alquity sicav - due diligence questionnaire

DUE DILIGENCE QUESTIONNAIREApril 2021

LIFECHANGINGINVESTMENTS

ALQUITY SICAVOperations & Finance Due Diligence Questionnaire

July 2021

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CONTENTS1. ALQUITY INVESTMENT MANAGEMENT LIMITED 4

1.1 Contact Information 4

1.2 External Service Providers 4

1.3 Company Information 5

1.4 Organisation, Structure & Oversight 6

1.5 AIML Structure 9

1.6 Manager Track Record 10

1.7 Compliance & Risk Management 10

1.8 Anti Money Laundering 11

1.9 Insurance 13

1.10 Internal Policies 13

2. ALQUITY SICAV 14

2.1 Investment Manager Information 14

2.2 External Service Providers 14

2.3 Fund Facts 14

2.4 Investment Rules & Guidelines 16

2.5 Trading & Operations 18

2.6 Investor Servicing & Reporting 18

2.7 Risk Management 19

3. ALQUITY AFRICA FUND 20

3.1 Sub-Fund Information 20

4. ALQUITY ASIA FUND 21


5. ALQUITY FUTURE WORLD FUND 22


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CONTENTS (CONT.)6. ALQUITY INDIAN SUBCONTINENT FUND 23


7. ALQUITY GLOBAL IMPACT FUND 24


8. TRANSFORMING LIVES 25

8.1 Overview 25

8.2 Source of Donations 25

8.3 The Alquity Transforming Lives Foundation 25

8.4 Charity Partner Selection Process 26

8.5 Monitoring Charity Partners 26

8.6 Measuring Impact 27

8.7 Current Partners & Projects 27

8.8 Connecting Investors & Projects 27

8.9 Benefits to the Alquity Business 27

9. TRANSFORMING LIVES FOUNDATION 28

9.1 Our Vision 28

9.2 The Awards 28

9.3 Eligibilty 29

9.4 Regions 29

9.5 The Alquity Story So Far 29

9.6 For More Info and to Join Us 29

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1. ALQUITY INVESTMENT MANAGEMENT LIMITED1.1 CONTACT INFORMATION

1.1.1 COMPANY NAME

Alquity Investment Management Ltd.

1.1.2 COMPANY ADDRESS

9 Kingsway London WC2B 6XF United Kingdom

1.1.3 TELEPHONE NUMBER

+44 (0) 207 557 7850

1.1.4 FAX NUMBER

+44 (0) 203 0041 645

1.1.5 EMAIL ADDRESS

[email protected]

1.1.6 WEBSITE

www.alquity.com

1.1.7 KEY CONTACTS

Brad Crombie Chief Executive Officer [email protected]

Paul Robinson Chairman and Founder [email protected]

Francisco Almada Chief Operating Officer [email protected]

Suresh Mistry Co-founder, Sales Director, Head of ESG Reporting [email protected]

Alex Boggis Sales Director UK [email protected]

Renee Arnold

Sales Director North America [email protected]

1.2 EXTERNAL SERVICE PROVIDERS

1.2.1 AUDITOR

SAFFERY CHAMPNESS

71 Queen Victoria Street London EC4V 4BE

1.2.2 LEGAL ADVISORS

DECHERT LLP

160 Queen Victoria Street London EC4V 4QQ

1.2.3 COMPLIANCE ADVISORS

OPTIMA

52 Grosvenor Gardens

Belgravia

London

SW1W 0AU

1.2.4 IT ADVISORS

RFA

Berger House

Mayfair

London

W1J 5AE

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1.3 COMPANY INFORMATION

1.3.1 INTRODUCTION

Founded in 2006 as part of the Alquity Group (now Alquity (UK) Limited), Alquity Investment Management Ltd is the investment manager of the Alquity SICAV.

Alquity is an asset management business that connects investors to their investments and to social progress in order to deliver better returns for all.

Our funds aim to deliver attractive risk-adjusted growth over the long-term via a high conviction, fundamentally driven process.

This approach emphasises not only financial analysis but also material non-financial factors, which incorporates forward-looking Environmental, Social and Governance (ESG) analysis to assess management capability and values. This results in portfolios that play long-term themes via transparent companies, with effective management who are aligned with shareholders.

Alquity funds are, therefore, responsible by construction, targeting consistent out-performance whilst contributing to long-term growth. This philosophy resonates across the broader business; we encourage fund manager engagement and are happy to share our analysis.

