Any communications contained on this website are issued by: (i) Systematica Investments Limited (“SIL”) acting solely in its capacity as general partner of Systematica Investments LP (“SILP”), (ii) Systematica Investments GP Limited and acting through its Geneva branch (“SIGPL”), (iii) Systematica Investments Singapore Pte. Limited (“SISPL”) and/or (iv) Systematica Investments UK LLP (“SIUK”), (each and together “Systematica Investments”). Systematica Investments shall mean: (i) for all purposes, except for issue into the United States or issue to U.S. persons, issue into Australia or to Australian persons, issue into Singapore or to Singaporean persons, or issue into Switzerland or to Swiss persons, SIUK; (ii) only for the purposes of issue into the United States or issue to U.S. persons, SIL acting solely in its capacity as general partner of SILP; (iii) for the purposes of issue into Australia or to Australian persons or issue into Singapore or to Singaporean persons, SISPL; and (iv) only for the purposes of issue into Switzerland or to Swiss persons, SIGPL acting through its Geneva branch.
SIL is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser under the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”). SIL is registered with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a commodity trading advisor and a commodity pool operator and is a member of the U.S. National Futures Association (the “NFA”) in such capacities and is approved by the NFA as a swap firm. SIL as general partner of SILP is licensed and regulated by the Jersey Financial Services Commission (the “JFSC”) under the Financial Services (Jersey) Law 1998 (the “FSJL”) to conduct fund services business in and from within Jersey. The JFSC does not take any responsibility for the financial soundness of the Funds (as defined below) or for the correctness of any statements made or expressed herein. The JFSC is protected by the FSJL against liability arising from the discharge of its functions under that law. SIGPL is licensed and regulated by the JFSC under the FSJL to conduct fund services business in and from within Jersey and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm, and its Geneva branch is authorised by the Swiss Financial Market Supervisory Authority FINMA (“FINMA”) as a branch of a Manager of Collective Assets. SIUK is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”) and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. SISPL is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to “wholesale investors” in Australia (as that term is defined in the Corporations Act 2001 (Cth)), is regulated by the Monetary Authority of Singapore (the “MAS”) under the laws of Singapore, which differ from Australian laws, and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. Each of SIUK, SISPL and SIGPL is registered with the SEC as an investment adviser under the Advisers Act. Such registrations, memberships, approvals, authorizations and licenses do not imply that any of the SEC, the CFTC, the NFA, the JFSC, FINMA, the FCA or the MAS have approved any applicable Systematica Investments entity’s qualifications to provide the advisory services set forth in this document.
For the purposes of this disclaimer the “funds” referred to will include each of the funds described herein as well as any other funds, sub-funds, managed accounts, special purpose vehicles or investment vehicles in respect of which SIL has been appointed to act as or shall be appointed to act as, investment manager (each, a “Fund” and together, the “Funds”).
In respect of any content on this website operated by SIUK, the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional clients” as defined in the FCA’s Handbook of Rules and Guidance (the “FCA Handbook”); and (b) are persons who may lawfully receive access to such information under the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “PCISE Order”) (the persons described in (a) and (b) above together, the “Relevant Persons”). Access by persons who are not Relevant Persons is strictly unauthorised.
In respect of content on this website operated by Systematica Investments (excluding SIUK), the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional investors” as defined in the Alternative Investment Fund Managers Regulation (SI 2013/1773) (as amended); and (b) are persons who may lawfully access such information under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2001 (the “FPO”) including by virtue of being investment professionals within the meaning of Article 19(5) of the FPO (the persons described in (a) and (b) above together, the “Permitted Persons”). Access by persons who are not Permitted Persons is strictly unauthorised.
Where communications contained on this website are issued by SIL, the following applies. Communications contained on this website have been prepared in accordance with the requirements of the FSJL and any other legislation, regulations and orders which may be applicable from time to time, together with the requirements of any relevant codes of practice and guidance issued by the JFSC from time to time (the “JFSC Regulatory Requirements”). The information contained in such communications is directed by SIL exclusively at persons who are professional clients or eligible counterparties for the purposes of the JFSC Regulatory Requirements, or, if to U.S. persons (as defined under Regulation S promulgated under the U.S. Securities Act of 1933, as amended (the “Securities Act”)), to U.S. persons who are both accredited investors (as defined under Regulation D promulgated under the Securities Act) and qualified purchasers (as defined in the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”)).
Where communications contained on this website are issued by SISPL, such communications have been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the relevant offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to “wholesale investors” under the Corporations Act 2001 (Cth).
The interests in the Funds have not been filed with or approved or disapproved by any regulatory authority of the United States or any state thereof, nor has any such regulatory authority passed upon or endorsed the merits of an offering of a Fund or the accuracy or adequacy of communications contained on this website. Any representation to the contrary is unlawful.
PURSUANT TO AN EXEMPTION FROM THE COMMODITY FUTURES TRADING COMMISSION IN CONNECTION WITH ACCOUNTS OF QUALIFIED ELIGIBLE PERSONS, THIS BROCHURE OR ACCOUNT DOCUMENT IS NOT REQUIRED TO BE, AND HAS NOT BEEN, FILED WITH THE COMMODITY FUTURES TRADING COMMISSION. THE COMMODITY FUTURES TRADING COMMISSION DOES NOT PASS UPON THE MERITS OF PARTICIPATING IN A TRADING PROGRAM OR UPON THE ADEQUACY OR ACCURACY OF THE COMMODITY TRADING ADVISOR DISCLOSURE. CONSEQUENTLY, THE COMMODITY FUTURES TRADING COMMISSION HAS NOT REVIEWED OR APPROVED THIS TRADING PROGRAM OR THIS BROCHURE OR ACCOUNT DOCUMENT.
The distribution of information or documents contained in communications on this website may be further restricted by law. No action has been or will be taken by SIL or any Fund to permit the possession or distribution of the information or documents contained in communications on this website in any jurisdiction (other than as expressly stated by Systematica Investments) where action for that purpose may be required. Accordingly, documents and information contained in communications on this website may not be distributed, or forwarded to recipients, in any jurisdiction except under circumstances that will result in compliance with any applicable laws and regulations. It is the responsibility of the recipient of information or documents contained in communications on this website (or its agent or adviser, as the case may be) to ensure that any individuals (whether employed by them or otherwise) who receive the information herein do so in accordance with applicable law and regulation. Persons to whom documents and information contained in communications on this website are communicated should inform themselves about and observe any such restrictions.
Recipients of any communications contained on this website should note that electronic communication, whether by email, website, SWIFT or otherwise, is an unsafe method of communication. Emails and SWIFT messages may be lost, delivered to the wrong address, intercepted or affected by delays, interference by third parties or viruses and their confidentiality, security and integrity cannot be guaranteed. None of the Funds or Systematica Investments bear any liability or responsibility therefor.
Distribution and Selling Restrictions: The distribution of documents and information contained in communications on this website and the offering or purchase of interests in the Funds may be restricted in certain jurisdictions. No persons receiving a copy of documents or information contained in communications on this website in any such jurisdiction may treat such information or documents as constituting marketing or an invitation to them to subscribe for interests in the Funds. Accordingly, documents and information contained in communications on this website do not constitute marketing, an offer or solicitation by anyone in any jurisdiction in which such marketing, offer or solicitation is not lawful or in which the person marketing or making such offer or solicitation is not qualified to do so or to anyone to whom it is unlawful to market or make such offer or solicitation. It is the responsibility of any persons in possession of documents or information contained in communications on this website, including individuals who may be employed by or a consultant to the recipient, to inform themselves of, and to observe, all applicable laws and regulations of any relevant jurisdiction. If any recipient, including individuals, is or becomes aware that the receipt of documents or information contained in communications on this website by them contravenes any law or regulation, they must destroy it or return it to Systematica Investments immediately. Prospective applicants for interests in the Funds should inform themselves as to the legal requirements of so applying and any applicable exchange control regulations and taxes in the countries of their respective citizenship, residence or domicile.
