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Risk management

Risk controls permeate every part of Threadneedle's business, from portfolio construction to the day-to-day running of portfolios. Risk control is one half of our performance objective namely, to seek superior returns for an appropriate level of risk.

Threadneedle's risk management process consists of the following elements:

Risk control at a team level

On a weekly basis, the team heads meet with portfolio managers to cover research ideas, portfolio activity, construction and risk. Portfolio analytics are available in real time to individual portfolio managers and other members of the investment team, including the Quantitative (Quant) team.

Risk control at a senior level

Risk reports are prepared daily by the Quant team for individual portfolio managers and team heads. The intention of the risk reports is to highlight any undue volatility within products and individual portfolios. They are reviewed on a monthly basis by the team heads and the Chief Investment Officer, to ensure that client and house objectives continue to be met in an appropriate manner. The Chief Investment Officer reviews on a more formal quarterly basis the performance and risk characteristics of each investment product in conjunction with each team head on a team-by-team basis. The performance of different products is also formally reviewed quarterly by the relevant board or governing management committee of the Threadneedle legal entity or business stream responsible for the product.

Risk control via a Compliance function

Threadneedle uses an external system which checks client guidelines pre and post-trade daily. We have a dedicated compliance team who operate a dynamic risk-based monitoring programme.

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Important Information

The information in this site is only aimed at and applicable to private investors who are residents of the Netherlands.

 
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The Important Legal Information is in three sections: (1) a disclaimer, (2) terms and conditions governing the use of the website and (3) a privacy statement. Please scroll down below to read these sections. If you do not agree and acquiesce to any part of any section please do not accept and enter the website

About this site

Products and services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Those accessing this website must select their country of residence or investor status and may not access any other country areas or view content not aimed at their country of residence or investor status. This website is not directed at you if Threadneedle is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use that would be contrary to local law or regulation.

This website is not directed at persons in any jurisdiction other than those listed above. Specifically it is not aimed at US persons. The products described in this website have not been registered under the U.S. Securities Act of 1933, and are not offered and may not be sold in the United States or to U.S. citizens and residents or any other person in any jurisdiction or country where offering or selling such products would be contrary to local law or regulation. This information is not an invitation to subscribe for units or shares in any funds described herein and is a way of information only.

Some generic information about Threadneedle may be viewed without selection of country of residence.

The areas on this website that are reserved for professional or institutional investors, journalists, financial advisers etc. must not be accessed by private investors. Threadneedle will not be liable for any damages or losses suffered by private investors accessing these areas.

Information from this website must not be issued in any jurisdiction where prohibited by law and must not be used in any way that would be contrary to local law or regulation. Specifically, the products and services mentioned on this Website must not be promoted in any jurisdiction where this would not be permitted.

Information included in this website is not directed at investors who, according to applicable laws and regulations, are not permitted to acquire, distribute, commercialise or be the addressees of an offer of the products mentioned on this website. This is why investors are required to previously inform themselves on the legal requirements, terms and conditions for the acquisition, distribution or commercialisation of such products.

Should an offer, acquisition, sale, solicitation, disclosure, promotion or publicity of the products mentioned on this website be deemed unlawful or illegal, according to the laws and regulations applicable in a given country, territory or jurisdiction, such an offer, acquisition, sale, solicitation, disclosure, promotion or publicity shall be deemed as not being made in such country, territory or jurisdiction nor addressed at any persons resident or domiciled therein.

This website is merely informative and does not allow for any subscription, acquisition, sale, transmission or any other action or operation relating to the products and services mentioned on this website.

No person or company (including other financial services sector related companies) may link their website to the www.threadneedle.com website without the express written permission of Threadneedle.

Threadneedle does not give investment advice or recommendations in respect of its product range or services offered. Nothing on this site should be construed as the giving of investment advice or recommendations.

If choosing to buy any Threadneedle product from this website you should not rely solely on the information contained on those pages. You should read carefully the terms and conditions relating to any product to be purchased.

Although Threadneedle shall use all reasonable endeavours to ensure that the information on this website is kept up-to-date, it cannot be held responsible for any losses or damage incurred as a result of using any out-of-date or superseded documentation on this website.