Further, at the corporate level we reinforce that social progress should drive financial success by donating a proportion of our management fees to development projects in the regions in which we invest. In this way, our business aligns the values of investors, employees, holdings and communities.

We believe these shared values are key to achieving enduring financial success.

1.3.2 TYPE OF COMPANY

Private Limited Company

1.3.3 PLACE & DATE OF INCORPORATION

Place: United Kingdom

Company number: 06020476

Date: December 2006

1.3.4 DOMICILED

United Kingdom

1.3.5 OFFICE LOCATIONS

London

1.3.6 FUNCTIONS PERFORMED AT LONDON OFFICE

Alquity SICAV investment management decisions, analysis, fund operations and business development.

1.3.7 LOCATION OF TRADING, RESEARCH & PORTFOLIO ACTIVITY

London

1.3.8 LOCATION OF ALQUITY OPERATIONS

London

1.3.9 REGULATORY AUTHORITY

Alquity Investment Management Ltd is authorised and regulated by the Financial Conduct Authority, registered number 463991.

1.3.10 KEY SYSTEMS USED

Bloomberg

Microsoft Office

Limina

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1.4.1 OWNERSHIP STRUCTURE

Alquity Investment Management Limited (AIML) is owned by Alquity UK Limited:

Since inception of the Alquity Africa Fund in 2010 there has been no significant change in the ultimate beneficial ownership of AIML, which remains with Paul Robinson.

There was a group restructure in 2013. This restructure took place to enable the external fundraise of new equity into the business:

• Pre-2013, AIML was owned by Alquity Group Limited, a Cayman Island entity owned by Paul Robinson.

• Post-2013, AIML was transferred from Alquity Group Limited to a new entity called Alquity UK Ltd (AUK). AUK is a UK registered business. After the external fundraise, the founders (Paul Robinson and Paul Freer) owned 90% and the external shareholders owned 10%.

During 2015, the business undertook a second EIS fundraise, increasing the proportion of the business owned by the external shareholders from 10% to 14.6%.

The group has raised further funding in 2020. This was via a Convertible Loan note with investment from Investible, a leading Australian VC group which was matched by the British Business Bank Future Fund. In addition, industry stalwart and founder of Aberdeen Asset Management, Martin Gilbert, also invested. East Capital, a Swedish asset manager with c. Euro 4.5bn AUM took a 9% stake and has entered into a partnership to create operational economies of scale in Luxembourg as well as a joint ESG and Impact Council that aims to keep both firms at the cutting edge of responsible investment.

As part of its long-term incentive plan, the business runs an employee share option scheme.

1.4.2 EMPLOYEES

As of April 2021 Alquity Investment Management

Ltd has 15 full time employees.

1.4.3 ORGANISATION STRUCTURE

See Figure 2 below.

1.4.4 SENIOR MANAGEMENT TEAM

The senior management team consists of the AIML directors, as well as senior managers from the Alquity team.

Their responsibilities include:

• Day-to-day running of the business

• Fund management execution

• Sales management

• Operational processes

• Compliance

Decisions made within this group are then ratified at the quarterly meetings of the Board of Alquity Investment Management Ltd and that of its parent Alquity UK.

Brad CrombieChief Executive Officer

Previously Brad was Global Head of Fixed Income at Aberdeen Asset Management, now a part of Standard Life Aberdeen PLC, a FTSE 100-listed asset manager, where he served on the company’s executive committee as well as Director of its principal UK operating subsidiaries. Prior to joining Aberdeen, Brad was Managing Director and Head of EMEA Non-Financials Credit Research at Bank of America Merrill Lynch. He started his investing career in European High Yield.

Brad also serves on the Business Strategy Committee of the Global Risk Institute in Financial Services and the Advisory Group on McGill University in the UK and Europe. From 2015 to 2018, Brad served as a founding member of the Advisory Council of the FICC Market Standards Board (FMSB), the body created following the UK’s Fair and Effective Markets Review (FEMR), initially serving on its Conduct & Ethics Sub-Committee.

Brad graduated from McGill University with a BA Degree in History and Political Science and an MA Degree in History and went on to read History in the PhD. programme at the University of Cambridge.

Figure 1 *includes current and former employees

1.4 ORGANISATION, STRUCTURE & OVERSIGHT

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Francisco AlmadaChief Operating Officer / Chief Financial Officer

Francisco brings 20 years of operations, management, legal, control and fund structuring experience in regulated institutions such as Ibex Capital (CFO/COO), Permira Advisers (Head of Structuring), Portland Hill Capital (COO/CFO) and Ernst & Young (Director).