Information for investors in the European Economic Area (the “EEA”) and the United Kingdom (“UK”): Investors that are resident, domiciled or with a registered office in any Member State of the EEA or the UK should note that access to this website is restricted to “professional investors” within the meaning of Directive 2011/61/EU (as amended and as implemented into local law or regulations in each EEA Member State, and in respect of the UK, as it forms part of UK law by virtue of the European Union (Withdrawal) Act 2018 (as amended), “AIFMD”). Access by persons that are not “professional investors” within the meaning of AIFMD is strictly unauthorised.
Information for investors in Switzerland: Any distribution or offer of interests in the Funds in Switzerland is exclusively made to, and directed at, qualified investors (“Qualified Investors”), as defined in the Swiss Collective Investment Schemes Act of 23 June 2006, as amended, and its implementing ordinance. Accordingly, the Funds have not been and will not be registered with FINMA for distribution to non-qualified investors. Any Funds which are Delaware limited partnerships are not distributed in Switzerland and are not available for subscription by investors in Switzerland. If a Swiss representative has been appointed in respect of a Fund, offering materials relating to interests in that Fund may be obtained by Qualified Investors in Switzerland from the Swiss representative and/or authorised distributors. Swiss representative (where appointed): Mont-Fort Funds AG, 63 Chemin Plan-Pra, 1936 Verbier, Switzerland. Swiss paying agent (where appointed): Neue Helvetische Bank AG, Seefeldstrasse 215, CH-8008 Zurich, Switzerland. In respect of the distribution of interests in the Funds in and from Switzerland, the place of performance and jurisdiction is the registered office of the Swiss representative. Systematica Investments GP Limited, Geneva Branch is affiliated with the Swiss Arbitration Centre (formerly known as the Swiss Chambers’ Arbitration Institution) for the provision of ombudsman services under the Swiss Federal Act on Financial Services.
Information for investors in Australia: To the extent that communications contained on this website are issued by SISPL, such communications has been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to ‘wholesale investors’ under the Corporations Act 2001 (Cth).
Information for investors in Singapore: The Funds are not authorised or recognised by the MAS and interests in any Funds are not allowed to be offered to the retail public. Communications contained on this website and any other communication or material in connection with the offer, sale, invitation for subscription or purchase of interests in any Fund may not be circulated or distributed, nor may interests in any Fund be offered, sold or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to the public or any member of the public in Singapore other than a person who is an accredited investor or an institutional investor (each as defined under the Securities and Futures Act (Chapter 289) of Singapore) (“SFA”) or unless otherwise permitted under any applicable exemption. Communications contained on this website and any other communications or material in connection with the offer or sale, or invitation for subscription or purchase, of interests may not be circulated or distributed, nor may interests be offered or sold, or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to persons in Singapore other than in accordance with the conditions set out in the applicable provisions of the SFA. Communications contained on this website and any other communication or material issued in connection with the offer or sale is not a prospectus as defined in the SFA and has not been registered as a prospectus with the MAS. Accordingly, statutory liability under the SFA in relation to the content of prospectuses would not apply. Each prospective investor should consider carefully whether the investment is suitable for him.
SIL, as general partner of SILP (SIL together with SILP and each of their subsidiaries and affiliates, the “Systematica Group”), was appointed as investment manager of the Funds on or after 1 January 2015 following the “spin-out” of the Systematica Group. Any Fund performance information in communications contained on this website relating to dates prior to 1 January 2015 illustrates the performance of the Funds whilst the predecessors of the Systematica Group were appointed as investment manager to the Funds. There is no guarantee that past performance of the Funds will be replicated under the management of the Systematica Group.
Communications contained on this website are not intended to constitute, and should not be construed as, investment advice, investment recommendations or investment research. Current and prospective investors acknowledge that no member of the Systematica Group has conducted or will conduct the activity of reception and transmission of orders in relation to the interests of the Funds, whether for the Funds, investors or otherwise. Potential investors in the Funds should seek their own independent financial, tax, legal and other advice. Communications contained on this website have been made available to you for informational purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to herein or for any other purpose. Communications contained on this website are not intended as and are not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. Before making any investment decision you should obtain independent legal, tax, accounting or other professional advice, as appropriate, none of which is offered to you by the members of the Systematica Group or any of their affiliates. None of the members of the Systematica Group or any of their affiliates accepts any duty of care to you in relation to any investment in the Funds.
The terms of investment in any of the Funds described herein or any other Fund are solely as set out in the relevant Fund’s prospectus or private placement memorandum (including any supplements thereto), as the case may be, application forms and/or memorandum and articles of association or limited partnership agreement or instrument of incorporation, as the case may be (collectively, the “Fund Documents”). Before acquiring an interest in any Fund, each prospective investor is required to confirm that it has carefully reviewed the various risks of an investment in the Fund, as set out in the Fund Documents, and is required to acknowledge and agree to the existence of any actual and potential conflicts of interests described in the Fund Documents and waive, to the fullest extent permitted by any applicable law, any claim with respect to the existence of any such conflicts.
Communications contained on this website may contain simulated performance results achieved by means of the retroactive application of Systematica Investments’ investment methodology, or the real-time application of a hypothetical capital allocation to such strategy. Hypothetical performance results have many inherent limitations, some of which are described below. No representation is being made that any particular trading program will or is likely to achieve profits or losses similar to those shown. In fact, there are frequently sharp differences between hypothetical performance results and the actual results subsequently achieved by any particular trading program. One of the limitations of hypothetical performance results is that they are generally prepared with the benefit of hindsight. In addition, hypothetical trading does not involve financial risk, and no hypothetical trading record can completely account for the impact of financial risk in actual trading. For example, the ability to withstand losses or to adhere to a particular trading program in spite of trading losses are material points which can also adversely affect actual trading results. There are numerous other factors related to the markets in general or to the implementation of any specific trading program which cannot be fully accounted for in the preparation of hypothetical performance results and all of which can adversely affect actual trading results.
Although the information in communications contained on this website is believed to be materially correct as at the date of issue, no representation or warranty is given as to the accuracy of any of the information provided. Furthermore, no representation or warranty is given in respect of the correctness of the information contained herein as at any future date. Certain information included in communications contained on this website is based on information obtained from third-party sources considered to be reliable. Any projections or analysis provided to assist the recipient of communications contained on this website in evaluating the matters described therein may be based on subjective assessments and assumptions and may use one among many alternative methodologies that produce different results. Accordingly, any projections or analysis should not be viewed as factual and should not be relied upon as an accurate prediction of future results. Furthermore, to the extent permitted by law, SIL, SILP, SIUK, SISPL, SIGPL, the Funds, and their branches, affiliates, agents, service providers and professional advisers assume no liability or responsibility and owe no duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in communications on this website or for any decision based on it.
PAST, PROJECTED AND/OR SIMULATED PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. Past, projected and/or simulated performance may not be a reliable guide to future performance. The actual performance realised by any given investor will depend on numerous factors and circumstances. Communications contained on this website may include returns for various indices. These indices are not intended to be direct benchmarks for a particular Fund, nor are they intended to be indicative of the type of assets in which a particular Fund may invest. The assets invested in by any of the Funds will likely be materially different from the assets underlying these indices, and will likely have a significantly different risk profile. The target returns, volatility and Sharpe ratio figures quoted are targets only and are based over the long term on the performance projections of the investment strategy and market interest rates at time of modelling and therefore may change.