Risk Warning

Past performance is not a guide to future returns. The value of investments and any income from them is not guaranteed and may fall as well as rise and the investor may not get back the original investment. Exchange rate movements could increase or decrease the value of underlying investments/holdings.

Risks are attached to every kind of investment. Information regarding the specific risks of the products described in the website and the investment techniques and investment instruments employed in the products described in the website is disclosed individually in the relevant prospectus or other offering documents of the products.

Investors should consider all risks carefully prior to investing in any units or shares in any funds and should consult (as necessary) any independent financial advisers and legal, accounting, tax and other advisers with respect to any investment in the products mentioned herein.

The mention of any specific shares or bonds should not be taken as a recommendation to deal and anyone considering dealing in these financial instruments should consult a stockbroker or financial adviser.

The research and analysis included in this website has been produced by Threadneedle for its own investment management activities, may have been acted upon prior to publication and is made available here incidentally. Information obtained from external sources is believed to be reliable but its accuracy or completeness cannot be guaranteed. Any opinions expressed are made as at the date of publication but are subject to change without notice.

Additional information for investors

Threadneedle (Lux) and World Express Funds II are open-ended investment companies with variable capital (société d'investissement à capital variable) incorporated under the laws of the Grand Duchy of Luxembourg. The management company of Threadneedle (Lux) and World Express Funds II is Threadneedle Management Luxembourg S.A. who is advised by Threadneedle Asset Management Ltd. and/or selected sub-advisors.
Dutch prospective investors are informed that not all sub-funds of Threadneedle (Lux) and World Express Funds II may be registered for public offer in The Netherlands. For a list of sub-funds and their registration, click here.

Threadneedle Investment Funds ICVC, Threadneedle Specialist Investment Funds ICVC and Threadneedle Focus Investment Funds ICVC are open-ended investment companies structured as umbrella companies; incorporated in England and Wales, authorised and regulated in the UK by the Financial Services Authority (FSA).

The incorporation of the funds in Luxembourg or England and Wales does not, however, require any authority to approve or disapprove either the adequacy of accuracy of the website, the prospectus of the funds or the assets held by the various portfolios/sub-funds of the funds. Any representations to the contrary are unauthorised and unlawful.

Subscriptions to a fund may only be made on the basis of the current Prospectus and the Key Investor Information Document or Simplified Prospectus and the latest annual or interim reports, which can be obtained free of charge, and the applicable Terms and Conditions from your financial adviser, the local distributor or:

- For Threadneedle(Lux), from the registered office at 69, route d'Esch, L-1470 Luxembourg and for World Express Funds II, at 5 allée Scheffer, L-2520 Luxembourg; and

- For Threadneedle Investment Funds ICVC, Threadneedle Specialist Investment Funds ICVC and Threadneedle Focus Investment Funds ICVC, from MeesPierson Intertrust, Rokin 55, NL 1012 KK Amsterdam.

Website terms and conditions

IMPORTANT NOTICE

THE OWNER OF THIS WEBSITE AND ALL RIGHTS RELATED TO IT IS "Threadneedle" AS DEFINED BELOW.  NOTWITHSTANDING ANY BRANDING APPARENT FROM VIEWING THE WEBSITE, IT IS IMPORTANT TO NOTE THAT ANY AND ALL CONNECTION THROUGH THIS WEBSITE IS WITH "Threadneedle".

THREADNEEDLE ONLINE TERMS AND CONDITIONS

PLEASE READ THE FOLLOWING: THE DISCLAIMER, PRIVACY POLICY AND THESE TERMS AND CONDITIONS (TOGETHER THE "Terms and Conditions"), BEFORE USING THE ONLINE SERVICES OR THIS WEBSITE ("Website")

THIS IS A LEGALLY BINDING AGREEMENT BETWEEN YOU AND THREADNEEDLE ESTABLISHING THE TERMS AND CONDITIONS UNDER WHICH THIS WEBSITE MAY BE USED. BY USING THIS WEBSITE YOU ARE DEEMED TO HAVE UNCONDITIONALLY ACCEPTED THESE TERMS AND CONDITIONS.

