photographs, programs, music clips, downloads, systems, methods of trading, video clips, graphics, user interfaces, visual interfaces, information, data, tools, Products, written materials, Services and other content, including but not limited to the design, structure, selection, coordination, expression and arrangement of the content available on or through the website or any form of publication.
• The “Products” is the term used to encompass all funds for which the Materials is made available on or through this website.
• The “Services” is the term used to encompass all mandatory services that should be fulfilled according to H2O AM agreements and licenses in each jurisdiction where H2O AM intervenes.
• The “Investment advice” is defined as any recommendation or guidance that attempts to educate, inform, or guide a client, regarding, without limitation, a particular investment product or series of products, Services, securities, financial instruments or any other linked services like tax, legal compliance or accounting advice.
• “Publication” is the act by which the Materials or reproduced Materials related to H2O AM brand name is made public.
• The “General Conditions of Use” (“Terms”) is the terms upon which this website is made available to a website’s users. These Terms are legally binding on all users. By accessing this website you agree to be bound by these Terms.
• The “Website’s users” or “Users” is the term used to define all visitors and/or users of the website’s Materials. This term encompasses, including without limitation, clients, advisors, distributors and media.
• The “Website’s users” may not copy, reproduce, republish post or exploit or disseminate in any other way the Materials on the website without prior authorization in writing from H2O AM, other than to download information from this website and reproduce it for private use, and disseminate it among family members.
• This website was created, is managed and updated by H2O AM.

 

COMPANY NAME

H2O Asset Management L.L.P.

H2O Asset Management L.L.P. is registered in England and Wales with a share capital of 10,000,000 £, with registered name H2O AM LLP, registration number OC 356207 and Legal Entity Identifier(LEI) 549300V7YSH2IZ841X25 . Its registered address is at 33 Cavendish Square, London W1G 0PW. H2O Asset Management L.L.P.’s registered VAT Number is 103684235

H2O Asset Management L.L.P. is authorised and regulated by the Financial Conduct Authority (“FCA”), and is entered on the FCA Register with the Registration Number 529105 and company number OC356207. The FCA Register can be accessed at http://www.fca.org.uk/.

H2O AM Europe SAS

H2O AM Europe SAS is registered in France with a share capital of 13,500,000 euros, SIREN n°843082538 Paris and legal entity identifier(LEI) N° 9695000GQ2JLFQA4JX30. Its registered office address is at 39, avenue Pierre 1er de Serbie 75008 Paris, France. H2O AM Europe SAS’s registered VAT Number is FR77843082538.

H2O AM Europe SAS is an asset management company, authorised and regulated by the Autorité des marchés financiers (“AMF”). The AMF agreement number is GP-19000011. The AMF Register can be accessed at https://www.amf-france.org.

H2O Monaco SAM

H2O Monaco is registered in Monaco with a share capital of 450,000 euros, Registration number 17S07498 and Legal entity identifier (LEI) N° 549300P23I30JJWXGS37 .

Its registered address is at 24, BD PRINCESSE CHARLOTTE ET 1, IMPASSE DE LA FONTAINE 10 ETG N° B10 – 98000 MONACO – MC PRINCIPAUTE DE MONACO

H2O Monaco is authorized by the Commission de Contrôle des Activités Financières (CCAF) to carry out the following activities as mentioned in points 4.1 and 6 of article 1 of law n°1.338 of September 7, 2007:

• Advice and assistance in the management, on behalf of third parties, of portfolios of securities or financial futures instruments,
• Manage foreign collective investment schemes

The CCAF agreement number is SAF 2017-04.

H2O AM ASIA PTE.LTD.

H2O AM ASIA PTE.LTD. is registered in Singapore with a share capital of 500,000 Singapore $, Registration number 201827907K and Legal entity identifier (LEI) number : 5493004DGLQ0FP9NFO63.

Its registered address is at 12 Marina Boulevard #17-01 – Marina Bay Financial Centre Tower 3 – Singapore 018982

H2O AM SWITZERLAND SA

H2O AM SWITZERLAND SA is registered in Switzerland with a share capital of 200,000 CHF, Registration number CHE-167.132.256.

