Important
Legal Notices

This website is directed only at persons in the United Kingdom and the European Economic Area that qualify as professional clients or eligible counterparties as defined by the Financial Conduct Authority. The information in this website is not intended for the use of and should not be relied on by any person who would qualify as a retail client. If you are uncertain about whether you qualify as a professional client or as an eligible counterparty, you should seek independent advice from your legal and financial advisers.

In the United States, this website is intended only for qualified purchasers as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended. Persons resident in jurisdictions other than the UK or US should consult their professional advisers to determine whether there are any restrictions, any requirements for regulatory, governmental or other consent, or any other formalities to be observed to enable them to invest in our investment products.

The information on this website is provided for your general information only and does not constitute the giving of any investment advice or an offer to sell or the solicitation of an offer to buy any product or service by us and must not be relied upon at any time or in any circumstances by anyone entering this website in connection with any investment decision. The information on this website does not constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and rules and guidance issued from time to time by the Financial Conduct Authority. The information and material on this website is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities or any service in any jurisdiction.

Any decision to purchase interests in any Fund described on this website must be based solely upon the information contained in the prospectus of the relevant Fund and subscriptions will only be received and shares issued on the basis of the current prospectus of the relevant Fund; you are referred to this document if further information is required.

No information provided on this website in relation to any product or service should be construed as investment or other advice to you on the suitability or otherwise of that product or service for any person, such suitability depending on all the circumstances of the person concerned and all persons should consult with their own financial and other appropriate professional advisers as to all matters concerning any potential investment or any interest in any investment.

By entering this website and continuing to use it, you represent and confirm that you are a professional client or eligible counterparty as defined by the Financial Conduct Authority, or in the US are a qualified purchaser as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended , or that otherwise there are no restrictions in place that prevent you from accessing this website and/or considering any investment products or services detailed therein, and that you agree to be fully bound by the terms and conditions of this Legal Notice and our full terms and conditions of use of our website which you should read before using this website. Please note that you may be required to provide documentary evidence in support of your identity and categorisation as a professional client or eligible counterparty or qualified purchaser where we are considering making a financial promotion to you or we are considering entering into a contract with you as an investor or you are considering making an investment.

SCIO Capital LLP is authorised and regulated by the Financial Conduct Authority.

References to ‘we’, ‘us’, ‘our’, ‘firm’, ‘SCIO’ or ‘SCIO Capital’ mean SCIO Capital LLP. ^®SCIO, SCIO Capital and the SCIO logo are registered EU trade-marks of SCIO CAPITAL LLP. All rights reserved.

Terms of website use

This terms of use (together with the documents referred to in it) tells you the terms of use on which you may make use of our website www.scio-capital.com (our Site), whether as a guest or a registered user. Use of our Site includes accessing, browsing, or registering to use our Site. Please read these terms of use carefully before you start to use our Site, as these will apply to your use of our Site. We recommend that you print a copy of this for future reference. By using our Site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms of use, you must not use our Site.

Other applicable terms

These terms of use refer to the following additional terms, which also apply to your use of our Site:

• Our Privacy Policy, which sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our Site, you consent to such processing and you warrant that all data provided by you is accurate.
• Our Acceptable Use Policy, which sets out the permitted uses and prohibited uses of our Site. When using our Site, you must comply with this Acceptable Use Policy.
• Our Cookie Policy, which sets out information about the cookies on our Site.

Information about us

www.scio-capital.com is a Site operated by SCIO Capital LLP, a limited liability company (‘We’ ‘us’ ‘our’ ‘firm’). We are registered in England and Wales under company number OC349474 and have our registered office at 6th Floor 130 Jermyn Street London SW1Y 4UR, United Kingdom. Our main trading address is 17 Cavendish Square, London W1G 0PH, United Kingdom or such other trading address as is displayed on the ‘contact us’ page from time to time. Our VAT number is 219 8427 83. We are regulated by the Financial Conduct Authority (‘FCA’). We are an asset management company.

Changes to these terms

We may revise these terms of use at any time by amending this page. Please check this page from time to time to take notice of any changes we made, as they are binding on you.

Changes to our Site

We may update our Site from time to time, and may change the content at any time. However, please note that any of the content on our Site may be out of date at any given time, and we are under no obligation to update it. We do not guarantee that our Site, or any content on it, will be free from errors or omissions.