Interests in the Funds and other investments and investment services to which communications contained on this website relate are only available to the persons referred to in the relevant paragraphs above, and other persons should not act on the information contained therein.
Any decision to purchase securities or interests with respect to any of the Funds described herein must be based solely upon the information contained in the Fund Documents, which must be received and reviewed prior to any investment decision. Any person subscribing for an investment must be able to bear the risks involved (including the risk of a total loss of capital) and must meet the suitability requirements relating to such investments. Some or all alternative investment programmes may not be suitable for certain investors.
Among the risks we wish to call to the particular attention of current and prospective investors are the following: (1) each Fund’s investment programme is speculative in nature and entails substantial risks; (2) the investments of each Fund may be subject to sudden and large falls in price or value and there could be a large loss upon realisation of a holder’s investment, which could equal the total amount invested; (3) as there is no recognised market for many of the investments of the Funds, it may be difficult or impossible for a Fund to obtain complete and/or reliable information about the value of such investments or the extent of the risks to which such investments are exposed; (4) the use of a single adviser group could mean a lack of diversification and, consequently, higher risk, and may depend upon the services of key personnel, and if certain or all of them become unavailable, the Funds may prematurely terminate; (5) an investment in a Fund is illiquid and there is no secondary market for the sale of interests in a Fund and none is expected to develop; (6) there are restrictions on transferring interests in a Fund; (7) SIL and its affiliates may receive performance-based compensation, which may result in riskier investments, and the Funds’ fees may offset trading profits; (8) the Funds are subject to certain conflicts of interest; (9) certain securities and instruments in which the Funds may invest can be highly volatile; (10) the Funds may be leveraged; (11) a substantial portion of the trades executed for the Funds take place on non-U.S. exchanges; (12) changes in rates of exchange may also have an adverse effect on the value, price or income of the investments of each Fund; and (13) the Funds are not mutual funds pursuant to, and are therefore not subject to, regulation under the Investment Company Act.
As announced in June 2022, the investment management business of First Quadrant, LLC (“First Quadrant”) was acquired by SIL acting solely in its capacity as general partner of SILP, with certain clients of First Quadrant transferring to SIL before the end of 2022. The information contained in documents and information contained in communications on this website may relate to, or contain, information in respect of, First Quadrant and its management of the assets of certain accounts and investment strategies referred to herein. This information may be subject to updating, completion and amendment. Any performance data and other information in communications contained on this website illustrates the performance of the relevant accounts and strategies (as applicable), and/or provides information in relation to them, in respect of the period during which First Quadrant was appointed as investment manager. The members of the Systematica Group take no responsibility for any such data or information which has not been checked or verified independently by any of the members of the Systematica Group. There is no guarantee that past performance of the relevant accounts and strategies (to the extent managed by First Quadrant) will be replicated under the management of the Systematica Group.
IMPORTANT INFORMATION
BY SELECTING THIS PROFILE YOU WILL HAVE ACCESS TO INFORMATION INTENDED SOLELY FOR PROFESSIONAL INVESTORS WHO BY THEIR NATURE HAVE THE KNOWLEDGE AND SKILLS NEEDED TO REACH AN INVESTMENT DECISION AND CORRECTLY ASSESS THE RISK INCURRED.
YOUR USE OF THIS WEBSITE REQUIRES FULL ACCEPTANCE WITHOUT RESERVATION ON YOUR PART OF THE CONDITIONS OUTLINED BELOW. IF YOU DO NOT ACCEPT THESE CONDITIONS, DO NOT ACCESS THE WEBSITE OR ANY OF ITS PAGES.
INFORMATION ON THIS WEBSITE
General
Subject to the terms and conditions below, Systematica Investments Limited (“Systematica”) operates and is responsible for this website.
Not an offer to purchase
The data and information featured on this website are provided free of charge and solely for information purposes. The information contained herein constitutes neither an offer to purchase nor a solicitation to sell and may not be construed as an investment recommendation on the part of Systematica, its affiliates, managers, officers, or employees and has no legal or contractual value. Any investment in the funds presented on the present website must be made in conformity with the related legal documentation in force (prospectus, Key Investor Information Documents), as approved, where applicable, by the regulatory authority in your country.
Risks of Investing
Investing entails risks, including possible loss of principal. No representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided. No assurances or guarantees are given regarding the performance of any investment.
Past performance may not be repeated and should not be seen as a guide to future performance. The value of investments and the income from them may go down as well as up and investors may not get back the amount originally invested. Exchange rates may cause the value of overseas investments and the income arising from them to rise or fall. The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences.
Materials relating to the investments mentioned on this website should be read in conjunction with a prospectus (available through this website) that describes charges, expenses, and risks. Read it carefully before any investment.
Legal restrictions at local level
The funds presented on this website are not authorised for distribution in all countries, and all sub-funds, classes of shares and, where applicable, categories of shares are not systematically registered in all jurisdictions and may not be available to all investors by virtue of their status. The information contained in the present website is not intended for distribution to, or use by, natural or legal persons that are nationals of a country or subject to a jurisdiction of which the laws or regulations would prohibit such distribution or would require Systematica or the companies in its group to be accredited in said jurisdictions. Access to information contained on the website will not be authorised to any person subject to restrictions, such as nationals of the United States. The investors are solely responsible for ensuring their conformity with the laws and regulations of their country of citizenship and/or residence and it is recommended that they consult their own legal, financial and tax advisors prior to any decision. Persons governed by a country where these investments are forbidden are requested to exit the website.
Accuracy of Information
The information contained on this website (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by Systematica to be reliable, but are not guaranteed as to its accuracy or completeness. Such information is provided without obligation and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at one’s own risk. The information contained on this website does not constitute an offer to buy or sell or an invitation to make an offer to buy or sell shares in any investment fund referred to herein. 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. All information contained on this website may be changed or amended without prior notice although neither Systematica nor any of its associated companies undertakes to update this website regularly.
No Liability
This information on this website has been prepared, approved and issued by Systematica and the information and opinions contained in this website have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, no representation, warranty or undertaking, express or implied, is made by Systematica, its associated companies or any other person as to the reliability, accuracy or completeness of the information contained on this website and no liability is accepted by such persons for the reliability, accuracy or completeness of such information.
SUBJECT TO THE ABOVE PARAGRAPH, SYSTEMATICA HEREBY EXCLUDES ALL LIABILITY FOR ANY DIRECT, INDIRECT, SPECIAL, OR CONSEQUENTIAL LOSS OR DAMAGE (IN EACH CASE INCLUDING BUT NOT LIMITED TO: BUSINESS INTERRUPTION, LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF ANTICIPATED SAVINGS AND/OR LOSS OF GOODWILL) ARISING FROM, OR IN CONNECTION WITH:
WHETHER OR NOT SUCH LOSS IS REASONABLY FORESEEABLE AS AT THE DATE YOU ACCESS THIS WEBSITE OR SYSTEMATICA HAS BEEN ADVISED OF THE POSSIBILITY OF YOU INCURRING SUCH LOSS OR DAMAGE, AND WHETHER OCCASIONED BY THE NEGLIGENCE OF SYSTEMATICA OR ITS EMPLOYEES, AGENTS, OR SUB-CONTRACTORS.
You should be aware that the Internet is not a completely reliable transmission medium. Neither Systematica nor any of its associated companies accepts any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. In addition, neither Systematica nor any of its associated companies accept any responsibility for the security or confidentiality of information transmitted across the internet to or from Systematica or any of its associated companies and any such transmission of information is entirely at your own risk.