Its registered address is rue Cornavin 11, c/o DYN Genève SA (CHE 372.076.788) – 1201 Genève.

PUBLICATION – H2O AM’S REPRESENTATIVES

Publications director: Loïc Guilloux, Président H2O AM Europe and Member of the Global Executive Committee

Editor: Marc Maudhuit, CEO of H2O Asset Management LLP

Host:  OVHcloud (Customer Support: 0333 370 0425), address: 2 rue Kellermann – 59100 Roubaix – France

OVH SAS is a subsidiary of OVH Groupe SA, a company registered with the Lille Trade and Companies Registry under number 537 407 926

https://www.ovhcloud.com/fr/

TERMS AND CONDITIONS OF USE

Use of this website is subject to the following terms and conditions, which should be read carefully. By using this website, users are deemed to have full knowledge of these conditions and to accept them. Please do not use this website if you do not agree with these conditions. You acknowledge that you understand that these Terms constitute a binding agreement between you and H2O AM that governs your access to and use of the Website.  Under no circumstances does the information published on the website represent an offer of products or services that could be construed as a public offering or a solicitation to buy or sell mutual funds or any other management or investment product.

WEBSITE APPLICABLE LAW AND JURIDICTION

This site is governed by French law and is subject to the jurisdiction of the French courts.
By accessing this website, you agree that all matters relating to your access to or use of this website, including all disputes and excluding customer claims which are further defined in the Customer Claims section, shall be governed by the courts and laws of France, without regard to principles of conflict of laws, and you agree to waive any objection to the courts and laws applicable in France.

NOTICE REGARDING WEBSITE’S MATERIALS

The content has been placed for information purposes only and in order to comply with legal and regulatory requirements. Unless expressly stated otherwise, in all circumstances and in all jurisdictions, the documents do not constitute an offer or solicitation to sell or buy securities or other financial instruments, nor investment advice, nor a public offering of securities or other financial instruments under applicable law, and should not be construed as such. Before investing, you should seek the advice of an investment professional, in particular to assess the risks involved in transactions. Your investment decision should be consistent with your appetite for risk. Where appropriate, you should consult your own tax, legal and accounting advisors before entering into any transaction. By accessing this site, you agree that H2O AM shall have no liability of any kind, present or future, arising from the use of the Material, unless such liability arises by law or regulation. The Material is not intended for distribution to, or use by, any person or entity in any country or jurisdiction where to do so would be contrary to law or regulation, or would require H2O AM to comply with the regulatory requirements of any such country or jurisdiction. Not all products and services may be registered or licensed in all countries or available to all customers.

BLOG AND SOCIAL NETWORKS

You are solely responsible for any information you choose to submit to blogs and social networks.

SOCIAL MEDIA CHANNELS

H2O AM’s social media content, including X (ex-Twitter), Instagram, LinkedIn, YouTube and Facebook, is provided for informational purposes only. It does not constitute an offer to sell securities or the solicitation of an offer to buy securities. H2O AM assumes no responsibility for the accuracy, completeness or usefulness of information available on social media channels.

FORWARD – LOOKING STATEMENTS

This website may contain forward-looking statements based on H2O AM’s current assumptions and forecasts. Various known and unknown risks, uncertainties and other factors could lead to material differences between the actual future results, financial situation, development or performance of the company and the estimates given herein. H2O AM assumes no responsibility to update these forward-looking statements or to conform them to future events or developments.

INTERNATIONAL USERS

This website is controlled, operated and updated by H2O AM. H2O AM does not warrant that the information presented on this website is also correct in locations outside the jurisdiction in which H2O AM is licensed. Please note that it is your responsibility to ensure that you act in compliance with local legislation in that location.

Dodd Franck act

Users are informed that the products and services presented on this site may only be offered in jurisdictions where their marketing and promotion are authorised.