IF YOU DO NOT ACCEPT THESE TERMS AND CONDITIONS DO NOT ACCESS THIS WEBSITE AND DO NOT USE THE ONLINE SERVICES.

IF YOU ARE ACCESSING THIS WEBSITE OR OTHER THREADNEEDLE GROUP COMPANIES WEBSITES OUTSIDE THE UNITED KINGDOM FROM THIS WEBSITE YOU SHOULD READ THE APPROPRIATE TERMS AND CONDITIONS, IF APPLICABLE, FOR THAT WEBSITE.

NOTHING ON THIS WEBSITE OR THE WEB PAGES OF ANY AFFILIATE SHOULD BE CONSTRUED AS AN OFFER TO SELL OR A SOLICITATION OF AN OFFER TO PURCHASE ANY SECURITIES WHERE IT WOULD BE ILLEGAL TO DO SO.

COMPANY DETAILS

As regards the UK, the company details are:

THREADNEEDLE ASSET MANAGEMENT LIMITED ("Threadneedle") is incorporated in England and Wales under company number 00572304 and whose registered office is situated in England at 60 St. Mary Axe, London EC3A 8JQ.

THREADNEEDLE ASSET MANAGEMENT LIMITED is authorised and regulated in the United Kingdom by the Financial Services Authority ("FSA") under FSA register number 122194. Threadneedle's VAT number in the United Kingdom is GB 815 5258 29.

As regards all other relevant and applicable jurisdictions and territories, the company details are:

THREADNEEDLE MANAGEMENT LUXEMBOURG S.A. ("Threadneedle") is a publically limited company (societe anonyme) incorporated in Luxembourg and registered with the Registre de Commerce et des Societes (Luxembourg) under registered number B 110242 and whose registered office is situated in Luxembourg at 74 Mühlenweg, L-2155 Luxembourg, Grand Duchy of Luxembourg.

For the purposes of interpretation of these Terms and Conditions any reference to "Threadneedle" shall be construed in accordance with and include reference to (i) the respective, relevant and applicable jurisdiction(s) or territory(ies), and, (ii) subject to the context per (i) above, accordingly any and all relevant companies constituting any holding company, subsidiary and/or affiliate company of such definition of "Threadneedle" as applicable.  

THREADNEEDLE MAKES NO REPRESENTATION OR WARRANTY OF ANY KIND WHATSOEVER, EXPRESS, IMPLIED OR STATUTORY REGARDING THIS WEBSITE OR THE MATERIALS AND INFORMATION CONTAINED OR REFERRED TO ON EACH PAGE ASSOCIATED WITH THIS WEBSITE. THREADNEEDLE ACCEPTS NO LIABILITY HOWSOEVER ARISING FOR ANY LOSS OR DAMAGE ARISING DIRECTLY OR INDIRECTLY FROM ACTION TAKEN, OR NOT TAKEN, IN RELIANCE ON MATERIAL OR INFORMATION CONTAINED ON THIS WEBSITE. IN PARTICULAR, NO WARRANTY IS GIVEN THAT ECONOMIC REPORTING INFORMATION MATERIAL OR DATA IS ACCURATE RELIABLE OR UP TO DATE.

THREADNEEDLE ACCEPTS NO LIABILITY WHATSOEVER AND WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE HOWSOEVER ARISING INCLUDING BUT NOT LIMITED WHETHER ARISING DIRECTLY OR OTHERWISE INDIRECTLY (SUCH AS BY WAY OF EXAMPLE ONLY, SPECIAL, INCIDENTAL OR CONSEQUENTIAL LOSS OR DAMAGE) FROM YOUR USE OF THIS WEBSITE AND INCLUDING BUT NOT LIMITED TO ANY LOSS, DAMAGE OR EXPENSE ARISING FROM ANY DEFECT, ERROR, IMPERFECTION, FAULT, MISTAKE INACCURACY  OR LACK OF COMPLETENESS OF INFORMATION ON OR WITH THIS WEBSITE, ITS CONTENTS OR ASSOCIATED SERVICES, OR DUE TO ANY UNAVAILABILITY OF THE WEBSITE OR ANY PART THEREOF OR ANY CONTENTS OR ASSOCIATED SERVICES.