Accessing our Site

This website is directed only at persons in the UK that qualify as Professional Clients or Eligible Counterparties under the rules of the Financial Conduct Authority. The information in this website is not intended for the use of and should not be relied on by any person who would qualify as a Retail Client. If you are uncertain about whether you qualify as a Professional Client or as an Eligible Counterparty, you should seek independent legal advice. Persons resident in jurisdictions other than the UK should consult their professional advisers to determine whether there are any restrictions, any requirements for regulatory, governmental or other consent, or any other formalities to be observed to enable them to invest in our investment products. The information on this website is provided for your general information only and does not constitute the giving of any investment advice or an offer to sell or the solicitation of an offer to buy any investment or service by us and must not be relied upon at any time or in any circumstances by anyone entering this website in connection with any investment decision. The information on this website does not constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and rules and guidance issued from time to time by the Financial Conduct Authority. The information and material on this website is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities or any service in any jurisdiction. Any decision to purchase interests in any fund described on this website must be based solely upon the information contained in the prospectus of the relevant Fund and subscriptions will only be received and shares issued on the basis of the current prospectus of the relevant Fund; you are referred to this document if further information is required. No information provided on this website in relation to any investment or service should be construed as advice to you on the suitability or otherwise of that investment or service for any person, such suitability depending on all the circumstances of the person concerned and all persons should consult with their own financial or other professional advisers as to all matters concerning any potential investment or any interest in it. By clicking the “ACCEPT” option when entering this website and continuing to use it, you represent and confirm that you are a Professional Client or Eligible Counterparty as defined by the Financial Conduct Authority and that you agree to be fully bound by the terms and conditions of this Legal Notice and our full terms and conditions of use of our website which you should read use before using this Site. Please note that you may be required to provide documentary evidence in support of your identity and categorisation as a Professional Client or Eligible Counterparty where we are considering making a financial promotion to you or we are considering entering into a contract with you as an investor. Our Site is made available free of charge. We do not guarantee that our Site, or any content on it, will always be available or be uninterrupted. Access to our Site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our Site without notice. We will not be liable to you if for any reason our Site is unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to our Site. You are also responsible for ensuring that all persons who access our Site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

Your account and password

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use. If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at info@scio-capital.com.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our Site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. You may print off one copy, and may download extracts, of any page(s) from our Site for your personal use and you may draw the attention of others within your organisation to content posted on our Site. You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. Our status (and that of any identified contributors) as the authors of content on our Site must always be acknowledged. You must not use any part of the content on our Site for commercial purposes without obtaining a licence to do so from us or our licensors. If you print off, copy or download any part of our Site in breach of these terms of use, your right to use our Site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

No reliance on information

The content on our Site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our Site. Although we make reasonable efforts to update the information on our Site, we make no representations, warranties or guarantees, whether express or implied, that the content on our Site is accurate, complete or up-to-date.

Limitation of our liability

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law. To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our Site or any content on it, whether express or implied. We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• use of, or inability to use, our Site; or
• use of or reliance on any content displayed on our Site.

If you are a business user, please note that in particular, we will not be liable for:

• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill or reputation; or
• any indirect or consequential loss or damage.

If you are a consumer user, please note that we only provide our Site for domestic and private use. You agree not to use our Site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Site or to your downloading of any content on it, or on any website linked to it. We assume no responsibility for the content of websites linked on our Site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them and you must at all times comply with all terms and conditions which apply to your use of such linked websites. You will be held fully liable for any misuse of any terms and conditions which apply to such linked websites.

Viruses

We do not guarantee that our Site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform in order to access our Site. You should use your own virus protection software. You must not misuse our Site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Site, the server on which our Site is stored or any server, computer or database connected to our Site. You must not attack our Site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Site will cease immediately.

Linking to our Site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link to our Site in any website that is not owned by you. Our Site must not be framed on any other Site, nor may you create a link to any part of our Site other than the home page. We reserve the right to withdraw linking permission without notice. The website in which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy. If you wish to make any use of content on our Site other than that set out above, please contact info@scio-capital.com. Third party links and resources in our Site Where our Site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources nor accept any liability in respect thereof.