Consequently, access to information and/or documents concerning the products and services offered on this site may be restricted or prohibited to legal entities or individuals who, by virtue of their nationality, residence, registered office , place of registration or any other reason, are subject to a foreign law that imposes specific restrictions or obligations on H2O with respect to the marketing and promotion of these products and services in that jurisdiction.

In this respect, the information on this site in no way constitutes an offer to sell or a solicitation, direct or indirect, to subscribe to financial instruments and units of account in the case of life insurance:

– in particular on the territory of the United States of America or,

– with American residents or,

– by nationals of certain countries, notably the United States of America.

The user is asked to ensure that he/she is legally authorised to connect to this website in the country from which the connection is established, and that there is nothing to prevent him/her, with regard to his/her legal status, from subscribing to the products and services offered on this website, including financial instruments.

THIRD PARTIES OFFERS/ADVERTISING AND WEBSITE LINKS

Third-party product and service offers and advertising may be published on this site in the form of banners. By clicking on one of these banners, you will be redirected to a third-party website. H2O AM declines all responsibility for the content of advertising and the conditions applicable to third-party offers. If you wish to subscribe to such an offer, enter into a contract with such a third party or make a complaint regarding such offers or advertising, you must contact the third party in question directly. The inclusion of banners does not imply that we endorse the material contained in such banners, nor that we are associated with the third parties, and you agree not to involve us in any dispute between you and the third party. The content of other websites that may be linked to this site is not maintained, controlled or verified by H2O AM. H2O AM is therefore not responsible for the availability, content, accuracy or privacy practices of other websites or services that may be linked to or advertised on this website. These links are provided on the website for information purposes. H2O AM is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by H2O AM of the linked website. By accessing this website, you agree that H2O AM has no liability of any kind, present or future, arising from the use of links to third party websites, unless such liability arises by law or regulation.

ACCESSIBILITY, AVAIBILITY AND COMPABILITY

H2O AM makes every effort to ensure that the website functions correctly at all times and remains available at all times. However, H2O AM offers no guarantee as to the availability, accessibility and/or compatibility of the website. As a user of the website, you must ensure that you have the appropriate computer equipment and software, including security software (firewall and anti-virus). H2O AM accepts no responsibility for damage to your computer system or loss of data resulting from your use of the website and H2O AM cannot guarantee that files downloaded from the website are free from viruses, contamination or destruction. H2O AM shall not be liable for any damages, losses, costs or expenses incurred by you due to a lack of availability, accessibility and/or compatibility of the website. However, should you experience any difficulties, we would like to hear from you in order to remedy the situation. Please contact : clientservices@h2o-am.com.

INTELLECTUAL PROPERTY RIGHTS

You agree that the content made available to you on or through this website is the property of H2O AM or its partners. The content protected by intellectual property rights. The use of this website and its content does not grant you any rights to these intellectual property rights. You may not copy, reproduce, republish, display, exploit, or distribute in any way the elements of the website without the prior written permission of H2O AM, with the exception of downloading information from the website and reproducing it for private use, as well as distributing it among members of your family. If H2O AM allows you to submit your content to the website, you may not submit such material unless you yourself own the rights to do so or have received the necessary permission from the relevant rights holders. By submitting content to the website, you grant us the right to use such material at our own discretion, including, without limitation, editing, copying, reproducing, disclosing, displaying and removing such material from the website. You agree to indemnify us against any claim or damage (including legal costs in connection with any such claim or damage) by any third party arising out of or in connection with any such content.

UNAUTHORISED USE OF THIS WEBSITE

As a user of this website, you agree not to :

• use the material published on this website in an illicit or illegal manner ;
• use this website in such a way as to damage, modify, interrupt or render it less effective in any way ;
• use this website to transmit computer viruses or to send illegal or illicit material, or material that is inappropriate in any way – in particular, but not exclusively, material that is offensive, obscene or threatening ;
• use this website in such a way as to infringe the rights of individuals or organizations – in particular, but not exclusively, the rights to privacy and intellectual property ;
• use this website to send or transmit promotional material or advertising.