He has a Juris Doctor from Universidade Catolica Portuguesa (5 years, one of which at the Universita degli Studi di Torino in Italy) and is a qualified Portuguese lawyer

1.4.5 INVESTMENT TEAM

The Investment Team is made up of 5 full-time investment professionals:

Mike Sell Head of Emerging Markets

Mike joined Alquity in 2014 and is responsible for all equity investments.

Mike holds a First Class BA in Economics from Southampton University and was awarded the Pearce Rowan prize.

Mike has over 20 years’ experience investing in Asian equities. He joined Baring Asset Management as a graduate trainee in 1994, where he became a member of the Emerging Market Asset Allocation Committee. Mike was then appointed Senior Partner at Thames River/Nevsky Capital, where he grew their Emerging

Market assets to US$7bn over 7 years, before moving to F&C with the long only Emerging Market business in 2011.

Gergely Ürmössy Global Macro & Portfolio Strategist

Gergely supports the investment team with macro analysis across emerging markets. He holds a Master of Economics from the Corvinus University of Budapest, a Master of Economic Policy in Global Markets from the Central European University and is a CFA® Level 3 candidate. Having started his career as a macroeconomic analyst at ING Bank, Gergely joined Alquity from Erste Bank in Hungary, where he spent four years as Chief Economist.

Marnie Aragon-Uy Head of Quantitative Strategies and Quantitative Risk

Marnie joined from Aberdeen Asset Management where she was formerly Global Head of Quantitative Analytics. Prior to this she was a Portfolio Manager at Deutsche Asset Management. She supports the investmemt team with risk analytics and optimising portfolio construction.

Figure 2

ALQUITY INVESTMENT MANAGEMENT ORGANISATIONAL STRUCTURE

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Kieron Kader Associate Portfolio Manager

Kieron joined Alquity from BP where he performed a variety of roles at one of the largest pension funds in the UK. Most recently, he spent two years as a Global Emerging Markets equity analyst, and also covered Developed Market equities, UK property and multi-asset risk in the prior two years.

He has passed the three Chartered Financial Analyst exams with first time passes. He has a BSc Economics (1st Class) from the University of Southampton, and an MSc Economics (Distinction) from University College London (UCL).

Dan Billis Senior Investment Analyst

Dan joined Alquity in 2018 and supports Mike Sell with the Asian and Indian Subcontinent funds by providing fundamental research across the regions, on both a macro and micro (stock) level.

He passed the CFA® Level 1 examination on his first attempt and has a 1st Class degree in Economics from the University of Exeter. Dan joined Alquity from Invesco, where he worked as

an Account Onboarding Manager.

1.4.6 FINANCE & OPERATIONS TEAM

The Finance & Operations Team is led by Francisco Almada (Chief Operating Officer). The team is also made up of:

Liam Kelly Head of Operations

Liam joined Alquity in 2016, and since November 2018 has been responsible for managing operational processes including relationship management with external parties, which includes the fund administrator and management company based in Luxembourg. He also provides data and analytical support for the sales and investment teams.

Liam holds a BA in History and Politics from the University of Hull, and in 2015 he spent a year in New York interning at Citi Private Bank as a Business Analyst in the Chief Operating Office of the Global Managed Investments department.

Katie Harmer Operations Analyst

Katie covers a number of operational tasks, procedures and projects to support the operations, sales and investment management teams. This includes daily updates and reconciliation of data for the portfolio management system, day to day management of cash flow, releasing daily prices, reconciliation of internal systems back to third party providers, dealing with invoices, maintaining investor sales data and preparation of sales reports.

Katie joined Alquity directly from Kent University where she completed an MA in International Relations.

1.4.7 ALQUITY BOARD

The Board of Alquity Investment Management Ltd and that of its parent Alquity UK meets on a quarterly basis and is made up of Paul Robinson (Executive Chairman & Founder), Brad Crombie (CEO), Neil Sandy and Jane Nicholls.

Paul Robinson Chairman and Founder

Paul founded Alquity in 2010 and is responsible for developing Alquity’s future strategy and driving growth through uncovering new opportunities and raising awareness across all stakeholders.

Paul has an HND in Business and Finance from Brighton University as well as attending executive leadership programmes at Harvard, INSEAD and London Business School.

