Hong Kong

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

1. Important Information

2. Privacy Notice

3. Cookie Policy

Scroll down to view the relevant policy.

1. Important Information

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

IMPORTANT INFORMATION ABOUT ACCESS TO THIS WEBSITE

This Website and the information on it is communicated by Stewart Investors which is a trading name of First Sentier Investors (UK) Limited (when communicating in the UK), which is authorised and regulated by the Financial Conduct Authority of the United Kingdom, and of First Sentier Investors (Ireland) Limited (when communicating within the European Economic Area (EEA)) , which is authorised and regulated by the Central Bank of Ireland, and of, First Sentier Investors (Hong Kong) Limited (when communicating in Hong Kong), and of First Sentier Investors (Singapore) (whose company registration number is 196900420D) (when communicating in Singapore) with a registration number 53310114W, and of First Sentier Investors International IM Limited (when communicating outside the above mentioned jurisdictions) which is authorised and regulated by the Financial Conduct Authority of the United Kingdom.

Where we use the word affiliate, we are describing investment teams that form part of the First Sentier Group – the legal structure of our affiliate investment teams varies – some affiliates are separate legal entities, some are not.

This Website uses cookies as described in paragraph 16 of these Terms and by agreeing to these Terms you consent to the use of cookies as described in that paragraph.

In Hong Kong, this website is communicated by First Sentier Investors (Hong Kong) Limited and has not been reviewed by the Securities & Futures Commission in Hong Kong. First Sentier Investors and Stewart Investors are the business names of First Sentier Investors (Hong Kong) Limited. First Sentier Investors (Hong Kong) Limited is part of the investment management business of First Sentier Investors, which is ultimately owned by Mitsubishi UFJ Financial Group, Inc. (“MUFG”), a global financial group. First Sentier Investors includes a number of entities in different jurisdictions.

In Singapore, this website is communicated by First Sentier Investors (Singapore) whose company registration number is 196900420D. Advertisements or publications on this website have not been reviewed by the Monetary Authority of Singapore. First Sentier Investors (registration number 53236800B) and Stewart Investors (registration number 53310114W) are the business divisions of First Sentier Investors (Singapore). First Sentier Investors (Singapore) Limited is part of the investment management business of First Sentier Investors, which is ultimately owned by Mitsubishi UFJ Financial Group, Inc. (“MUFG”), a global financial group. First Sentier Investors includes a number of entities in different jurisdictions.

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

Investing involves certain risks including that the value of investments and any income from them may go down as well as up and are not guaranteed. Investors may get back significantly less than the original amount invested. For further information please expand the “Risk Warnings” section below. For a full description of the terms of investment and the risks please see the Prospectus, key fact statement (if applicable) and product highlights sheets, which are available on the regional website specific to your location and investor type : http://www.firstsentierinvestors.com. If you are in any doubt as to the suitability of our funds for your investment needs, please seek investment advice.

This website does not constitute an offer or invitation or investment recommendation to distribute or purchase shares in the OEIC in the European Union (or the additional EEA states).

1. About this Website:

In Singapore, this website is communicated by First Sentier Investors (Singapore) whose company registration number is 196900420D. Advertisements or publications on this website have not been reviewed by the Monetary Authority of Singapore. First Sentier Investors (registration number 53236800B) and Stewart Investors (registration number 53310114W) are the business divisions of First Sentier Investors (Singapore). First Sentier Investors (Singapore) is part of the investment management business of First Sentier Investors, which is ultimately owned by Mitsubishi UFJ Financial Group, Inc. (“MUFG”), a global financial group. First Sentier Investors includes a number of entities in different jurisdictions.

2. Selling Restrictions:

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

3. No Advice:

The information on this Website is provided for general information purposes only and does not constitute, and should not be construed as, investment advice or a recommendation or an offer or solicitation to buy, hold or sell any security or to execute any agreement for portfolio management or investment advisory and has not been prepared in connection with any such offer. The information on this Website is provided solely on the basis that you will make your own investment decisions and Stewart Investors has not taken any account of your particular investment objectives or financial situation in preparing the information on this Website. In addition, nothing in this Website shall, or is intended to, constitute financial, legal, accounting or tax advice. We strongly recommend that you seek professional investment advice before making any investment decision.