By accessing this site, you acknowledge that H2O AM reserves the right to suspend, restrict or terminate your access to the site at any time and without notice, and to formally notify you and/or take legal action against you, if we have reasonable grounds to believe that you have violated any of the above restrictions, or any other provision of these Terms.

PASSWORDS

You may be required to use a password to access certain parts of the website. In this case, access to these parts without a password is strictly forbidden. If you have received such a password, it must remain confidential and secret. Any use of our services after a valid identification using your password will be considered as being used by you. By accessing this site, you acknowledge that H2O AM has the right to cancel your password if the security of the site is threatened.

Passwords are handled in accordance with our privacy policy.

MODIFICATIONS TO THESE CONDITIONS

By accessing this site, you acknowledge that H2O AM reserves the right to modify the site and these terms and conditions at any time without notice. Therefore, each time you use this website, you should consult the current terms and conditions.

ILLEGALITY OF A PROVISION

If any provision of these terms and conditions is held by a court or regulatory authority to be invalid or unenforceable, the remaining provisions shall continue to apply.

CLIENT COMPLAINTS 

Customer satisfaction is our top priority. This is why we are very attentive to customer complaints about H2O AM products and/or services. We are committed to investigating your request and responding to your complaint in a timely manner. H2O AM’s complaint handling system processes customer complaints accurately, consistently and in accordance with applicable regulations. Access to the claims department is free of charge, and customers may file their claims in either French or English.

Definition of complaints

A claim is considered to be the expression of dissatisfaction (oral or written) with the provision or lack of provision of a financial service.

A request for information, advice, clarification, service or provision of service does not constitute a claim.

Handling complaints

Complaints can be sent by post, telephone and/or e-mail, or can be provided through the customer’s usual point of contact.

• By Telephone: The Client’s usual point of contact
• By Post:
  • H2O Asset Management L.L.P.: 9th Floor, 33 Cavendish Square, W1G 0PW, London, United Kingdom
  • H2O AM Europe SAS : 5^th Floor, 39 avenue Pierre 1er de Serbie 750008 Paris, France
  • H20 Monaco : 24, BD PRINCESSE CHARLOTTE ET 1, IMPASSE DE LA FONTAINE 10 ETG N° B10 – 98000 MONACO – MC PRINCIPAUTE DE MONACO
  • H2O AM ASIA PTE. : 12 Marina Boulevard #17-01 – Marina Bay Financial Centre Tower 3 – Singapore 018982
  • H2O AM SWITZERLAND SA : rue Cornavin 11, c/o DYN Genève SA (CHE 372.076.788) – 1201 Genève
• By Email: The Client’s usual point of contact AND/OR complaints@h2o-am.com

Processing deadlines

• H2o AM Group entities are required to acknowledge receipt of all complaints within the timeline of 5 business days. H2O AM Europe has the same objective but this timeline can be expanded to 10 days from the date on which the written complaint is sent.
• Respond to any complaints within a maximum period of eight weeks following their receipt or 2 months for H2O AM Europe from the date on which the written complaint is sent. H2O AM will collate all the information, documentation and comments relevant to your complaint. 
• If our investigation is going to take longer than eight weeks or two months for H2O AM Europe, we will write to you again to explain why and let you know when we expect to be able to conclude matters. When we have completed our investigation we will let you know the outcome in writing.

Ombudsman
As a last resort and if you are not happy with our final response you may refer your request, free of charge, to the Ombudsman according to jurisdiction where complaints shall be addressed. The Ombudsman must be referred to within a year of the complaint submitted to H2O AM and only after all the internal remedies mentioned above have been used.