PLEASE NOTE THAT WHILST THREADNEEDLE TAKES REASONABLE STEPS TO ENSURE THAT IT USES UPTODATE VIRUS PROTECTION TO ENSURE THE SECURITY AND INTEGRITY OF ALL THE DOCUMENTS ON THIS WEBSITE, ANY DOCUMENTS DOWNLOADED FROM THIS WEBSITE ARE DOWNLOADED ENTIRELY AT YOUR OWN AND SOLE RISK AND THREADNEEDLE NEITHER ASSUMES NOR ACCEPTS LIABILITY FOR ANY LOSS OR DAMAGE, (WHETHER DIRECT OR INDIRECT), HOWSOEVER CAUSED, AS A RESULT OF, FOR EXAMPLE, ANY COMPUTER VIRUSES, TROJAN HORSES, WORMS, SOFTWARE BOMBS, MALWARE OR SIMILAR ITEMS OR PROCESSES ARISING FROM OR OTHERWISE DURING YOUR USE OF THIS WEBSITE.

ANY HYPERLINKS FROM THIS WEBSITE EXIST FOR INFORMATION PURPOSES AND ARE FOR YOUR CONVENIENCE ONLY AND THREADNEEDLE ACCEPTS NO LIABILITY HOWSOEVER ARISING FOR ANY LOSS OR DAMAGE ARISING WHETHER DIRECTLY OR INDIRECTLY (INCLUDING BUT NOT LIMITED TO CONSEQUENTIAL LOSS) FROM THE ACCURACY OR OTHERWISE OF MATERIALS OR INFORMATION CONTAINED ON THE PAGES OF SUCH SITES OR LOSS WHATSOEVER OR HOWSOEVER ARISING (WHETHER DIRECTLY OR INDIRECTLY) FROM DEFECTS WITH THE WEBSITE OR ANY SUCH SITES. INCLUSION OF HYPERLINKS DOES NOT IMPLY IN ANY WAY ANY ENDORSEMENT BY THREADNEEDLE OF THOSE SITES NOR THE MATERIAL CONTAINED ON THEM.

THREADNEEDLE DOES NOT GUARANTEE THAT ANY E-MAILS FROM THE WEBSITE SENT TO YOU WILL BE RECEIVED BY YOU THROUGH THE INTERNET OR SENT BY YOU OVER THE INTERNET WILL BE RECEIVED BY THREADNEEDLE, NOR DOES THREADNEEDLE WARRANT THE PRIVACY AND/OR SECURITY OF E-MAILS OR DATA CONTAINED IN ANY COMMUNICATIONS DURING INTERNET TRANSMISSION NOR THAT THE WEBSITE NOR ANY OTHER SUCH SITES WILL BE AT ANY TIME HOSTED AND/OR AVAILABLE.

USE AND DISCLOSURE OF PERSONAL INFORMATION

Unless restricted by applicable law, you agree that any and all personal information/data relating to you collected by Threadneedle from this Website from time to time may be used and disclosed for such purposes and to such persons as may be in accordance with Threadneedle's current Privacy Policy.

A copy of Threadneedle's current Privacy Policy may be accessed by clicking here.

INDEMNITY

You hereby agree to indemnify and to keep Threadneedle fully and effectively indemnified against any action, liability, cost, claim, loss, damage, proceeding or expense (including but not limited to any legal fees, costs and expenses whatsoever and howsoever arising on a full indemnity basis) suffered or incurred and all by Threadneedle howsoever arising from or which is directly or indirectly related to:-

(i) your access to and/or use of Threadneedle's Website and/or any other person or entity's use of this service or Website where such person or entity was able to access the service or Website using your user id and/or password; and/or,

(ii) any breach or non-observance of any of these terms and conditions by you or by any other person or entity where such person or entity was able to access and/or use Website by using your user id and login password.

TERMINATION

Threadneedle may terminate this Agreement, your access to or use of this Website and/or any such sites at any time on notice, with or without cause.