4. Risk Warnings:

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

The offering documents, key fact statements (if applicable) and products highlights sheet (available on the above regional website specific to your location and investor type) also contain risk warnings which are specific to the relevant fund and which you should consider carefully before taking any decision to invest.

5. Offering Documents:

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

6. Information on this Website:

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

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

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

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

7. Material Interests:

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

8. Linked Websites:

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

9. Liability:

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

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

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

10. Access:

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

11. Compliance with Law and Regulation:

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

12. Intellectual Property:

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

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

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

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

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

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

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

13. The Internet:

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

14. Data Protection:

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

15. Cookies:

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

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

When you browse this website, you do so on the basis of these Terms and Conditions, a Cookie may set if you have accepted them. This can mean that you don’t have to re-accept them on every visit. This type of cookie is ‘persistent’ as they remember your preferences. Every time we amend our Terms and Conditions, or on an annual basis, a new Cookie will be set and you will be asked to re-accept our Terms and Conditions.

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

The browsers of most computers, smartphones and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences.

However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work. More information about cookies can be found on www.allaboutcookies.org.

16. Amendment:

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

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

17. Third Parties:

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

18. Applicable Law:

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

19. Jurisdiction:

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

20. Contact Us:

If you have any enquiries in relation to this Website or the information on it, please contact Stewart Investors at [email protected]

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

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

2. PRIVACY NOTICE

1. Purpose

1.1 First Sentier Investors (“FSI”) is committed to protecting the identity of individuals and safeguarding their Personal data.

1.2 This Privacy Notice (“Policy”) describes how we will fulfil our obligations under applicable data protection laws, including:

what Personal data FSI collects
how FSI collects and stores Personal data
how FSI uses Personal data
how Personal data can be disclosed to others
how an individual can access or correct their Personal data
how to complain if an individual has concerns about how FSI has managed their Personal data

2. Scope

2.1 This Policy applies to all subsidiaries and affiliates within FSI. FSI is the corporate group comprising the following and all of their direct and indirect subsidiaries:

First Sentier Investors Holdings Pty Limited; and
First Sentier Investors (US) LLC.

2.2 Please refer to Appendix A for the list of companies and investment funds in Europe and the United Kingdom to which this Policy applies.

3. What is Personal data?

3.1 Personal data is information or an opinion about an individual from which the individual can be reasonably identified.

4. What Personal data does FSI collect?

4.1 The Personal data FSI may collect will depend on the circumstances of collection, including whether we collect the information from individuals as an investor or client, a supplier, contractor, stakeholder, job applicant, employee or in some other capacity. For example in some locations business contact details of a company representative with whom we deal are considered to be Personal data.

4.2 FSI collects Personal data so that we can provide products and services and engage suppliers and comply with our legal obligations such as those under taxation and anti-money laundering and counter-terrorism financing laws. If FSI does not collect Personal data, we may not be able to provide a product or service or enter into a supplier arrangement.

4.3 The product or service that we are providing or receiving will also determine what information we will collect. This information may include a name; address (including proof of name and address); photo identification; contact details both personal and work (for example, email and phone numbers); hobbies and interests; job title and company; nationality; citizenship; tax residency; date of birth; passport details; government issued identifying numbers (eg. tax numbers and national identity); adviser details; investment details; banking details; signed contracts ; business cards, contact sheets and biographies; financial dealings; family connections; details of company’s directors, secretaries, authorised signatories and identification documents; details of any complaints made; data required to conduct due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); responses to surveys and competitions; fraud enquiries (for example, information from police reports); images captured by CCTV cameras on our premises(in locations where there are cameras present); recordings of telephone conversations and electronic communications with our staff.

4.4 We may also collect Personal data using cookies on this site. The collection is managed in accordance with our Cookies Policy.

4.5 We may collect Personal data from third parties, depending on the nature of the business relationship, in particular the following:

Third party service providers to our funds (for example, transfer agents, registrars, administrators, distributors, custodians and paying agents) – information received includes personal details of investors obtained from fund application forms such as: name; address; contact details; nationality; government issued identity numbers (eg. national insurance number); date of birth; tax residency; adviser details; investment details; bank account details.
Advisers (including independent financial advisers) – information received may include an investor’s or client’s name; address; gender; date of birth; bank details.
Suppliers such as Experian and Refinitiv – information received includes the results of “Know Your Client”, anti-money laundering, politically exposed persons and sanctions checks.
Publically available sources such as MandateWire and LinkedIn – information available includes contact details of institutional investors (MandateWire) and details of job title, company, former employers and roles, and connections (LinkedIn).