Paul has spent the last 20 years building businesses, mainly within the financial services and fund management sector. A keen social entrepreneur, Paul funded and helped build Global Ethics, an ethical goods company operating businesses under the “One” Brand which have generated over £15m in donations to date.

These experiences led Paul to found Alquity, a business that uses social responsibility as a competitive financial advantage.

Brad Crombie Chief Executive Officer

See page 7

Neil SandyNeil joined Barclays Unicorn Limited in 1989 and during his time with Barclays was Client Services Director for their mutual funds business and direct proposition b2. After this Neil went on to complete an MBA and head up their service delivery and supplier management function for Barclays Private Clients and was later Head of International Banking Operations and Operational Rigour for Barclays Wealth. Neil joined Truestone Asset Management in 2006 as Chief Operating Officer.

Neil has built the Truestone brand and operations to industrial strength, defining the client experience and bringing to fruition Truestone’s unique approach to client services. This incorporates traditional investments alongside philanthropic and impact investing opportunities for clients. Neil chairs the firm’s Investment Management Committee. Neil is also a trustee of a charity called “GivingWorks”.

Jane NichollsJane is currently Director, Global Distribution Strategy and Transformation at Aberdeen Standard Investments. Her previous roles include Director, Group Strategy and M&A for Challenger Group in Sydney, Australia and Managing Director, Head of Client Solutions and Strategy at J.P. Morgan Asset Management in London.

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Jane brings proven senior leadership capability and a track record of building businesses and delivering successful strategic initiatives with particular expertise across strategy and distribution across Australia, UK & Europe, Middle East, Asia and Japan.

Jane is barrister and solicitor (High Court of Australia and Supreme Court of Victoria). She holds Bachelor of Economics and Bachelor of Law from Monash University, Australia.

1.4.8 ALQUITY TRANSFORMING LIVES FOUNDATION

Foundation - Board of TrusteesThe Alquity Transforming Lives Foundation was set up to ensure that all of Alquity’s donations are used in the most sustainable way possible that allows people to create true impact and change for themselves and their communities.

The Board of Trustees is chaired by David Brocklebank and Paul Robinson (Founder & Executive Chairman)

In addition to this, there are also three further external Trustees to oversee the donations generated from the funds.

David Brocklebank Chair

David spent 20 years in the technology industry in a variety of roles and technologies including digital rights management, optical storage and multidimensional modelling. Ten years ago he moved into the social sector at Guidestar Data Services, a data specialist on the charity sector which sowed the seeds of what would become his second career.

He is currently Chair of Tree Shepherd, Executive Director of the Venture Partnership Foundation, and now our new Chair at Alquity Transforming Lives Foundation.

Veena Giridhar TrusteeVeena is a qualified accountant with an MBA from INSEAD and 17 years of experience across three different continents of which nine have been in the food and beverage industry, spanning internal consulting, market entry, sales & general management. The first eight years were in the services sector providing accounting and assurance advice to charities and for-profit companies in the Southern African region.

Rupen Shah TrusteeRupen has had a 20-year career at Britvic Soft Drinks PLC, most recently as Finance and Investor Relations Director, and previously held senior leadership roles in sales, international and strategy departments. In the summer of 2016 he left the business to have some time with his family before embarking on a new adventure.

As a British Kenyan Indian, Rupen came from humble roots but was able to achieve something

more because he was given opportunities - I believe everybody deserves opportunities and that links very well to what the Alquity Transforming Lives is all about.

1.5 AIML STRUCTURE

ALQUITY INVESTMENT MANAGEMENT LIMITEDInvestment Manager Regulated by the FCA (UK)

FCA Registered Officers:

Brad Crombie SMF1 (Chief Executive), SMF3 (Executive Director)

Paul Robinson SMF3 (Executive Director)

Francisco Almada SMF3 (Executive Director), SMF16 (Compliance Oversight), SMF17 (MLRO)

The following employees overtake the FCA CF function

Brad Crombie, Paul Robinson, Francisco Almada, Suresh Mistry, Alex Boggis, Mike Sell, Kieron Kader and Cyn Cano

Alquity SICAVUCITS VRegulated by the CSSF (Luxembourg), HKSFC (Hong Kong)

and other jurisdictions

DirectorsKarine Hirn,Paul Robinson, Antonio Thomas (Chairman)

East Capital Management S.A.Management Company

Fundrock Management Company S.A.Central Administration Agent

Skandinaviska Enskilda Banken AB (Lux.) Depositary and Paying Agent

Deloitte (Lux.)Auditors

Elvinger Hoss PrussenLegal Advisers

Figure 3

European Fund Administration S.A.Central Administration Agent Sub-administrative, Sub-registrar and Transfer Agent

Alquity Investment Management LimitedInvestment Manager and Distributor

East Capital Management S.A.Global Distributor

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1.7.2 STAFF TRAINING

Alquity undertakes a compulsory annual training program for all team members covering compliance, conflicts of interests, personal account dealing, market abuse, money laundering and the Bribery Act. All new recruits undergo an induction program covering these matters. The Compliance Officer retains records

of training course attendance.