MODIFICATION

Threadneedle reserves the right in its discretion to modify and or change without restriction and without prior warning or notice any information or material contained in these Terms and Conditions or otherwise any applicable terms and conditions to relevant products and/or services available in or on this Website or otherwise in or on Threadneedle's Website generally. Continued use of this Website by you shall be deemed to indicate your continued consent to any such new, modified, amended or deletion of any of these Terms and Conditions.

INTELLECTUAL PROPERTY RIGHTS

All contents of this Website including, but not limited to the text, graphics, links and sounds are the copyright of Threadneedle and may not be copied, downloaded, distributed or published in any way without the prior written consent of Threadneedle.

"threadneedle" is registered trade mark and service mark of Threadneedle Asset Management Holdings Limited and no permission or licence is granted to use any such trade mark or service mark without the prior written consent of Threadneedle Asset Management Holdings Limited. All other marks names and logos used on this Website (unless otherwise stated) are the intellectual property rights held by companies within the Threadneedle group of companies. In relation to any information or materials which you submit to Threadneedle using this Website, you hereby grant to Threadneedle a worldwide royalty-free perpetual licence of the copyright and all other intellectual property rights in such information or materials for any purpose it deems including, without limitation, the copying, transmission, distribution and publication thereof, unless restricted by applicable law.

You agree that Threadneedle shall not be under any obligation of confidentiality to you regarding any such information or materials submitted to it using this Website unless agreed otherwise in a separate direct contract between you and Threadneedle or required by law.

You acknowledge that the contents of the foregoing provisions of these Term and Conditions shall not limit any specific provisions which may be set out in the individual terms and conditions of particular products and services offered on or through this Website.

Threadneedle may be contacted via email through the "CONTACT US" facility on Threadneedle's website.

CONDUCT OF INVESTMENT BUSINESS OUTSIDE THE UK

The conduct of investment business with Threadneedle, any Threadneedle office or any Threadneedle company outside the United Kingdom is regulated by the appropriate authority and applicable securities legislation for the relevant jurisdiction as may be specified on the Website and in the Terms and Conditions for that particular office or company.  It is your responsibility to identify the appropriate regulatory authority for such investment business on a particular Threadneedle website and to ensure that such investment business qualifies for protection in your jurisdiction/country, as such securities legislation will vary from jurisdiction to jurisdiction.

Please note transactions with any office of Threadneedle outside the United Kingdom, or with any other Threadneedle Group company outside the United Kingdom, are not protected by the United Kingdom's regulatory regime for the conduct of investment business. Transactions with offices of non-Threadneedle companies referred to in this Website will not normally be so protected unless otherwise indicated. Individuals may obtain on request a quotation in writing about the terms on which a company named in this Website is prepared to do business.

THE DISTRIBUTION OF THIS WEBSITE'S MATERIAL MAY BE RESTRICTED BY LAW IN CERTAIN JURISDICTIONS.  NOTWITHSTANDING ANY OBLIGATION OR RESPONSIBILITY WHICH MAY BE IMPOSED UPON THREADNEEDLE BY ANY LOCAL LAW AND WHERE NOT PROHIBITED BY SUCH LOCAL LAW,  IT IS YOUR RESPONSIBILITY TO FIND OUT WHAT THOSE RESTRICTIONS ARE, AND, OBSERVE THEM.

JURISDICTION AND RESTRICTIONS

Threadneedle reserves at its sole discretion, and without assigning any reason therefor, the right to use any third party under Threadneedle's direction to host, control and maintain the Website.  Threadneedle makes no representation whatsoever as to the level, quality or adequacy of such hosting, control or maintenance of the Website.  Furthermore Threadneedle makes no representation whatsoever that to any extent, such material and information contained in or on the Website is appropriate, accurate, complete or available for use in any location and/or jurisdiction. These Terms and Conditions are governed by English Law and any dispute shall be subject to the non-exclusive jurisdiction of the English Courts.

Threadneedle is a brand name, and both the Threadneedle name and logo are trademarks or registered trademarks of the Threadneedle group of companies.

