Below sets out information in relation to the services we provide you.

1. Definitions

JCRA means J. C. Rathbone Associates Limited.

JCRA Entity means any entity owned or controlled by JCRA Group Limited and JCRA Entities shall be construed accordingly.

JCRA Individual means any director, associate, consultant, officer or employee of JCRA or any JCRA Entity and JCRA Individuals shall be construed accordingly.

JCRA Group means JCRA, JCRA Individuals and JCRA Entities.

we, us, and our, means JCRA or such other JCRA Entity with which the client has entered into a contract to provide services.

you means the client, being the person or persons identified by us as having provided our instructions and to whom we are providing the services and your shall be construed accordingly.

2. General

JCRA is a private limited company incorporated in England (number 02330205) with registered office and principal place of business at 12 St James’s Square, London SW1Y 4LB, United Kingdom. The group VAT number is 577723305.

JCRA Individuals and Gateley Custodian and Nominee Services Limited (number 08956316) own the entire issued share capital of ENSCO 1240 Limited, a private limited company incorporated in England (number 10807097) with registered office at 12 St James’s Square, London SW1Y 4LB, United Kingdom. ENSCO 1240 Limited owns the entire issued share capital of ENSCO 1149 Limited, a private limited company incorporated in England (number 09796409) with registered office at 12 St James’s Square, London SW1Y 4LB, United Kingdom. ENSCO 1149 Limited owns the entire issued share capital of JCRA Group Limited.

3. Regulatory Regime

JCRA is authorised and regulated by the Financial Conduct Authority (“FCA”), 25 The North Colonnade, London E14 5HS, United Kingdom for certain designated investment business under number 145229. The FCA register detailing JCRA’s status can be accessed here.

JCRA is not authorised to provide designated investment business to retail clients. JCRA provides designated investment business to professional clients and eligible counterparties.

No JCRA Entity holds client money.

4. Confidentiality

Subject to paragraph 8 below, we owe an overriding duty of confidentiality to our clients which includes prospective and former clients.

5. Telephone Conversations

We record telephone conversations in accordance with the FCA’s rules. Records of such conversations and communications are available upon request.

6. Conflicts Policy

The FCA’s rules require JCRA to takes all appropriate steps to identify and to prevent or manage conflicts of interest between JCRA Individuals and its clients or one client and another client. Our conflicts policy is available upon written request to compliance@jcrauk.co.uk.

7. Data Protection

JCRA is registered as a data controller with the UK Information Commissioner under registration number ZA269435. Details about the JCRA’s registration can be found here.

J. C. Rathbone Holdings Limited is registered as a data controller with the UK Information Commissioner under registration number Z3627732. Details about its registration can be found here.

JCRA Group Limited is registered as a data controller with the UK Information Commissioner under registration number ZA269434. Details about its registration can be found here.

JCRA Group processes any personal information you provide to us, or which we obtain, for the following purposes:

• (a) to provide our services to you;
• (b) for financial crime prevention, which may include disclosure to relevant third parties – see section 8 below;
• (c) for storage on our existing or new systems, networks, applications or software, which may include disclosure to relevant third party service providers;
• (d) for marketing communications as set out in section 12 below, unless you object to us doing so; and
• (e) as may be required by law.

8. Financial Crime

JCRA will carry out appropriate, risk-based due diligence before agreeing to accept an engagement with any client.

We will be obliged to make a report to the relevant authorities if at any time we become aware of or suspect financial crime in relation to any matters on which we are engaged or services provided by third parties for a JCRA Entity. Our obligation to make such a report will override our duty of client confidentiality and we may not be permitted to inform the client concerned whether or not we have made, or might intend to make, such a report.

Where we request your personal information for “know-your-customer” purposes, these will typically include:

1. A passport;
2. A full photocard driving licence; or
3. Any other official document including a photograph.

A natural person may also be asked to provide one of the following documents as proof of permanent address:

1. An original bank statement (no more than 3 months old);
2. An original utility bill (no more than 3 months old) - excluding mobile phone bills;
3. An original local authority tax bill (no more than 3 months old); or
4. Evidence on the Electoral Register.

We may also request an up-to-date structure chart identifying: (i) the beneficial owners holding or controlling, directly or indirectly, 25% or more of the shares or voting rights in the company; (ii) any other person who otherwise exercises control over the management of the company; and (iii) the ultimate beneficial owner of the company. The structure chart should have the percentage splits of the relevant shareholdings

We may request that some or all of the above-mentioned documents are certified by an independent, qualified lawyer, notary, FCA-approved person or accountant. Any certified copy document should state:

1. The name, address and firm of the person certifying;
2. That the person certifying has seen the original document in its entirety;
3. That the copy is a true copy of the original; and
4. That any photograph is a true likeness of the individual.

9. Inside Information and Insider Lists

Where you have obligations in relation to the control of inside information and a matter will or may involve our employees working for you on this matter being in possession of inside information we will maintain a list of those of our employees who are in possession of inside information.

We also take reasonable measures to ensure that where we are notified that our employees have access to inside information relating to any client, they understand and acknowledge the legal and regulatory duties imposed on persons in possession of such information and the sanctions involved for misuse and improper disclosure of such information.

10. Complaints Procedure

We have a policy and procedure for dealing with complaints. If you are not satisfied with any contractually agreed services received by us, please e-mail the relevant JCRA Individual involved in your matter copying in compliance@jcrauk.co.uk. All complaints will be considered promptly and fairly and will be investigated by a member of the compliance department who was not involved in the subject matter of the complaint. If your complaint is about a member of the compliance department, your complaint should be submitted to info@jcrauk.com for the attention of the Chief Executive Officer. Our detailed complaints policy and procedures is available upon request.

If a complaint is not resolved to your satisfaction and you qualify as an 'eligible complainant' as defined in the FCA Handbook, you may be able to refer the complaint to the Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR (www.financial-ombudsman.org.uk). The Financial Ombudsman Service is an organisation set up by law to give consumers a free and independent service for resolving disputes with financial firms. Details of the persons who are 'eligible complainants' can be obtained from the Financial Ombudsman Service. Save for very limited circumstances, persons classified as professional clients will not be eligible to have complaints dealt with by the Financial Ombudsman Service.

11. Compensation

JCRA is covered by the Financial Services Compensation Scheme Limited ("FSCS"). In certain circumstances, and if the relevant client is an 'eligible claimant' (as defined in the FCA Rules), the client may be entitled to compensation from the FSCS if JCRA is in default and unable to meet its financial obligations to the client. The amount of compensation available from the FSCS for investment business is £50,000. Further information on the FSCS (including as to the meaning of 'eligible claimant') can be obtained at www.fscs.org.uk.

12. Marketing

We intend to use the contact details that you provide to us for sending out marketing communications including invitations to events, such as seminars or conferences, or briefings, for surveys related to topical financial markets matters or similar publications which we think might be of interest to you.

If you do not wish to receive such communications, please let us know in writing, addressed to our marketing communications team at our London office or by sending an e-mail to: info@jcrauk.com.

We will never pass your information on to third parties for marketing purposes.

13. Reliance

Our advice is provided to and for the benefit of our client only. No other person may use or rely upon the work undertaken for our client nor derive any rights or benefits from such work without our prior written approval.