4.6 In the context of FSI’s recruitment process for employees and contractors, we may collect (including through a recruitment agency), and hold, the following kinds of Personal data: applicant’s or employee’s name, contact details, date of birth, citizenship, employment references, background checks, regulatory accreditation, media (including social media), directorships, driver’s licence information, education, employment history and credential validation. Applicants for job vacancies in the United Kingdom and Europe will receive a separate Privacy Notice as part of the application process.

4.7 In the employment context, we may also collect and hold the Personal data listed above, as well as tax number, financial information, banking details, and other Personal data that may be collected in the use of FSI systems or assets. This information may be collected to assist us in monitoring compliance with our internal policies and perform other necessary functions and activities. All employees and contractors receive a separate Privacy Notice in relation to their employment.

5. How does FSI collect and store Personal data?

Collecting information

5.1 We collect from time to time, Personal data on investors, clients, suppliers, contractors, stakeholders, job applicants, employees and other business contacts from a number of sources, including from: investor application forms; other FSI forms (including website forms); client investment management agreements; various forms of correspondence; conversations; advisers; intermediaries; business cards; third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents); client advisers; other third parties; and from public sources. This information may be collected directly from investors, clients, intermediaries and business contacts, or indirectly from third parties.

Collecting information from visits to FSI’s website

5.2 We may collect information based on FSI’s website usage. FSI uses “cookies” and other data collection methods such as pixel tags to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our site. This information is collected to analyse and improve our website, our marketing campaigns and to record statistics on web traffic.

5.3 If account information is accessed online through one of the secure areas of FSI’s website, we will collect information about the visit using “cookies” to track the use of our website and to allow visitors to effectively access their account information. This information is collected for security purposes and to protect the integrity of visitor’s account details. For more information, please see our Cookies Policy.

6. How is Personal data protected?

6.1 Personal data held by us will be kept confidential.

6.2 We hold Personal data in secure computer storage facilities (whether in-house, at our service providers, or on cloud based systems), on paper-based files and in other formats. We take reasonable steps to protect information from loss and unauthorised access, destruction, use, modification or disclosure.

6.3 Access to Personal data held by FSI is controlled to prevent misuse or unauthorised disclosure of the information. We utilise a range of technical security measures such as secure authentication, password controls, encryption, firewalls and anti-virus technology to prevent unauthorised access to information. Physical access to our buildings is controlled by security pass.

6.4 How long we hold Personal data for will vary and will be determined by various criteria including:

the purpose for which we are using it – we will need to keep the Personal data for as long as is necessary for that purpose, and
legal obligations – laws or regulation may set a minimum period for which we have to keep Personal data.

7. How does FSI use Personal data

7.1 The information we use will depend on the nature of the business relationship, as follows:

In relation to prospective investors and clients, we may process Personal data for identification purposes (prior to becoming an investor in our funds or a client of ours under an investment management agreement), for the purposes of anti-money laundering, counter terrorist financing, suitability and appropriateness assessments, “Know Your Client” and credit-worthiness checks, and for any other applicable legal or regulatory reasons. Failure to provide relevant information will mean that we will not be able to on-board a potential investor or client.
In relation to investors in our funds, we may process information collected for the purpose of account administration and other general business purposes (for example, for processing subscriptions and investments; maintaining the share register of investors, carrying out investor instructions; handling any complaints and enquiries; sending investor communications, including financial reports, valuations, corporate actions). In addition, in order to comply with regulatory obligations, we may collect and disclose certain information about our investors and certain related persons and their investments to the local tax authority and and/or other relevant tax authorities overseas.
In relation to our investment management clients, we may process Personal data for the purpose of managing and administering clients’ accounts, including providing valuations and periodic reports and informing clients of relevant information as required by the investment management agreement.
We may from time to time process Personal data of investors and clients to comply with legal and regulatory requirements impacting our business. In particular, we may need in the context of our business: to obtain legal advice on legal and regulatory requirements; to report to relevant regulators; to comply with market opening and registration requirements in the conduct of our business; prevent or investigate any actual or suspected fraud; unlawful activity or misconduct; consider any concern or complain raised against FSI and/or to manage any legal action against FSI.
In relation to intermediaries who introduce investors into our funds (such as distributors, platforms and independent financial advisers), we may process Personal data to conduct market research, gauge product sales or product performance or assess the creditworthiness of intermediaries. In addition, we may process the Personal data of investors introduced to our funds, as outlined above.
In relation to our general business contacts (including consultants and intermediaries who act for our mutual clients), we may process Personal data for general business purposes such as: for public relations and corporate communications purposes; providing thought leadership articles; networking/relationship building; conducting market research and gathering industry statistics; evaluating products and services; when visiting our offices; and assisting with any queries.
We may process Personal data to analyse the performance of IT systems, monitor usage of resources and systems and to improve products, services and usability of our technology platform, including telephone calls and electronic communications with our staff which may be recorded for the purposes of retaining a record of communications; in the interests of security; for training and compliance monitoring purposes and/or to comply with legal or regulatory obligations.
In relation to job applicants, to consider an application for employment.
In relation to employees and contractors, we may process Personal data for the purpose of complying with tax, employment/labour and workplace health and safety regulations (including management of working hours, sick leave and the health and safety of personnel, talent management including promotions and position assignments/reassignments and the administration and payment of wages and benefits). Personal data of employees may also be used for the purposes of managing or ending the employment or other contractual relationship and disputes with employees, including defending claims brought by employees. We may also use information for other purposes required or authorised by or under law (including purposes for which consent has been provided).