Applicable law

These terms of use, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Contact us

To contact us, please email info@scio-capital.com. Thank you for visiting our Site.  

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INTRODUCTION

This is SCIO Capital LLP’s privacy notice.

SCIO Capital LLP respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice: This privacy notice aims to give you information on how SCIO Capital LLP collects and processes your personal data through our relationship with you and/or your use of this website, including any data you may provide through this website when you sign up to our investor newsletters and reports or browse through our website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
SCIO Capital LLP is the controller and responsible for your personal data (collectively referred to as ‘SCIO’, ‘we’, ‘us’ or ‘our’ in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights in respect of your personal data, please contact us using the details set out below.

Contact details
Our full details are:

SCIO Capital LLP
General Data Protection Regulation
Email address: data@scio-capital.com
Postal address: 17 Cavendish Square, London, W1G 0PH, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time during your relationship with us.

Website third party links
This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes home and business address, delivery email address and telephone numbers.
• Employment Data includes your position, title, employment history and experience, specialism and qualifications.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, email address and first and last names.
• Usage Data includes information about how you use our website which is anonymised.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Fund Data includes investor reports, monthly and public reports on funds managed by the us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to end our business relationship and cancel any services you obtain from us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by contacting and corresponding with us by post, phone, email or otherwise. This includes (but is not limited to) personal data you provide when you:
• request marketing to be sent to you;
• subscribe to our service or publications;
• subscribe for any shares in any funds we manage;
• are about to enter into a contract with us or there is a contract between us including where you:
• appoint us to provide you with investment advice or discretionary management services;
• provide services to us;
• apply for employment with us;
• provide information to us about investments;
• create an account on our website;
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
• analytics providers such as Google based outside the EU;
• Identity and Contact, Financial and Transactional Data from service providers relating to your investments such as BNP Paribas Securities Services Luxembourg SCA and Waystone Investment Management (Lux) S.A. or CACEIS Investor Services Bank S.A. both based inside the EU.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
• Identity and Contact Data from publicly available sources such as websites following a Google or other search engine companies, based inside and outside the EU.

4. HOW WE USE YOUR PERSONAL DATA

• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message if applicable. You have the right to withdraw consent to marketing at any time by contacting us.
• Purposes for which we will use your personal data
  We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
• Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We have established the following personal data control mechanisms:

Promotion from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you or where you tell us which financial products you are interested in hearing about. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or have appointed us to advise you or manage your investments or if you provided us with your details and, in each case, you have not opted out of receiving that marketing.

Third party marketing
We will get your express opt-in consent before we share your personal data with any company outside SCIO Capital LLP for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a contract between us or other transactions or while SCIO remains appointed as portfolio managers of any funds where you have an interest or are giving consideration or intending to subscribe for such an interest or where we have a legitimate interest in holding that data.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that you cannot disable or refuse cookies if you are logged in, otherwise you are able to disable or refuse cookies but still continue to have full access and functionality to our website. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External third parties as set out in the Glossary.
• Specific third parties such as service providers to funds we manage or advise e.g. Waystone Investment Management (Lux) S.A. or CACEIS Investor Services Bank S.A.
• Third parties who are conducting a due diligence on our business as portfolio managers or to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. DATA RETENTION

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, we remove your user information and log in details from our website and MailChimp if you cease to be an investor or client of SCIO or no longer wish to subscribe.

By law we have to keep basic information about individuals we deal with (including Contact, Identity, Financial and Transaction Data) for a minimum of 6 years after they cease being clients or investors or cease to communicate with us in order to comply with legal and compliance obligations and because we have a legitimate interest in retaining the information.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for data security or research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click here to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

Lawful basis

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties
External third parties

• Service providers acting as controllers or joint processors based in the EEA and US who provide CRM services (e.g. Pipeline), IT and system administration services, online data storage and data processors (e.g. Microsoft for data storage and MailChimp (which is GDPR compliant) to send emails and newsletters, introduction and advisory services, employment screening service providers and criminal record checks (e.g. HireRight).
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers and compliance professionals based in the EEA, who provide consultancy, banking, legal, insurance, accounting and compliance services.
• Service providers acting as controllers or joint processors to funds managed or advised by SCIO, based in the EEA, including directors, lawyers, auditors, insurers, distribution agents, depositaries, administrators, transfer agents, registrars and domiciliation agents.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Regulators and other authorities acting as processors or joint controllers based in the EEA and US who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