Indemnity
You agree to indemnify, defend, and hold harmless Systematica, its affiliates and licensors, and the officers, directors, employees, and agents of Systematica and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website.
Material Interests
Systematica, its associated companies and its and their members and/or directors, officers and/or employees may have holdings in the investment funds referred to on this website and may otherwise be interested in transactions that you effect in those funds.
Linked Websites
This website may be linked to third party websites or contain information provided by third parties. Neither Systematica nor any of its associated companies make any representation as to the accuracy or completeness of such websites or information, have not and will not review or update such websites or information, and caution browsers that any use made of such websites or information is at their own risk. Neither Systematica nor any of its associated companies accepts any liability arising out of the information contained on any linked website or information on this website provided by a third party and the use of such sites and information is at your own risk.
Cookies
A “cookie” is a piece of information that is saved to your PC’s hard disk by the web server. Confirmation of reading and accepting these terms and conditions will place a cookie on your PC’s hard disk. This will ease your navigation around this website by not popping up these terms and conditions again during this browser session. This cookie is temporary and will be removed when you close your browser. The cookie is not used for any other reason.
Intellectual Property
Copyright, trademarks, database rights, patents and all similar rights in this website and the information contained in it are owned by Systematica and its associated companies, their licensors or relevant third party content providers. You may use the information on this website and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means – electronic, mechanical, photocopying, recording or otherwise – without the prior written permission of Systematica. Nothing on this website should be considered as granting any licence or right under any trademark of Systematica or its associated companies or any third party.
Licence
Systematica permits users of this website to make transient copies of it as necessary incidental acts during the viewing of it. Systematica also permits users to download or print a hard copy of individual pages and/or sections of this website for their own use, provided that users do not remove any copyright or other proprietary notices and that such copies are for the user’s own individual use.
You may not modify, copy, distribute, transmit, post, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any pages, data, information, software, products, content, or services obtained from this website, unless you have obtained the prior written permission of Systematica. You may not link to this website, nor frame it, without the express written permission of Systematica.
Downloading Software and Files
If you download software or files from this website, the software—including any files or images incorporated in or generated by the software and data accompanying the software—and files (collectively, the “Files”) are licensed to you by Systematica solely for your personal, non-commercial use. However, Systematica does not transfer title in the Files to you. You own the medium on which the Files are recorded, but Systematica and its licensors retain full and complete title in and to the Files, including all intellectual property rights therein. Save as otherwise permitted by applicable law, you may not redistribute, sell, decompile, reverse engineer, disassemble, or otherwise reduce the Files to any other form whatsoever.
Termination
The rights granted to you herein terminate immediately upon any violation by you of these terms of use. Systematica reserves the right to terminate your access to this website at any time, without notice, for any reason whatsoever. You agree that Systematica shall not be liable to you or any third party for any termination of your access to this website.
Severability
If any provision in these terms and conditions is deemed unlawful, invalid, or for any reason unenforceable, then that provision will be deemed severed from, and will not affect the validity and enforceability of, the remaining provisions.
Unless otherwise agreed, these terms and conditions represent the entire agreement between Systematica and the user relating to the subject matter herein.
Conditions of Use
If you have read and understood these conditions of use you may click the “Accept” button to proceed. By doing so you acknowledge that you understand the conditions of use and agree to abide by them.
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Any communications contained on this website are issued by: (i) Systematica Investments Limited (“SIL”) acting solely in its capacity as general partner of Systematica Investments LP (“SILP”), (ii) Systematica Investments GP Limited and acting through its Geneva branch (“SIGPL”), (iii) Systematica Investments Singapore Pte. Limited (“SISPL”) and/or (iv) Systematica Investments UK LLP (“SIUK”), (each and together “Systematica Investments”). Systematica Investments shall mean: (i) for all purposes, except for issue into the United States or issue to U.S. persons, issue into Australia or to Australian persons, issue into Singapore or to Singaporean persons, or issue into Switzerland or to Swiss persons, SIUK; (ii) only for the purposes of issue into the United States or issue to U.S. persons, SIL acting solely in its capacity as general partner of SILP; (iii) for the purposes of issue into Australia or to Australian persons or issue into Singapore or to Singaporean persons, SISPL; and (iv) only for the purposes of issue into Switzerland or to Swiss persons, SIGPL acting through its Geneva branch.
SIL is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser under the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”). SIL is registered with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a commodity trading advisor and a commodity pool operator and is a member of the U.S. National Futures Association (the “NFA”) in such capacities and is approved by the NFA as a swap firm. SIL as general partner of SILP is licensed and regulated by the Jersey Financial Services Commission (the “JFSC”) under the Financial Services (Jersey) Law 1998 (the “FSJL”) to conduct fund services business in and from within Jersey. The JFSC does not take any responsibility for the financial soundness of the Funds (as defined below) or for the correctness of any statements made or expressed herein. The JFSC is protected by the FSJL against liability arising from the discharge of its functions under that law. SIGPL is licensed and regulated by the JFSC under the FSJL to conduct fund services business in and from within Jersey and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm, and its Geneva branch is authorised by the Swiss Financial Market Supervisory Authority FINMA (“FINMA”) as a branch of a Manager of Collective Assets. SIUK is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”) and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. SISPL is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to “wholesale investors” in Australia (as that term is defined in the Corporations Act 2001 (Cth)), is regulated by the Monetary Authority of Singapore (the “MAS”) under the laws of Singapore, which differ from Australian laws, and is registered with the CFTC as a commodity trading advisor, is a member of the NFA in such capacity and is approved by the NFA as a swap firm. Each of SIUK, SISPL and SIGPL is registered with the SEC as an investment adviser under the Advisers Act. Such registrations, memberships, approvals, authorizations and licenses do not imply that any of the SEC, the CFTC, the NFA, the JFSC, FINMA, the FCA or the MAS have approved any applicable Systematica Investments entity’s qualifications to provide the advisory services set forth in this document.
For the purposes of this disclaimer the “funds” referred to will include each of the funds described herein as well as any other funds, sub-funds, managed accounts, special purpose vehicles or investment vehicles in respect of which SIL has been appointed to act as or shall be appointed to act as, investment manager (each, a “Fund” and together, the “Funds”).
In respect of any content on this website operated by SIUK, the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional clients” as defined in the FCA’s Handbook of Rules and Guidance (the “FCA Handbook”); and (b) are persons who may lawfully receive access to such information under the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “PCISE Order”) (the persons described in (a) and (b) above together, the “Relevant Persons”). Access by persons who are not Relevant Persons is strictly unauthorised.
In respect of content on this website operated by Systematica Investments (excluding SIUK), the following applies. The contents of this website may only be accessed by persons that are resident, domiciled or with a registered office in the United Kingdom who (a) fall within the definition of “professional investors” as defined in the Alternative Investment Fund Managers Regulation (SI 2013/1773) (as amended); and (b) are persons who may lawfully access such information under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2001 (the “FPO”) including by virtue of being investment professionals within the meaning of Article 19(5) of the FPO (the persons described in (a) and (b) above together, the “Permitted Persons”). Access by persons who are not Permitted Persons is strictly unauthorised.
Where communications contained on this website are issued by SIL, the following applies. Communications contained on this website have been prepared in accordance with the requirements of the FSJL and any other legislation, regulations and orders which may be applicable from time to time, together with the requirements of any relevant codes of practice and guidance issued by the JFSC from time to time (the “JFSC Regulatory Requirements”). The information contained in such communications is directed by SIL exclusively at persons who are professional clients or eligible counterparties for the purposes of the JFSC Regulatory Requirements, or, if to U.S. persons (as defined under Regulation S promulgated under the U.S. Securities Act of 1933, as amended (the “Securities Act”)), to U.S. persons who are both accredited investors (as defined under Regulation D promulgated under the Securities Act) and qualified purchasers (as defined in the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”)).