7.2 We are entitled to use Personal data in these ways because:

We have legal and regulatory obligations that we have to discharge;
We may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
The use of Personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates);
The use of Personal data is necessary for the performance of a contract;
Consent to us processing Personal data has been provided (other than for marketing purposes);
Consent has been provided for us to process Personal data for the purposes of informing (for example, by telephone, mail or email) individuals about other products and services available from the other companies within FSI and about marketing campaigns and event invitations.

8. How is Personal data disclosed to others

8.1 We may disclose Personal data to other companies within FSI, for internal business and administrative purposes (including to administer our products and services and for prudential and risk management purposes) and, where consent has been given, to provide individuals with information on related products and services.

8.2 We may also disclose Personal data relating to our clients to other companies within FSI to whom we sub-delegate our services (for example, trade order execution and portfolio management). When we disclose Personal data to other companies within FSI, we will take appropriate measures to ensure that such Personal data is shared and treated securely and in accordance with this Policy.

8.3 FSI related companies and third parties are located in jurisdictions including, but not limited to, Australia, Canada, Cayman Islands, France, Germany, Hong Kong, India, Ireland, Japan, Luxembourg, New Zealand, Singapore, United Kingdom, and the United States.

8.4 We may disclose Personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us.

8.5 The following is a list of the types of third parties who process Personal data on our behalf:

third party service providers to our funds (for example, transfer agents, administrators, distributors, platform providers, custodians, paying agents and researchers). These third party service providers may also disclose and transfer your Personal data to their subsidiaries or affiliates or other third party contractors;
credit reference agencies, debt collection agencies and other companies for use in credit decisions, for fraud prevention, to pursue debtors and for the verification of identity;
Auditors;
document execution vendors in relation to the execution of contracts with our clients;
mailing houses or printing companies;
recruitment agencies and payroll administrators;
information technology providers; and
brokers.

8.6 Where a financial adviser (as indicated on the investor application forms) or other professional adviser is used, then details of an individual’s investments and valuations may also be provided to their adviser and their respective service providers.

8.7 We may disclose to relevant tax authorities, regulators, government departments, competent authorities of the UK or of other countries, or other government or law enforcement agencies (without limitation) any Personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) in order to comply with a court order or to meet legal and regulatory requirements arising in the conduct of our business. Such disclosure may be made directly to such regulators or competent authorities etc. or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.

8.8 With your consent, we may also disclose Personal data to other third parties and for other purposes. That consent may be written, verbal or implied from conduct.

For those located in the United Kingdom or Europe,

8.9 In relation to data transfers outside of the European Economic Area (“EEA”) or UK, we may transfer Personal data of individuals located in the UK or Europe to our affiliates (including outside the EEA or UK) and/or allow the information to be accessed by our affiliates and their employees outside the EEA or UK as well as within it. It may also be processed by personnel operating outside the EEA or UK who work for us or for one of our third party service providers.