This acceptable use policy sets out the terms between you and us under which you may access our website www.scio-capital.com (our Site). This acceptable use policy applies to all users of, and visitors to, our site. Your use of our Site means that you accept, and agree to abide by, all the policies in this acceptable use policy, which supplement our terms of website use. Our Site www.scio-capital.com is operated and owned by SCIO Capital LLP (we or us). We are registered in England and Wales under company number OC349474 and we have our registered office at address 6th Floor, 130 Jermyn Street, London, SW1Y 4UR, United Kingdom. Our main trading address is 17 Cavendish Square, London, W1G 0PH, United Kingdom. We are regulated by the Financial Conduct Authority.

PROHIBITED USES

You may use our Site only for lawful purposes. You may not use our Site:

• In any way that breaches any applicable local, national or international law or regulation.
• In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
• For the purpose of harming or attempting to harm minors in any way.
• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• Not to reproduce, duplicate, copy or re-sell any part of our Site in contravention of the provisions of our terms of website use.
• Not to access without authority, interfere with, damage or disrupt:
• any part of our Site;
• any equipment or network on which our Site is stored;
• any software used in the provision of our Site; or
• any equipment or network or software owned or used by any third party.

SUSPENSION AND TERMINATION

We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our Site. When a breach of this policy has occurred, we may take such action as we deem appropriate. Failure to comply with this acceptable use policy constitutes a material breach of the terms of use upon which you are permitted to use our Site, and may result in our taking all or any of the following actions:

• Immediate, temporary or permanent withdrawal of your right to use our Site.
• Issue of a warning to you.
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
• Further legal action against you.
• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

We exclude liability for actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

CHANGES TO THE ACCEPTABLE USE POLICY

We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our Site.

SCIO-FUND SICAV-FIS: PRIVACY NOTICE IN RELATION TO SCIO-FUND SICAV-FIS IN THE CONTEXT OF GDPR

Please find below a link to the privacy notice. For any enquiries, please email GDPRsciofund@scio-capital.com.

SCIO Fund – Privacy Notice (AIFs) – 30 November 2018

INFORMATION ABOUT OUR USE OF COOKIES

Our website www.scio-capital.com (our Site) uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Site. You must allow cookies to accept our Legal Disclaimer upon entering our Site. By continuing to browse the Site, you continue to agree to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. If you are a registered user of this website we will use a session cookie when you login to allow you to access secure registered users’ content.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We use Google Analytics, the web analytics service provided by Google, Inc. Google Analytics uses cookies to collect information about details of our users, visits to the site (including IP addresses) and the resources they access on it. You can also install the Google Analytics Opt-Out Browser Add-On to prevent Google Analytics cookies being set, available for download here: http://tools.google.com/dlpage/gaoptout?hl=en. We do not use any other third party cookies.

We do not store personally identifiable information. Cookies cannot harm your computer.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Unless you do this, cookies will be issued when you use our website. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

You can also delete cookies via your browser at any time. If you do not accept cookies, or decide to delete them, you will still be able to access and use the website but you won’t be able to login to your registered users’ content.

Except for essential cookies, all cookies will expire after one day.

March 2023

INTRODUCTION

This statement outlines the Firm’s position with respect to the UK Stewardship Code (the “Code”), which was published by the Financial Reporting Council (“FRC”) in July 2010 and amended in 2012 and 2020. Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, the Firm is required to make a public disclosure about the nature of its commitment and level of compliance to the Code or, where it does not commit to the Code, to explain its alternative investment strategy.

The Code is a voluntary code, which aims to enhance the quality of engagement between asset managers and companies in the UK, to help improve long-term risk-adjusted returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with investee companies and is to be applied by firms on an “apply and explain” basis. It also describes steps that asset owners can take to protect and enhance the value that accrues to the ultimate beneficiary.

The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy.