Where communications contained on this website are issued by SISPL, such communications have been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the relevant offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to “wholesale investors” under the Corporations Act 2001 (Cth).
The interests in the Funds have not been filed with or approved or disapproved by any regulatory authority of the United States or any state thereof, nor has any such regulatory authority passed upon or endorsed the merits of an offering of a Fund or the accuracy or adequacy of communications contained on this website. Any representation to the contrary is unlawful.
PURSUANT TO AN EXEMPTION FROM THE COMMODITY FUTURES TRADING COMMISSION IN CONNECTION WITH ACCOUNTS OF QUALIFIED ELIGIBLE PERSONS, THIS BROCHURE OR ACCOUNT DOCUMENT IS NOT REQUIRED TO BE, AND HAS NOT BEEN, FILED WITH THE COMMODITY FUTURES TRADING COMMISSION. THE COMMODITY FUTURES TRADING COMMISSION DOES NOT PASS UPON THE MERITS OF PARTICIPATING IN A TRADING PROGRAM OR UPON THE ADEQUACY OR ACCURACY OF THE COMMODITY TRADING ADVISOR DISCLOSURE. CONSEQUENTLY, THE COMMODITY FUTURES TRADING COMMISSION HAS NOT REVIEWED OR APPROVED THIS TRADING PROGRAM OR THIS BROCHURE OR ACCOUNT DOCUMENT.
The distribution of information or documents contained in communications on this website may be further restricted by law. No action has been or will be taken by SIL or any Fund to permit the possession or distribution of the information or documents contained in communications on this website in any jurisdiction (other than as expressly stated by Systematica Investments) where action for that purpose may be required. Accordingly, documents and information contained in communications on this website may not be distributed, or forwarded to recipients, in any jurisdiction except under circumstances that will result in compliance with any applicable laws and regulations. It is the responsibility of the recipient of information or documents contained in communications on this website (or its agent or adviser, as the case may be) to ensure that any individuals (whether employed by them or otherwise) who receive the information herein do so in accordance with applicable law and regulation. Persons to whom documents and information contained in communications on this website are communicated should inform themselves about and observe any such restrictions.
Recipients of any communications contained on this website should note that electronic communication, whether by email, website, SWIFT or otherwise, is an unsafe method of communication. Emails and SWIFT messages may be lost, delivered to the wrong address, intercepted or affected by delays, interference by third parties or viruses and their confidentiality, security and integrity cannot be guaranteed. None of the Funds or Systematica Investments bear any liability or responsibility therefor.
Distribution and Selling Restrictions: The distribution of documents and information contained in communications on this website and the offering or purchase of interests in the Funds may be restricted in certain jurisdictions. No persons receiving a copy of documents or information contained in communications on this website in any such jurisdiction may treat such information or documents as constituting marketing or an invitation to them to subscribe for interests in the Funds. Accordingly, documents and information contained in communications on this website do not constitute marketing, an offer or solicitation by anyone in any jurisdiction in which such marketing, offer or solicitation is not lawful or in which the person marketing or making such offer or solicitation is not qualified to do so or to anyone to whom it is unlawful to market or make such offer or solicitation. It is the responsibility of any persons in possession of documents or information contained in communications on this website, including individuals who may be employed by or a consultant to the recipient, to inform themselves of, and to observe, all applicable laws and regulations of any relevant jurisdiction. If any recipient, including individuals, is or becomes aware that the receipt of documents or information contained in communications on this website by them contravenes any law or regulation, they must destroy it or return it to Systematica Investments immediately. Prospective applicants for interests in the Funds should inform themselves as to the legal requirements of so applying and any applicable exchange control regulations and taxes in the countries of their respective citizenship, residence or domicile.
Information for investors in the European Economic Area (the “EEA”) and the United Kingdom (“UK”): Investors that are resident, domiciled or with a registered office in any Member State of the EEA or the UK should note that access to this website is restricted to “professional investors” within the meaning of Directive 2011/61/EU (as amended and as implemented into local law or regulations in each EEA Member State, and in respect of the UK, as it forms part of UK law by virtue of the European Union (Withdrawal) Act 2018 (as amended), “AIFMD”). Access by persons that are not “professional investors” within the meaning of AIFMD is strictly unauthorised.
Information for investors in Switzerland: Any distribution or offer of interests in the Funds in Switzerland is exclusively made to, and directed at, qualified investors (“Qualified Investors”), as defined in the Swiss Collective Investment Schemes Act of 23 June 2006, as amended, and its implementing ordinance. Accordingly, the Funds have not been and will not be registered with FINMA for distribution to non-qualified investors. Any Funds which are Delaware limited partnerships are not distributed in Switzerland and are not available for subscription by investors in Switzerland. If a Swiss representative has been appointed in respect of a Fund, offering materials relating to interests in that Fund may be obtained by Qualified Investors in Switzerland from the Swiss representative and/or authorised distributors. Swiss representative (where appointed): Mont-Fort Funds AG, 63 Chemin Plan-Pra, 1936 Verbier, Switzerland. Swiss paying agent (where appointed): Neue Helvetische Bank AG, Seefeldstrasse 215, CH-8008 Zurich, Switzerland. In respect of the distribution of interests in the Funds in and from Switzerland, the place of performance and jurisdiction is the registered office of the Swiss representative. Systematica Investments GP Limited, Geneva Branch is affiliated with the Swiss Arbitration Centre (formerly known as the Swiss Chambers’ Arbitration Institution) for the provision of ombudsman services under the Swiss Federal Act on Financial Services.
Information for investors in Australia: To the extent that communications contained on this website are issued by SISPL, such communications has been prepared without taking into account the objectives, financial situation or needs of Australian persons who receive such communications. Before making an investment decision, Australian persons who receive such communications should consider the offering document, if applicable, and assess whether the product is appropriate given your objectives, financial situation or needs. Communications contained on this website are only to be made available to ‘wholesale investors’ under the Corporations Act 2001 (Cth).
Information for investors in Singapore: The Funds are not authorised or recognised by the MAS and interests in any Funds are not allowed to be offered to the retail public. Communications contained on this website and any other communication or material in connection with the offer, sale, invitation for subscription or purchase of interests in any Fund may not be circulated or distributed, nor may interests in any Fund be offered, sold or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to the public or any member of the public in Singapore other than a person who is an accredited investor or an institutional investor (each as defined under the Securities and Futures Act (Chapter 289) of Singapore) (“SFA”) or unless otherwise permitted under any applicable exemption. Communications contained on this website and any other communications or material in connection with the offer or sale, or invitation for subscription or purchase, of interests may not be circulated or distributed, nor may interests be offered or sold, or be made the subject of an invitation for subscription or purchase, whether directly or indirectly, to persons in Singapore other than in accordance with the conditions set out in the applicable provisions of the SFA. Communications contained on this website and any other communication or material issued in connection with the offer or sale is not a prospectus as defined in the SFA and has not been registered as a prospectus with the MAS. Accordingly, statutory liability under the SFA in relation to the content of prospectuses would not apply. Each prospective investor should consider carefully whether the investment is suitable for him.
SIL, as general partner of SILP (SIL together with SILP and each of their subsidiaries and affiliates, the “Systematica Group”), was appointed as investment manager of the Funds on or after 1 January 2015 following the “spin-out” of the Systematica Group. Any Fund performance information in communications contained on this website relating to dates prior to 1 January 2015 illustrates the performance of the Funds whilst the predecessors of the Systematica Group were appointed as investment manager to the Funds. There is no guarantee that past performance of the Funds will be replicated under the management of the Systematica Group.