8.10 Where we transfer such Personal data outside the EEA or UK, we will ensure that it is protected in a manner that is consistent with how Personal data is protected by us in the EEA or UK or that the transfer is otherwise compliant with data protection laws. This can be done in a number of ways, for example:

the country that we send the data to might be approved by the European Commission or the UK Information Commissioner’s Office (“UK ICO”);

the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission or UK ICO, obliging them to protect your Personal data; or

where data protection laws permit us to transfer Personal data outside the EEA or UK

8.11 Individuals can obtain more details of the protection given to Personal data when it is transferred outside the EEA or UK (including a sample copy of the model contractual clauses) by contacting [email protected].

9. An individual’s rights in relation to their data

9.1 Individuals have a right to access the Personal data that we hold about them and if they wish to make an application to access or obtain this Personal data, they can contact us using the details in section 12 below. In some circumstances, individuals have the right to receive some Personal data in a structured, commonly used and machine-readable format and/or request that we transmit that Personal data to a third party where this is technically feasible. Please note that this right only applies to Personal data which individuals have provided to us.

9.2 Generally we do not charge a fee to request access to Personal data. However, if we do propose to charge a fee we will advise beforehand, so that the applicant can decide whether to proceed. Any fee charged would be to cover the cost of obtaining the information. For example, searching, retrieving and despatching the information.

9.3 We must verify the applicant’s identity before giving access to, or correcting the Personal data.

9.4 We take reasonable steps to ensure that the Personal data we collect, use or disclose is accurate, complete and up to date. Individuals are encouraged to contact us if any of the details they have provided change or if they believe that the Personal data we have about them is not accurate, complete or up to date.

9.5 In certain circumstances, FSI may not be able to correct or provide applicants with access to their Personal data. In these circumstances, we will write to the applicant to explain and provide the reasons why.

9.6 If an individual wishes us to erase or restrict using their Personal data, they are encouraged to contact us. We may need to discuss the basis of the request with the applicant as there may be circumstances where we are legally entitled to continue processing the Personal data or refuse the request.

9.7 If individuals have previously provided their consent to our use of their Personal data (other than for marketing purposes) and they wish to withdraw such consent, they are encouraged to contact us. We may need to discuss with the individual whether our use of their Personal data needs to continue for lawful purposes (i.e. because we have another legitimate reason for doing so).

9.8 If an individual has previously consented to being sent information about other products and services available from the First Sentier Investors group of companies, they may withdraw such consent by contacting us.

10. Expressing concerns or complaints about the management of Personal data

10.1 If an individual has a complaint related to how FSI has managed their Personal data, they are encouraged to contact us using the contact information in section 12 below. We may ask the complainant to place their concerns in writing in order for us to fully understand and investigate the issues they have raised.

10.2 We will acknowledge any complaint within five business days of it being received and make every effort to resolve the issue within a reasonable time of us being notified.

10.3 If an individual suspects misconduct, they are encouraged to Speak Up. Please refer to the Global Whistleblower Policy for more information on reporting misconduct.

10.4 Please refer to Appendix B for details of the external parties to contact for complaints that remain unresolved.

11. Notifiable data breaches

11.1 We have put in place procedures to deal with any suspected Personal data breach and will notify potentially impacted individuals and any applicable regulator of a breach where we are legally required to do so.

12. How to contact us

12.1 For any other Personal data related queries, access or Personal data correction requests, individuals may contact their FSI relationship manager or should they not have a relationship manager contact the Data Protection or Privacy Officer, as relevant, at the following:

Contact details in your location

Australia

Privacy Officer
First Sentier Investors
Level 5, International Tower 3
300 Barangaroo Avenue,
Barangaroo NSW 2000
[email protected]

Hong Kong

Data Protection Officer
First Sentier Investors (Hong Kong) Limited
Level 25, One Exchange Square
8 Connaught Place
Central, Hong Kong
[email protected]

Japan

Data Protection Officer
First Sentier Investors (Japan) Limited
6F, Cross Office Uchisaiwaicho
1-18-6 Nishishinbashi Minato-ku Tokyo
105-0003 Japan
[email protected]

Singapore

Data Protection Officer
First Sentier Investors (Singapore)
79 Robinson Road
#17-01
Singapore 068897
[email protected]

United Kingdom & EEA

Data Protection Officer
First Sentier Investors
7th Floor, Finsbury Circus House
15 Finsbury Circus
London EC2M 7EB
[email protected]

Chief Compliance Officer
First Sentier Investors
10 E. 53rd St.
21st Fl NY
NY 10022
[email protected]

