Regulatory compliance statement

Disclosure of Information

The Group (“we”, “us” or “our”) needs to use and share client information to operate effectively, including in connection with our provision of products and services to you and for the purposes of client servicing.

We will keep information provided by or relating to you confidential, except as required by Law or any Authority.

• “Affiliate” means, in relation to a company, any of its subsidiaries, holding companies or any other subsidiary of any such holding company and (where applicable) any representative and branch office in any jurisdiction.
• “Authority” means government, quasi-government, administrative, regulatory or supervisory body or authority or court having jurisdiction over any of our subsidiaries.
• “Law” means any law, regulation, rule, directive, order, request, guideline, sanction, embargo, and restriction of or agreement with any Authority.

Privacy

To comply with applicable Laws and in the course of providing products and services to you, we will need to collect, hold, use and share Personal Information of your Data Subjects.

Our Privacy Statement outlines how Ceviant processes Personal Information. You agree to make your Data Subjects aware of our Privacy Statement.

• “Data Subjects” means all individuals whose Personal Information we receive in the course of our relationship with you, including your direct and indirect beneficial owners, directors, officers and authorized persons.
• “Personal Information” means any information relating to Data Subjects.

Compliance with Laws and Financial Crime Compliance

Ceviant is committed to complying with Laws, including applicable financial crime compliance laws and regulations such as those related to anti-money laundering, anti-bribery and corruption, in all jurisdictions in which we operate.

As our ability to comply with Laws is directly linked to the conduct of our clients, we require you to comply with all applicable Laws and conduct your business in a manner that will not place yourself or Ceviant in breach of all applicable Laws.

If you become aware of any breach or any action, investigation or proceeding brought against you or your subsidiaries with respect to any breach of any applicable Law in connection with our provision of products and services to you or matter set out in this Statement, you will notify us promptly (unless prohibited by Law to do so).

Sanctions

Ceviant is obliged to comply with sanctions Laws including those of the United States, United Kingdom, European Union or any of its member states (“Sanctions”).

As our ability to comply with Sanctions is directly linked to the conduct of our clients, you confirm and will ensure that (i) you and your subsidiaries are not targets or the subject of Sanctions; and (ii) no product, service or transaction (or proceeds of the same) involving Ceviant has or will be utilized for the benefit of any person that is a target or subject of Sanctions or in any manner that would result in you or your subsidiaries or any Ceviant’s subsidiary being in breach of any applicable Sanctions or becoming a target or subject of Sanctions. We reserve the right to not provide any product or service or process any transaction if by doing so it may cause us to breach the Group’s Sanctions policy.

Tax Information Compliance

We may require you or your Data Subjects to provide documents and information for the purposes of establishing your tax status and that of your Data Subjects.

If you or your Data Subjects do not provide documents or information when we request it, we may make our own decision about your tax status and treat you accordingly.

We may be required to withhold taxes from payments made to you for onward remittance to applicable Authorities.

Client Classification

From time to time, we may request and obtain information from you and/or third-party or public sources, to determine your regulatory classifications (or that of the funds that you manage) under applicable Laws.

You will inform us immediately and in any event prior to entering into any transaction with us if any regulatory classification that we have previously notified you of or information (including contact details) that we have about you and/or the funds that you manage is known by you to be inaccurate or incomplete. Unless we receive notification otherwise, you shall be deemed to have (i) confirmed such regulatory classifications and that the information that we have about you and/or the funds that you manage is complete and accurate; and (ii) agreed and consented to the Group reporting your derivative transactions with us to any Authority (including trade repository(ies)).

Provision of Information

You agree to (or will procure that your Affiliates and Data Subjects) provide such documents and information as we may reasonably request in relation to matters covered by this Statement. You will promptly inform us of any changes to documents and information provided to us so that they are up to date, accurate and complete.

Product Documents

This Statement shall form part of any specific legal documentation governing a product, service or transaction that you enter into with us (“Product Documents”).

In relation to any product, service or transaction under a Product Document, the relevant terms of such Product Document will prevail to the extent they are in addition to or inconsistent with this Statement.

Communication and Updates

We will generally communicate with you in English, unless otherwise required by Law. You consent to receiving this Statement and any other information relevant to you through various methods, including email or our website (irrespective of such information being personally addressed to you). Please read any such information carefully. Should you have any questions, we recommend that you seek independent legal and / or financial advice.

The most current version of this Statement is available on our website. We may also provide other important regulatory information in relation to this Statement on our website or on any other website as notified by us.

We reserve the right to amend this Statement and any other important regulatory information provided to you on our website(s). We recommend that you regularly review the information on our website(s) as it may be updated from time to time. These updates shall apply to our relationship going forward and automatically.