Communications contained on this website are not intended to constitute, and should not be construed as, investment advice, investment recommendations or investment research. Current and prospective investors acknowledge that no member of the Systematica Group has conducted or will conduct the activity of reception and transmission of orders in relation to the interests of the Funds, whether for the Funds, investors or otherwise. Potential investors in the Funds should seek their own independent financial, tax, legal and other advice. Communications contained on this website have been made available to you for informational purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to herein or for any other purpose. Communications contained on this website are not intended as and are not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such a solicitation or offer. Before making any investment decision you should obtain independent legal, tax, accounting or other professional advice, as appropriate, none of which is offered to you by the members of the Systematica Group or any of their affiliates. None of the members of the Systematica Group or any of their affiliates accepts any duty of care to you in relation to any investment in the Funds.
The terms of investment in any of the Funds described herein or any other Fund are solely as set out in the relevant Fund’s prospectus or private placement memorandum (including any supplements thereto), as the case may be, application forms and/or memorandum and articles of association or limited partnership agreement or instrument of incorporation, as the case may be (collectively, the “Fund Documents”). Before acquiring an interest in any Fund, each prospective investor is required to confirm that it has carefully reviewed the various risks of an investment in the Fund, as set out in the Fund Documents, and is required to acknowledge and agree to the existence of any actual and potential conflicts of interests described in the Fund Documents and waive, to the fullest extent permitted by any applicable law, any claim with respect to the existence of any such conflicts.
Communications contained on this website may contain simulated performance results achieved by means of the retroactive application of Systematica Investments’ investment methodology, or the real-time application of a hypothetical capital allocation to such strategy. Hypothetical performance results have many inherent limitations, some of which are described below. No representation is being made that any particular trading program will or is likely to achieve profits or losses similar to those shown. In fact, there are frequently sharp differences between hypothetical performance results and the actual results subsequently achieved by any particular trading program. One of the limitations of hypothetical performance results is that they are generally prepared with the benefit of hindsight. In addition, hypothetical trading does not involve financial risk, and no hypothetical trading record can completely account for the impact of financial risk in actual trading. For example, the ability to withstand losses or to adhere to a particular trading program in spite of trading losses are material points which can also adversely affect actual trading results. There are numerous other factors related to the markets in general or to the implementation of any specific trading program which cannot be fully accounted for in the preparation of hypothetical performance results and all of which can adversely affect actual trading results.
Although the information in communications contained on this website is believed to be materially correct as at the date of issue, no representation or warranty is given as to the accuracy of any of the information provided. Furthermore, no representation or warranty is given in respect of the correctness of the information contained herein as at any future date. Certain information included in communications contained on this website is based on information obtained from third-party sources considered to be reliable. Any projections or analysis provided to assist the recipient of communications contained on this website in evaluating the matters described therein may be based on subjective assessments and assumptions and may use one among many alternative methodologies that produce different results. Accordingly, any projections or analysis should not be viewed as factual and should not be relied upon as an accurate prediction of future results. Furthermore, to the extent permitted by law, SIL, SILP, SIUK, SISPL, SIGPL, the Funds, and their branches, affiliates, agents, service providers and professional advisers assume no liability or responsibility and owe no duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in communications on this website or for any decision based on it.
PAST, PROJECTED AND/OR SIMULATED PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. Past, projected and/or simulated performance may not be a reliable guide to future performance. The actual performance realised by any given investor will depend on numerous factors and circumstances. Communications contained on this website may include returns for various indices. These indices are not intended to be direct benchmarks for a particular Fund, nor are they intended to be indicative of the type of assets in which a particular Fund may invest. The assets invested in by any of the Funds will likely be materially different from the assets underlying these indices, and will likely have a significantly different risk profile. The target returns, volatility and Sharpe ratio figures quoted are targets only and are based over the long term on the performance projections of the investment strategy and market interest rates at time of modelling and therefore may change.
Interests in the Funds and other investments and investment services to which communications contained on this website relate are only available to the persons referred to in the relevant paragraphs above, and other persons should not act on the information contained therein.
Any decision to purchase securities or interests with respect to any of the Funds described herein must be based solely upon the information contained in the Fund Documents, which must be received and reviewed prior to any investment decision. Any person subscribing for an investment must be able to bear the risks involved (including the risk of a total loss of capital) and must meet the suitability requirements relating to such investments. Some or all alternative investment programmes may not be suitable for certain investors.
Among the risks we wish to call to the particular attention of current and prospective investors are the following: (1) each Fund’s investment programme is speculative in nature and entails substantial risks; (2) the investments of each Fund may be subject to sudden and large falls in price or value and there could be a large loss upon realisation of a holder’s investment, which could equal the total amount invested; (3) as there is no recognised market for many of the investments of the Funds, it may be difficult or impossible for a Fund to obtain complete and/or reliable information about the value of such investments or the extent of the risks to which such investments are exposed; (4) the use of a single adviser group could mean a lack of diversification and, consequently, higher risk, and may depend upon the services of key personnel, and if certain or all of them become unavailable, the Funds may prematurely terminate; (5) an investment in a Fund is illiquid and there is no secondary market for the sale of interests in a Fund and none is expected to develop; (6) there are restrictions on transferring interests in a Fund; (7) SIL and its affiliates may receive performance-based compensation, which may result in riskier investments, and the Funds’ fees may offset trading profits; (8) the Funds are subject to certain conflicts of interest; (9) certain securities and instruments in which the Funds may invest can be highly volatile; (10) the Funds may be leveraged; (11) a substantial portion of the trades executed for the Funds take place on non-U.S. exchanges; (12) changes in rates of exchange may also have an adverse effect on the value, price or income of the investments of each Fund; and (13) the Funds are not mutual funds pursuant to, and are therefore not subject to, regulation under the Investment Company Act.
As announced in June 2022, the investment management business of First Quadrant, LLC (“First Quadrant”) was acquired by SIL acting solely in its capacity as general partner of SILP, with certain clients of First Quadrant transferring to SIL before the end of 2022. The information contained in documents and information contained in communications on this website may relate to, or contain, information in respect of, First Quadrant and its management of the assets of certain accounts and investment strategies referred to herein. This information may be subject to updating, completion and amendment. Any performance data and other information in communications contained on this website illustrates the performance of the relevant accounts and strategies (as applicable), and/or provides information in relation to them, in respect of the period during which First Quadrant was appointed as investment manager. The members of the Systematica Group take no responsibility for any such data or information which has not been checked or verified independently by any of the members of the Systematica Group. There is no guarantee that past performance of the relevant accounts and strategies (to the extent managed by First Quadrant) will be replicated under the management of the Systematica Group.
DATA PROTECTION REGULATION MATTERS – PRIVACY NOTICE
Each of (i) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“EU GDPR”), (ii) the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR” and together with EU GDPR, “GDPR”) and (ii) the Cayman Islands Data Protection Act (As Revised) (and any associated guidance and regulations, together, “DPA” and together with GDPR, the “Data Protection Laws”) is applicable, to the extent relevant, to the processing of personal data by each of Systematica Investments Services Limited, Systematica Investments UK LLP (“SIUK”), Systematica Investments Limited, Systematica Investments LP, Systematica Investments Holdings Limited, Systematica Investments Guernsey LP, Systematica Investments GP Limited, Systematica Investments US LLC, Systematica Investments Singapore Pte. Ltd and Systematica Investments Shanghai Co., Ltd (the “Systematica Entities”) in the course of their businesses, and certain other persons. This notice sets out information relating to those activities.