United Kingdom:

The Financial Ombudsman Service can be contacted in a number of ways:

• By post: Financial Ombudsman Service Exchange Tower, Harbour Exchange Square London, E14 9SR
• By telephone: +44 (0) 800 023 4567
• By email: complaint.info@financial- ombudsman.org.uk
• By website: financial-ombudsman.org.uk

France:

The AMF Ombudsman Service can be contacted in a number of ways:

• By post: Ombudsman – Autorité des Marchés Financiers, 17 place de la Bourse – 75082 Paris cedex 02.
• By Fax: +33 (0)1 5345 5960
• By website : https://www.amf-france.org/en_US/Le-mediateur-de-l-AMF/Le-mediateur-mode-d-emploi/Modes-de-saisine

Monaco :

The Ombudsman Service can be contacted

• by website : https://en.service-public-particuliers.gouv.mc/You-and-The-Administration/Ombudsman-service/Mediation

Singapore:

The Financial Industry Disputes Resolution Centre Ltd (FIDReC) is an independent and impartial institution that resolves consumer financial disputes through mediation and adjudication. It can be contacted in a number of ways:

• By Post : 36, #15-01 Robinson Rd, City House, Singapore 068877
• By phone : +65 6327 8878
• By website :  https://www.fidrec.com.sg/website/index.html

Switzerland:

Association Finanzombudsstelle Schweiz (FINOS) is a neutral institution to develop consensual solutions for all parties within the framework of mediation and thus avoid costly legal disputes. Their ombudsman service deals with questions and complaints from clients of our affiliated financial services providers.

By post : Talstrasse 20 CH-8001 Zürich

By website : Info@finos.ch

Data Protection

In accordance with laws data protection, H2O AM is required to retain personal data for as long as is necessary for the purposes for which it was collected. When personal data is no longer required, it is securely destroyed in accordance with H2O AM’s privacy policy.

You have rights concerning your Personal Data. These rights are described below. For further information, to ask a question concerning these rights or for any request concerning the processing of your Personal Data by H2O AM, please contact us by email at : compliance@h2o-am.com

Your rights with regards to your personal data

You have a number of rights in relation to your Personal Data. These rights are set out below.

• The right to request access to Personal Data (Article 18 of the GDPR) held by H2O AM about you, as well as the right to request the amendment (Article 16) of any inaccurate, incorrect or incomplete Personal Data ;
• The right to erasure of your Personal Data to the extent permitted by law (for example, as specified in Article 17 of the European General Data Protection Regulation (GDPR);
• The right to restrict (Article 18) the processing of your Personal Data by us (in other words, to allow only its storage) in specified circumstances; if your Personal Data is restricted, we will only process it with your consent or for the purposes of establishing, exercising or defending legal claims, or for regulatory purposes;
• Right to object to the processing of your Personal Data :
  • Where such data is processed for direct marketing purposes, you have the right to object to such processing at any time. If you exercise this right, your Personal Data may no longer be processed for such purposes.
  • Where such processing is based on legitimate interests, you also have the right to object at any time. Exercising this right of objection obliges us to cease such processing, unless we are able to prove that valid legitimate reasons justify such processing overriding your interests, rights and freedoms, or if the processing of your Personal Data is necessary for us to constitute, exercise or defend a legal claim.

If you wish to exercise any of these rights, please contact us at” compliance@h2o-am.com .

Your rights as an investor

This summary has been prepared by H2O AM the “Company” and is a summary of the main rights of existing or potential investors (the “Investors”), in accordance with the European Regulation on cross-border distribution of collective investment undertakings (Regulation (EU) 2019/1156).

This summary is not intended to be an exhaustive list of all the rights available to Investors in relation to Undertakings for Collective Investment (UCIs).

This summary does not replace the information contained in the prospectus and/or offering document (hereinafter the “Prospectus”), the key investor information document (KID) or any other document relating to the UCIs. These rights may include:

• Right to investment information

Investors are entitled to receive the following information about the fund:

• Key Information Document (KID)
• The card
• the prospectus
• the articles of association, if applicable
• Annual, semi-annual and monthly financial reports
• The regulations

The fund’s prospectus, KID, product card, regulations, articles of association, if applicable, and financial reports are available on the website or on request from the management company.

The KID and prospectus, and the articles of association where applicable, must be made available to the subscriber prior to subscription.

• Right to redeem investments

Redemptions are made in accordance with the terms and conditions set out in the prospectus and bylaws, where applicable. The right of redemption is subject to the condition that all documents required to ensure compliance with laws and regulations relating to the fight against money laundering and the financing of terrorism have been provided.