Privacy Statement

Your data controller

This Privacy Statement relates solely to information supplied by you to us via this website. Threadneedle Asset Management Holdings Limited registered in England and Wales under company number 03554212 and whose registered office is at 60 St. Mary Axe London EC3A 8JQ ("Threadneedle"). Any reference to Threadneedle shall also include reference to or any of the Threadneedle group of companies including its holding companies, subsidiaries and affiliates. For the purposes of the UK Data Protection Act 1998 ("DPA"), the data controller in respect of any personal information provided is Asset Management Holdings Limited. In this privacy statement "we", "us" and "our" means Threadneedle. We shall respect the privacy of your personal information, treat it as confidential and keep it secure, subject to the provision of the DPA and related and/or subsequent rule law and/or legislation.

Uses made of your personal information

The type of information you consent for us to collect, store and process about you are the personal data ("personal information") you supply to us through this website or otherwise any other additional personal information that you provide to us. Please note that for certain products we may need to process sensitive personal data and references to personal information shall include references to your sensitive personal data.

The personal information that you provide to us will be used for a number of different purposes including but not limited: to understanding you financial needs; to conducting, and assisting any other third parties in conducting, (i) appropriate credit checks or (ii) reviewing credit worthiness; to manage and administer your account (including but not limited to contacting you), to update, correct and enhance Threadneedle's records; to offer you investment products and services (except where you have asked us not to do so) and to help us develop new ones; to contact you with details of changes to the products you have bought; to plan for, conduct and monitor Threadneedle business; for internal analysis and research; to comply with legal or regulatory requirements including but not limited to any rule regulation law authority (such as by way of example only, for the purposes of debt collection and/or the prevention of fraud or any other crime) or any direction of any competent; and to identify you when you contact us. We may use external third parties to process your personal information on our behalf in accordance with these purposes. Your personal data may be held in electronic, electro-magnetic and/or paper form.

Sharing of your personal information

If applicable, where you have notified us of your adviser, the personal information provided may be shared with such adviser. You must notify us in writing if you no longer wish us to share your personal information with your adviser or of any change to your adviser. Your adviser should have its own arrangements with you about its use of your personal information. The personal information provided may also be shared with other organisations in order for us to comply with any legal or regulatory requirements. In addition, we may share your personal information with the companies within the Threadneedle group for the purposes set out in this privacy statement.

Additionally Threadneedle may communicate your personal information to such individuals and entities as are listed below, including but not limited to those parties for which you subsequently give Threadneedle permission, or is under either a legal obligation or any other duty to do so. For the purposes detailed above, your information may be disclosed to:

1. any other branches or companies within the Threadneedle group of companies;

2. any regulatory, supervisory, governmental or quasi-governmental authority with authority and jurisdiction over Threadneedle;

3. any agent, contractor or third party service provider, professional adviser or any other person under a duty of confidentiality to Threadneedle;

4. any credit reference agency and, in the event of default, any debt collection agency;

5. any actual or potential participant or sub-participant in, assignee, novatee or transferee of, Threadneedle's rights and/or obligations in relation to you; and,

6. any financial institution with which Threadneedle has or proposes to have dealings

See also under 'Overseas transfers' below.

Consent to use and sharing

In agreeing to this Privacy Policy and providing your personal information to us, you are consenting to us sharing your personal information with other organisations including any other company within the Threadneedle group of companies or otherwise use external third parties to process your personal information on our behalf, in order for us to comply with any legal or regulatory requirements and/or our obligations to your employer.

Business changes

If we or the Threadneedle group undergoes a group reorganisation or is sold to a third party, the personal information provided to us may be transferred to that reorganised entity or third party and used for the purposes highlighted above.

Overseas transfers

We may transfer your personal information to countries located outside of the European Economic Area (the EEA), this may happen when our servers, suppliers and/or, service providers are based outside of the EEA. The data protection laws and other laws of these countries may not be as comprehensive as those that apply within the EEA - in these instances we will take steps to ensure that your privacy rights are respected. Details of the countries relevant to you will be provided upon request. By providing us with this information, you consent to these transfers and uses, and to any disclosure required by law.