The Systematica Entities
The Systematica Entities are controllers of personal data for the purposes of the Data Protection Laws and will, in the course of each Systematica Entity’s business, process personal data. Information regarding such processing is set out herein.
Any person seeking information with respect to control or processing of personal data by any of the Systematica Entities or seeking to exercise any rights afforded to them under the Data Protection Laws should contact the compliance department of SIUK at [email protected].
Under the Data Protection Laws, any person wishing to is entitled to make a complaint with respect to any of the Systematica Entities’ control or processing of personal data. Under GDPR, such a complaint may be made to the Information Commissioner’s Office (“ICO”). The ICO is the UK supervisory authority for data protection issues. Contact details for the ICO may be found at www.ico.org.uk. Under DPA, such a complaint may be made to the Cayman Islands Ombudsman (“Ombudsman”). The Ombudsman is the Cayman Islands supervisory authority for data protection issues. Contact details for the Ombudsman may be found at www. ombudsman.ky.
The policies and procedures adopted by the Systematica Entities with respect to the control or processing of personal data may be amended from time to time. Similarly, the purposes for which the Systematica Entities may control or process personal data may change from time to time. If any changes would require a material amendment to the information set out herein, details of such changes will be made available in the current version of this document from time to time.
Summary of Personal Data
For the purposes of the Data Protection Laws, personal data means any information about an individual from which that person can be identified, directly or indirectly. In the course of their business, the Systematica Entities may collect, use, store, transfer and process personal information from individuals, including former, current or prospective investors and other natural persons, and former, current and prospective employees, directors, officers or other representatives or agents of market counterparties, professional services and other service providers, trade associations, public bodies and other entities or undertakings. Such personal data is typically limited in scope, and includes, for example, the name and contact details of such individuals, as well as some technical data (such as internet protocol addresses), usage data and information about marketing and communication preferences. On occasions, the Systematica Entities may also process personal data of such individuals which includes other identifiers such as date of birth, social security number, tax identification number, passport, national identity or driver’s licence number. Personal data that the Systematica Entities collect may also include commercial information, such as records of products or services purchased, obtained or considered, or other purchasing histories or tendencies, including funds invested in, investments considered, or sources of wealth; and professional or employment-related information, such as investment experience, occupation, compensation, employer and title.
In addition, the Systematica Entities may also collect, use, store, transfer and process personal information concerning current or former applicants for positions of employment at or membership of, or current or former employees or members of, the Systematica Entities. Such personal data may include some or all of the following: name and contact details, information about employment and educational history, performance records, salary data, references, bank account details, identification data, tax information, social security numbers and information regarding immigration status. The Systematica Entities will endeavour to contact those former job applicants or former employees if the personal data processed in relation to the same is material, sensitive or particularly private in order to inform them of the continued processing of their personal data, the nature of that processing, the lawful basis upon which the processing is taking place, and their rights under the Data Protection Laws with respect to such processing.
In certain limited circumstances, the Systematica Entities may process special categories of personal data (which may include details about people’s racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about people’s health, genetic and biometric data and information about criminal convictions and offences).
Collection of Personal Data
The Systematica Entities may collect personal data through a range of means. These may include direct interactions (where a person provides personal data to the relevant Systematica Entity through correspondence or other direct methods of communication), through third-party service providers (for example, recruitment agents) or publicly available sources (where a Systematica Entity receives personal data through a publicly available source such as a website or publicly-available registry).
Purposes for Collection and Use of Personal Data
The Systematica Entities will only process personal data in circumstances where they have established a lawful basis under the Data Protection Laws to do so. These circumstances include where the processing of the relevant data relates to a legitimate interest of the relevant Systematica Entity, further described below. In such circumstances the Systematica Entities will have established that the processing is necessary for the relevant purpose, and not inconsistent with the interests, rights or freedoms of a relevant data subject.
In accordance with the above, each Systematica Entity has determined that the lawful bases for its processing of personal data are the legitimate interests of the relevant Systematica Entity to undertake activities necessary and ancillary to the carrying on of an investment management business, including where necessary for the purposes of the relevant Systematica Entity carrying out its activities relating to any fund, vehicle or account in respect of which a Systematica Entity acts as investment manager, sub-investment manager, investment adviser or sub-investment adviser (the “Funds”), the administration of the Funds, the investment activities of the Funds, otherwise in furtherance of any contract entered into with respect to the activities of the Funds, to exercise and comply with the relevant Fund’s or Systematica Entity’s rights and obligations at law or under regulation where such obligations are not set out under the laws of any member state of the European Economic Area (“EEA”) or the United Kingdom, to establish, exercise or defend legal claims and in order to protect and enforce its (or another person’s) rights, property, or safety, or to assist others to do the same, and in order to provide information about its services and any investment products it offers.
In addition, each Systematica Entity may also control or process personal data where necessary to comply with legal or regulatory obligations applicable to them under the laws of the Cayman Islands, the United Kingdom, the European Union or any member state of the EEA, or in order to give effect to a contract, or to take necessary pre-contractual steps with a view to potentially entering into a contract (including in its capacity as an employer or a prospective employer), or where an individual has provided their consent to such processing, to the extent applicable.
Systematica Entities may from time to time control or process personal data for the purposes of operating their business, entering into contractual arrangements in the context of their investment management business, including in respect of the Funds marketing, and advertising the Funds and/or other investment vehicles and/or services related to the Systematica Entities. Any person who does not wish their personal data to be processed for marketing purposes may opt out of such processing by notifying the compliance department of SIUK at [email protected].
Any Systematica Entity will only use personal data for the purposes that it has been collected for, unless they reasonably consider that they need to use it for another reason and that reason is compatible with the original purpose of the control or processing. Any person requiring information with respect to any additional purpose for which personal data may be controlled or processed may obtain such information from the compliance department of SIUK. If a Systematica Entity needs to control or process personal data for an unrelated purpose, the relevant Systematica Entity will use its reasonable endeavours to notify affected persons and to explain the basis on which they are permitted to undertake the same.
The Systematica Entities may be legally obliged to process certain personal data in order to be able to perform services and business operations or to comply with contractual requirements. If individuals choose not to provide the Systematica Entities with the necessary personal data or to restrict the Systematica Entities from processing personal data, the Systematica Entities may not be able to meet their obligations or deliver the products or services requested. This may lead to cancellation of contracts; if this is the case, the relevant Systematica Entity will endeavour to contact the individuals to discuss this.
Disclosure of Personal Data
Each Systematica Entity may share personal data with certain third parties for the purposes set out above. The relevant third parties with whom such personal data may be shared include entities appointed to provide services to the Funds, the relevant Systematica Entity and their affiliates, including professional service providers such as banks, auditors, law firms, consultants and other third parties; regulatory, legal and tax authorities; and third parties in the event any Systematica Entity sells or transfers all or a portion of its business or assets (including in the event of a reorganisation, dissolution or liquidation. Further details of the third parties with whom personal data may be shared are available on request from the compliance department of SIUK. Wherever possible, personal data will only be disclosed by a Systematica Entity to a third party in circumstances where that third party has agreed to respect the security of personal data and treat it in accordance with applicable law. The Systematica Entities will seek to ensure that third parties to whom any personal data may be disclosed will not use personal data for their own purposes and only process personal data for specified purposes and otherwise in accordance with the instructions of the relevant Systematica Entity and/or with the Data Protection Laws.
Transfer of Personal Data outside the EEA, the United Kingdom or the Cayman Islands
The activities of the Systematica Entities are such that it may be necessary for personal data to be transferred and/or processed outside the EEA, the United Kingdom or the Cayman Islands.