1.7.3 WITHDRAWAL OR REFUSAL OF AUTHORISATION FROM REGULATORY BODIES FOR THE COMPANY

The regulatory body has never withdrawn or refused authorisation with regards to the company.

1.7.4 WITHDRAWAL OR REFUSAL OF AUTHORISATION FROM REGULATORY BODIES FOR EMPLOYEES

The regulatory body has never withdrawn or refused authorisation with regards to the company’s employees.

1.7.5 CRIMINAL, CIVIL, REGULATORY OR ADMINISTRATIVE PROCEEDINGS IN THE LAST FIVE YEARS

Over the last five years there has been no criminal, regulatory or administrative proceedings against the company, any of its principles, the investment product or any of its directors, including reparations, arbitrations and negotiated settlements.

1.7.6 MONITORING OUTSOURCED FUNCTIONS

East Capital Asset Management as Management Company for the Alquity SICAV is responsible for the management of the Alquity SICAV, and AIML is sub-contracted to carry out Investment Management and Distribution for the Alquity SICAV. In line with the duties of Management Companies as set out by the CSSF in Luxembourg, East Capital Asset Management has ultimate responsibility for the Alquity SICAV, particularly with respect to monitoring outsourced functions.

East Capital Asset Management have a dedicated outsourced functions team who are responsible for making sure that service providers carry out sub-contracted activities in an appropriate manner. FundRock Management Company S.A. sub-delegates the duties relating to the administration of the Fund as well as the transfer and registrar agent function to European Fund Administration S.A. (EFA) have been contracted to cover Trading Advisors (TA) and Administration and Skandinaviska Enskilda Banken AB (publ) acting through its Luxembourg branch (“SEB”) have been contracted to cover Custody for the Alquity SICAV.

1.6 MANAGER TRACK RECORD

1.6.1 FUNDS MANAGED

Alquity Investment Management Limited (AIML) manages Alquity Funds:

• Alquity Africa Fund launched 28 June 2010

• Alquity Asia Fund launched 30 April 2014

• Alquity Future World Fund launched 4 June 2014

• Alquity Indian Subcontinent Fund launched 30 April 2014

• Alquity Global Impact Fund launched 29 January 2021

1.6.2 OLDEST CONTINUALLY ACTIVE FUND

Alquity Africa Fund

1.6.3 LARGEST CURRENT FUND

Alquity Asia Fund

1.6.4 LENGTH OF TRACK RECORD

Inception of Alquity Africa Fund: 28 June 2010

1.6.5 AUDIT OF TRACK RECORD

The daily NAV is published by our independent Administrator EFA.

The price is also published on Bloomberg, as well as other industry-leading data providers such as Trustnet and Morningstar.

The SICAV, and all its sub-funds, are audited by Deloitte.

1.7 COMPLIANCE & RISK MANAGEMENT

1.7.1 RESPONSIBILITY FOR COMPLIANCE

Francisco Almada (Chief Operating Officer and Compliance Manager) was recruited in May 2019.

Francisco is the principle point of contact for all compliance matters and has access to an external firm of compliance consultants for technical advice.

Francisco is responsible for all compliance and has been assigned the FCA controlled functions of SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting).

On a quarterly basis, Francisco reviews all records retained as per the compliance manual and plan for any potential regulatory changes.

Once a quarter the external compliance consultants conduct a compliance review to provide an independent assessment of compliance related processes and procedures.