The Code comprises twelve Principles that can be summarised as follows:

THE FIRM’S POSITION ON THE CODE

It should be noted that given the Firm’s specialist focus on asset –backed credit, the number of occasions on which the Firm will have an engagement with UK companies will be limited (albeit from time-to-time the Firm will facilitate investments in bi-lateral loans with UK companies on its clients’ behalf). Therefore, the Code’s relevance has limited applicability to the Firm’s investment activities. The Firm has chosen not to voluntarily commit to the Code given the nature of the Firm’s asset base and its investment approach. This Statement is reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. Should the Firm’s position change we will review our commitment to the Code and make appropriate disclosure at that time. For further details on any of the above information please contact the Firm’s Compliance Officer.

1. MIFIDPRU 8 DISCLOSURE

The Firm is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is a UK domiciled discretionary investment manager to a Luxembourg based collective investment fund. The Firm is categorised as a “SNI MIFIDPRU investment firm” by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s MIFIDPRU 8 disclosure fulfils the Firm’s obligation to disclose to market participants’ key information on a firm’s remuneration policies and practices In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities. This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model.

2. REMUNERATION POLICIES AND PRACTICES

The Firm is subject to the Remuneration Code (the “Code”) for MIFIDPRU Firms as codified in Section 19G of the SYSC sourcebook of the Financial Conduct Authority handbook. This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.

A. QUALITATIVE INFORMATION

The Firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote effective risk management and do not encourage excessive risk taking. The Firm ensures that the remuneration policy and its practical application are consistent with the Firm’s business strategy, objectives and long-term interests. Given the nature and small size of our business, remuneration for all employees is set by the Firm’s initial partners who are the co-managing partners for the Firm. Staff receive a salary which reflects their market value, responsibilities and experience. All staff may also receive variable remuneration, such as an annual bonus, where the individual operates within the risk appetite of the company and has demonstrated appropriate behaviour. Variable remuneration is intended to reflect contribution to the Firm’s overall success. From 2023 staff are entitled to a fixed percentage of any performance fee received by the company for the calendar year. Additionally, staff are assessed throughout the year and rated based on company, and individual performance. The performance assessment considers both, financial measures such as earnings, (which incl a fixed percentage of any performance fee) and profit margin and non-financial measures such as productivity/efficiency and quality, risk management, people and culture, customer focus and growth and innovation. The Firm’s link between discretionary variable remuneration and performance is based upon the following tenets:

• Ensuring an appropriate balance of financial results between staff and shareholders
• Attraction and retention of staff members
• Aligning the interest of senior staff members via long-term incentive awards
• Link a proportion of a staff member’s total compensation to the Firm’s performance
• Discourage excessive risk-taking
• Ensure client interests are not negatively impacted.

B. QUANTITATIVE INFORMATION

With respect to the financial year 2022/2023, The total amount of remuneration awarded to all staff, including the split of fixed and variable remuneration, was as follows:

SCIO CAPITAL LLP CONFIRMS THE FOLLOWING:

We are committed to embedding ESG principles within our organisation, in line with expectations we place on investments.

We believe that high standards of corporate responsibility generally make good business sense and have the potential to protect and enhance investment returns.

As an FCA-regulated company, we do not invest in any countries that are considered high-risk by the FATF for money laundering, bribery and terrorist financing.

We support the UN’s Sustainable Development Goals through our investment policies and daily business operations.

We seek to integrate the consideration and thoughtful management of ESG issues throughout the investment cycle and process consists of five stages (Initial screening, Investment criteria, Quantitative analysis, Qualitative analysis and the Investment committee). Any investment opportunities found not compliant with ESG criteria, will be documented as such.

Pursuant to EU Regulation 2019/2088 (Sustainable Finance Disclosure Regulation) (SFDR) the SFDR classification of SCIO-Fund SICAV-FIS (and its sub funds) is Article 6.

No benchmark was chosen for the purpose of promoting ESG characteristics and/or sustainable investment objectives (where applicable).

The Firm’s Renumeration Policy is consistent with the integration of sustainability risks by virtue of the incorporation of ESG issues into the investment analysis and decision making process, which includes its negative (avoidance) screening for the sectors and countries set out in the Firm’s ESG Policy. The Firm has a collaborative work culture and recognition of achievement and success is not linked solely to financial gains. Discretionary remuneration is awarded taking into account various factors including achievement to ESG goals. The Firm has a collaborative work culture and recognition of achievement or success is not linked solely to financial gains. Discretionary remuneration is awarded considering various factors, including achievement of ESG goals.