In circumstances where a Systematica Entity transfers personal data outside the EEA, the United Kingdom or the Cayman Islands, they will seek to ensure a similar degree of protection is afforded to it by ensuring that personal data is generally transferred only to persons in countries outside the EEA, the United Kingdom or the Cayman Islands in one of the following circumstances:
Further information on specific mechanisms utilised by Systematica Entities transferring personal data outside the EEA, the United Kingdom or the Cayman Islands and the countries to which such transfer may be made (which may include, but are not limited to The Bailiwick of Jersey, the Bailiwick of Guernsey, Switzerland, Singapore, the Cayman Islands and the United States) may be obtained from the compliance department of SIUK upon request.
Data Security and Retention
To protect personal data from unauthorised access and use, the Systematica Entities take reasonable steps to use technical, administrative, organisational and physical security measures appropriate to the nature of the personal data they are processing. The Systematica Entities generally restrict access to personal data to those employees and agents who have been advised as to the proper handling of such information and who need to know such data in order to operate the business. Given the nature of information security, there is no guarantee that such safeguards will always be successful.
Each Systematica Entity will retain personal data for as long as necessary to fulfil the purposes for which it has been collected. This will include any period of retention required to satisfy any legal, regulatory, taxation, accounting, regulatory or reporting requirement applicable to the relevant Systematica Entity.
In determining the appropriate retention period for any personal data, the relevant Systematica Entity will consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of the data, the purpose for which the relevant data is being processed, the extent to which the purposes for which the relevant data is being processed can be achieved by other means and any applicable legal requirements. Without prejudice to the generality of the forgoing, the Systematica Entities have determined that they will retain records for at least 6 years.
Details of retention periods applicable to personal data subject to the Data Protection Laws are available upon request from the compliance department of SIUK. In some circumstances, a person may request that a Systematica Entity delete any personal data retained by it. Further, in some circumstances, a Systematica Entity may anonymize personal data for research or statistical purposes, in which case such information will no longer be linked to an individual and will not constitute personal data and may be retained and utilised indefinitely without further notice.
Rights of Persons
Under the Data Protection Laws, persons whose data is processed by a Systematica Entity will have certain rights. These rights include the right to access personal data, the right to require correction of personal data, the right to require erasure of personal data in certain circumstances, the right to restrict processing of personal data, the right to require a transfer of personal data, and the right to withdraw consent to the processing of personal data, to the extent applicable. In addition, if the processing of personal data is based on a legitimate interest of a Systematica Entity, a person will have the right to object to the processing of that personal data.
Any person seeking to exercise any such right should contact the compliance department of SIUK. In certain circumstances, the relevant Systematica Entity may charge reasonable fees if any such request is clearly unfounded, repetitive or excessive.
Links to External Websites
Our website may contain links to third party websites. Any access to and use of such third party websites is not governed by this Privacy Notice, but, instead, is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
The California Consumer Privacy Act
The California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”) imposes certain obligations on the Systematica Group and certain funds managed by the Systematica Group (together, “we” or “us”) and grants certain rights to California resident investors (“California Resident,” “you,” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California Resident or a household. It does not include de-identified information, aggregate consumer information or publicly available information (as defined in the CCPA).
Purposes for Collecting and Using Personal Information
We may collect or use your personal information for the following business or commercial purposes: (i) performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions, and withdrawals, verifying information, processing payments or providing similar services; (ii) performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting and other operational matters; (iii) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, anti-terrorist financing, and conflict checks; and (iv) enabling or effecting commercial transactions, including, using bank account details to remit funds and process distributions.
Personal Information We Collect
We may collect the following categories of personal information from or about a California Resident: (i) identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers; (ii) certain information protected under federal or state laws such as a signature, account balances, wire instructions, credit card information, bank account or other financial information; (iii) characteristics of protected classifications under federal or certain state laws, including, gender, age, national origin, citizenship or marital status; (iv) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth; (v) internet or other electronic network activity information, including interactions with our website or use of certain online tools; (vi) geolocation data; (vii) professional or employment-related information, including occupation, compensation, employer, and title; and (viii) inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds. We may disclose for a business purpose all or just a few of the above categories of personal information.
Sources of Personal Information
We may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; and/or (v) from information captured on applicable websites. In addition, we may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Sharing Personal Information with Third Parties
We do not sell your personal information. We may disclose personal information to third parties in circumstances where we believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, to protect our rights or property, or upon reasonable request by the fund in which you have invested. We also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent.
We may disclose your personal information to our service providers or other entities that have agreed to limitations on the use of your personal information or that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA or other applicable laws.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions (“request to delete”); and (iv) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (v) limit the use and disclosure of sensitive personal information where required by the CCPA (“right to limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit); (vi) correct inaccurate personal information (“request to correct”) that a business maintains about a consumer; (vii) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting the personal information; (d) the categories of third parties with whom we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose; (viii) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); and (ix) not be discriminated against because you exercised any of your rights under the CCPA.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information, including, generally, personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit a “request to know,” “request to delete,” or “request to correct,” each as described above, by calling us at +44 020 3180 5700, or through our website at the following link: https://www.systematica.com/contact-us/
We are required to provide certain information or, to delete personal information or to correct inaccurate personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Request to Know, Request to Delete or Request to Correct, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, phone number and email address, and we may require you to discuss the request with us over the phone. This measure is in place to help ensure that personal information is not disclosed to any person who does not have the right to receive it. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a “request to know,” “request to delete,” or “request to correct,” on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We will deliver responses to verifiable consumer requests, free of charge, either through your online account with one of our service providers, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.
Contact for More Information
If you have any questions or concerns about this notice please contact us at [email protected]
COOKIES POLICY
This website uses cookies, which are tiny files that are downloaded to your computer or other device to improve your experience. Cookies allow a site or services to know if your computer or device has visited that site or service before. Cookies can then be used to help understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure the marketing you see online is more relevant to you and your interests.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed.
This page describes what information the cookies gather, how we use that information and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored; however, preventing the cookies from being stored may downgrade or ‘break’ certain elements of the sites functionality.
THE TYPES OF COOKIES WE USE
There are generally two types of cookies that we use: “Performance” and “Functionality”. The following is a brief description of each cookie category.
1. Performance Cookies. These cookies collect information about how you have used the website, for example, information related to the unique username you have provided. These cookies may also be used to allow us to know that you have logged in so that we can serve you fresher content than a user who has never logged in. We also use cookies to track aggregate website usage and experiment with new features and changes on the website. The information collected is used to improve how the website works.
2. Functionality Cookies. These cookies allow us to remember how you’re logged in, whether you chose to no longer see advertisements, whether you made an edit to an article on the website while logged out, when you logged in or out, the state or history of website tools you’ve used. These cookies also allow us to tailor the website to provide enhanced features and content for you and to remember how you have customized the website in other ways, such as customizing the toolbars we offer in the right column of every page. The information these cookies collect may be anonymous, and they are not used to track your browsing activity on other sites or services.
The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
| Cookie Type | Name | Purpose |
|---|---|---|
| Functionality | disclaimer_agreed | To suppress the Disclaimer after users have dismissed it. |
| Functionality | Cookies_saw | To suppress the cookies notification ribbon after users have dismissed it |
| Functionality | Notification | To suppress notification pop-up from reappearing on the landing page. |
DISABLING COOKIES
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site.
THIRD PARTY COOKIES
In some cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
From time to time we may test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimizations our users appreciate the most.
MORE INFORMATION
For more information please contact us through our preferred contact method.
Email: [email protected]