Appendix A – Relevant companies and investment funds in Europe and the United Kingdom

Companies

First Sentier Investors (UK) Funds Limited*

First Sentier Investors (UK) IM Limited*

First Sentier Investors (UK) Services Limited

First Sentier Investors Europe Holdings Limited

First Sentier Investors International IM Limited*

First Sentier Investors (Ireland) Limited**

*Authorised and regulated by the Financial Conduct Authority of the United Kingdom
**Authorised by the Central Bank of Ireland Investment funds

Appendix B – External contact details for complaints

Australia

If the individual’s complaint remains unresolved, they may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) to have the complaint heard and determined. The OAIC may be contacted on the privacy hotline: 1300 363 992.

When we write to the individual about our decision, we will explain how to access an external dispute resolution scheme or make a complaint to the OAIC.

Hong Kong

An individual can lodge a complaint with the Office of the Privacy Commissioner for Personal data. For more information and instructions visit: https://www.pcpd.org.hk/english/complaints/introduction/introduction.html

Please send the individual’s complaint to:

Address: Room 1303, 13/F, Dah Sing Financial Centre, 248 Queen's Road East, Wanchai, Hong Kong;
Fax: 852 2877 7026; or
Email to [email protected]

Japan

If an individual has a complaint in relation to the way we have used the individual’s information, they should contact us in the first instance. Contact can also be made with a local consumer center or the Personal Information Protection Commission (“PPC”). Contact details for the PPC are:

Address: Kasumigaseki Common Gate West Tower 32nd Floor, 3-2-1, Kasumigaseki, Chiyoda-ku, Tokyo, 100-0013, Japan
Inquiry Line for Act on Protection of Personal Information: 03 6457 9849 (in Japanese only)
https://www.ppc.go.jp/en/contactus/piinquiry/

The PPC mediates the complaints with regard to the handling personal information.

Singapore

The Personal data Protection Commission (“PDPC”) encourages individuals who have concerns about the ways in which an organisation has handled their Personal data to first approach the organisation to clarify the reasons for the organisation's actions and seek an amicable resolution of the matter. Nonetheless, should the individual want to report the complaint to the PDPC, they can contact https://www.pdpc.gov.sg/Complaints-and-Reviews.

United Kingdom

If an individual has a complaint in relation to the way we have used the individual’s information, they should contact us in the first instance. They also have the right to lodge a complaint with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel: 0303 123 1113).

EEA

If an individual has a complaint in relation to the way we have used the individual’s information, they should contact us in the first instance. They also have the right to lodge a complaint with the Irish Data Protection Commission at 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (Tel: +353 578 684 800) if they think that any of the individual’s rights have been infringed by us.

3. Cookies Policy

You can find more information about the individual cookies that we use and the purposes for which we use them below:

Google Analytics

Google Analytics use third and first-party cookies to collect information about how visitors use our website, helping us to optimise user experience.

The duration of the Google cookies, and further information about Google cookies, can be found here.

Details of Google's privacy policy is here.

_ga: This persistent cookie is used to distinguish users and expires after two years.

_gid: This persistent cookie is used to distinguish users and expires after 24 hours.

_gat: This persistent cookie is used to throttle the request rate (limiting the collection of data on high traffic sites) from Google Analytics. It expires after 10 minutes.

_utma: This persistent cookie is used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics and expires after 2 years.

_utmb: This persistent cookie is used to determine new sessions/visits. This cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics and expires after 30 mins.

_utmc: This session cookie operates in conjunction with the __utmb cookie to determine whether the user is in a new session/visit. This cookie expires at the end of the browser session.

_utmz: This persistent cookie stores the traffic source or campaign that explains how the user reaches our site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics. This cookie expires after 6 months.

Google Tag Manager

dc_gtm_: Google Tag Manager is used to manage all scripts on the website. This persistent cookie expires after 10 minutes.

You can find more information about the types of cookies used by Google here.

Amazon Web Services

AWSELB: This cookie is associated with the Amazon Web Services Elastic Load Balancing functionality for routing client request on the server.

Terms and Conditions

SIW_TERMS: This cookie is a session based cookie, used to determine agreement to our Terms and Conditions and also holds your regional selection.

Cookies

SIW_COOKIES_ACCEPTED: This cookie is a session based cookie, used to determine agreement to our Cookie Policy.