For the purposes of this Privacy Statement where any disclosure of your personal information requires the transfer of your personal information to parties located in other countries we understand that such countries may not offer the same standard of data protection as the country where you live and work. However, Threadneedle shall ensure that those overseas third parties to whom your personal information is transferred, treat your personal information securely and confidentially. Threadneedle also fully intends to comply with all applicable data protection and privacy laws. Nevertheless we may transfer your information under certain circumstances, such as by way of examples only, where it is necessary to perform our contract with you. In providing details to Threadneedle via this website you indicate your consent to Threadneedle for Threadneedle to any and all transfers including any transfers not specifically detailed above.

Access to/correction of your information

With limited exceptions, you have the right to ask for a copy of the information that we hold on you. There may be a charge for this (if a charge is permitted). If any of the information that we hold about you is wrong, please tell us and we will put it right. You can write to us at Threadneedle Investment Services Limited, PO Box 1331, Swindon SN38 7TA.

Subject to any applicable local laws and regulations, If you prefer not to be kept informed of Threadneedle products and services, please let us know.

Third Party Information

If you provide us with information about another person, you confirm you already have explicit confirmation that such other person has appointed you to act for them to consent to the processing of their personal data by us. This means that you have informed them of our identity and the purpose for which their personal data will be processed, namely to verify their name and address and otherwise only in connection with you. You agree to keep us, and any Threadneedle group company or relevant third party fully indemnified for your not having complied with this paragraph.

Cookies

A "cookie" is a small piece of encoded information sent by a web server to be stored on your web browser (Internet Explorer, Netscape) so that it can remember something about you such as username, password, references at a later date. Cookies have three functions: security, log in and responsibility discharge.

A cookie also ensures that there is a unique identification when you visit the Threadneedle.com website and helps us to determine what page you may see next time you visit the website. This process enables us to provide you with personalised information and simplify your user experience.

Threadneedle uses persistent cookies that do not expire at the end of a user session. The cookie stored on your web browser does not contain any personal information and is encrypted and only the Threadneedle web server can read it.

Specifically cookies may:

1. allow us to recognise the PC you are using when you return to our website so that we can understand your interest in our website and tailor website content and advertisements to match your interests;

2. identify you after you have logged in by storing a temporary reference number in the cookie so that our web server can conduct a dialogue with you while simultaneously dealing with other customers. (Your browser keeps this type of cookie until you log off or close down your browser when these types of cookie are normally deleted. No other information is stored in this type of cookie);

3. allow you to carry information across pages of our website and avoid having to re-enter that information;

4. allow you access to stored information if you register for any of our on-line services;

5. enable us to produce statistical information (anonymous) which helps us to improve the structure and content of our website; and/or,

6. enable us to evaluate the effectiveness of our advertising and promotions.

If you do not wish to have a cookie stored on your computer, you should disable them in your browsers security options.

Disclaimer

When entering the website, you are required to read the disclaimer. When you as a user confirm that you have read the disclaimer, a cookie is set with the value of "yes".

The cookie will expire twelve months after you the user confirm that you have read the disclaimer, or sooner should the disclaimer text be updated.

Amendments

Threadneedle reserves the right to amend this Privacy Statement at any time and on notice by placing any such amendments on this website. This Privacy Statement is not intended to, nor does it, create any contractual rights whatsoever or any other legal rights, nor does it create any obligations on Threadneedle in respect of any other party or on behalf of any party.

Threadneedle / Issued by

Threadneedle Asset Management Limited
Registered in England and Wales, Registered No.  573204
60 St Mary Axe, London EC3A 8JQ, United Kingdom
Authorised and regulated in the UK by the Financial Services Authority, Register No. 122194

Threadneedle Investment Services Limited
Registered in England and Wales, Registered No. 3701768
60 St Mary Axe, London EC3A 8JQ, United Kingdom
Authorised and regulated in the UK by the Financial Services Authority, Register No. 190437

Threadneedle International Investments GmbH
Registered No: CH-020.4.040.172-3
Dreikönigstrasse 31A, 8002 Zürich

Threadneedle Management Luxembourg S.A.
Registered with the Registre de Commerce et des Societes (Luxembourg), Registered No. B 110242
74 Mühlenweg, L-2155 Luxembourg, Grand Duchy of Luxembourg.

Threadneedle Investments is a brand name, and both the Threadneedle Investments name and logo are trademarks or registered trademarks of the Threadneedle group of companies.