• Handling customer complaints

Please refer to the “CUSTOMER COMPLAINTS” section.

• Cross-border complaints

You can also use FIN-NET to file a cross-border complaint if you reside in a member country of the European Economic Area, if you have a complaint against a financial services provider in another member country of the European Economic Area, if you have filed a complaint but are not satisfied with the response, and if you wish to find out which alternative dispute resolution body could resolve the dispute.

To make a complaint to a member of the FIN-NET network, you can contact a FIN-NET member directly and ask for advice. Click here for contact details of all FIN-NET members in each country.

Finally, you always retain the right to take legal action.

• If you hold units in a mutual fund (FCP)

Co-owners’ rights are represented by units, with each unit corresponding to the same fraction of the fund’s assets. Each unitholder has a co-ownership right in the fund’s assets proportional to the number of units held.

• The right to attend and vote at Shareholders’ Meetings

Where the mutual fund is incorporated, each Investor has the right to attend general meetings of shareholders in person or by proxy, in accordance with the provisions of the company’s articles of association.

• Dividend rights

In the cases referred to in the Prospectus, and in accordance with the legal provisions in force, each Investor is entitled to a proportional share of the Fund’s income. Dividends are distributed in accordance with the terms and conditions set out in the Prospectus, which is available in the “Our Strategies & Funds/Documents” section of the website.  

Record Keeping

When complaint has been settled, the complaint record and associated correspondence will be retained the records for at least five years from the date the complaint was received. The date on which the complaint was resolved will be recorded. All complaints records, even in relation to minor complaints and those complaints resolved within one business day will be maintained for 5 years in relation to MiFID business.

Reporting to the FCA

Twice a year H2O AM will provide the FCA with a complete report concerning complaints received from eligible complainants including those settled within 3 business days.

Nature of commitment to the UK Stewardship Code

Under the Financial Conduct Authority’s (FCA) Conduct of Business Sourcebook Rule 2.2.3, H2O Asset Management LLP (H2O) is required to make a public disclosure on its website in relation to its commitment to the Financial Reporting Council’s (FRC) Stewardship Code (hereafter, the Code).

In October 2019, a substantially revised and strengthened UK Stewardship Code was published and took effect on 1 January 2020. The revised version comprises a set of twelve Principles, implemented on an ‘apply and explain’ basis. These Principles apply to asset managers and asset owners, with a separate set of six Principles applying to service providers. The revised Code defines stewardship as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.”

Whilst H2O strongly endorses this definition of stewardship and the purpose of the Code, we are currently not a signatory due to the nature of our investment approach, which is essentially top-down and global macro.

H2O’s investment strategy is driven by views on the government bond, credit and currency markets, with the majority of positions taken through derivative contracts such as futures, and with limited allocation to individual equity securities and corporate bonds. We are currently exploring possible approaches to exercising stewardship activities across our investment universe, notably by incorporating ESG criteria into our investment decisions (Principle 7). We will therefore review our approach to the Code in the future and update this disclosure accordingly.

PRIVACY NOTICE

You may freely visit this website and access the website’s Materials without having to provide any personal data. Only the subscription service offered by this website requires personal data to be entered. Unless otherwise indicated, your replies and any information that you are requested to provide on this website’s data collection forms are optional. The data collection forms clearly indicate whether the information requested is optional or mandatory. In the event of failure to provide mandatory replies or information, H2O AM will be unable to deal with your requests in the proper way. Each time you send us personal data, H2O AM will process this in accordance with the provisions below, and with its legal and regulatory obligations.

Personal data is stored in a secure environment which is not accessible by the public. It is processed only for internal purposes. Personal data is not retained for longer than is necessary to provide the services .H2O AM does not pass personal data to third parties, except to fulfil legal and regulatory obligations and in the event of a request from the courts or the police. If, exceptionally, H2O AM wishes to pass personal data to organizations or companies with which it works, you will be asked to give your express consent to this.

The full version of H2O Data Privacy Notice and Protection is made accessible on this website.