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A material proportion of East Capital Asset Management monitoring is carried out on EFA/SEB’s activities. Specifically monitoring is carried out on:

• KPIs provided by EFA/SEB

• Regular meetings with EFA/SEB management to raise and resolve persistent issues

• Audits are carried out by East Capital Asset Management on EFA/SEB processes to ensure that they are in line with stated procedures. Key areas of concern/ topical issues are prioritised and reliance is placed on SAS70 type reporting for processes not covered. For example, recently AML/KYC has been identified as topical and East Capital Asset Management audits have been focused there

• Accounting data is provided to East Capital Asset Management by EFA and is monitored by East Capital Asset Management for outliers and inconsistencies

East Capital Asset Management also monitor outsourced Investment Management and Distribution functions carried out by AIML. Areas covered include:

• Due diligence on brokers used to execute trades

• Due diligence carried out on distribution intermediaries

• Post-trade portfolio compliance with UCITS rules for the SICAV (e.g., 5/10/40)

• Compliance with investment mandate AIML carry out monitoring on a number of outsourced functions. The process includes:

– Maintenance of an EFA/SEB issues log to pick up persistent issues

– Review of monthly KPI report from EFA/SEB and follow-up on material items

– A weekly call with East Capital Asset Management that covers:

– A review of KPIs

– A review of fund costs and an update on steps taken to manage fund costs

– Ad-hoc requests from East Capital Asset Management relating to monitoring of outsourced functions

– Monitoring of weekly and monthly risk reporting is provided by East Capital Asset Management.

1.7.7 AIML’S RISK MANAGEMENT PROCESS

The operations team does a daily portfolio compliance check on the 5/10/40 compliance of the portfolio at sub-fund level. The level of un-invested cash with any issues identified is reported to the compliance officer and the portfolio manager for that portfolio.

The Alquity Investment Committee has also issued investment management guidelines (in terms of country, industry and sector exposure), which are monitored as part of this process.

1.8 ANTI MONEY LAUNDERING

1.8.1 ANTI-MONEY LAUNDERING (AML) AT ALQUITY

Alquity’s AML function is outsourced to the Fund

Administrator, EFA. Alquity visits EFA on a regular basis to ensure that AML procedures are followed. In addition to this, Alquity incorporates an AML procedure as part of its compliance monitoring programme.

1.8.2 AML OFFICER

Francisco Almada (COO) is responsible for all AML and has been assigned the FCA controlled functions of SMF17 (Money Laundering Reporting).

The Management Company, East Capital Asset Management, undertakes MLRO on behalf of the fund activities.

1.8.3 PROCEDURES TO ENSURE COMPLIANCE WITH AML POLICIES

The Fund Administrator, EFA, carries out the AML checks. AML procedures are also checked as part of the annual audit carried out by Saffery Champness for Alquity Investment Management Limited.

The following AML procedures are incorporated in the visits and discussions to their offices.

EFA has an enterprise-wide compliance programme to deter, detect and report suspected money laundering and terrorist financing activities. The programme applies appropriate risk-based scrutiny and monitoring measures to clients, particularly those whose business activities are known to be susceptible to criminal activity or who have been designated as high-risk for money laundering or terrorist activity financing.

EFA’s Global Anti-Money Laundering Compliance Group is dedicated to the continuous development and maintenance of robust policies, guidelines, training and risk-assessment tools and models, consistent with national requirements and international best practices. This helps their employees deal with ever-evolving money laundering and terrorism financing risks. To enhance their anti-money laundering and terrorist activity financing detection capabilities, the company

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has implemented a combination of automated systems and analytical processes to detect, track and assess transactions for suspicious activities as well as to identify transactions that meet prescribed thresholds for reporting to regulators.

As part of EFA’s enterprise-wide compliance program, in addition to Anti-Money Laundering and Anti-Terrorist Financing, EFA has also implemented policies in respect of Client Due Diligence and Economic Sanctions that establish minimum enterprise standards. These standards are designed to guide EFA’s various businesses in developing their own policies, guidelines and processes, to be consistent with EFA policies and standards, as well as compliance with various other such laws and regulations to which EFA operations are subject in other jurisdictions in which they operate. Where local laws set higher standards than those contained in the global policies, units must comply with the higher local standards.

Business units are also required to assess their operations to identify potential money laundering risks and establish policies, procedures, guidelines and risk mitigation strategies to address these risks. Annual anti-money laundering training is mandatory for all employees, including senior executives, and reinforces these key obligations.

EFA defines money laundering as any act or attempt to disguise the source of money or assets derived from criminal activity. EFA is committed to preventing the use of its financial services for money laundering purposes by establishing policies and processes to ensure that:

• EFA does business only with those whose identities, activities and funds can reasonably be established to be legitimate and who have been screened against applicable government and regulators’ lists of designated people, entities or countries

• EFA’s directors, officers and employees do not knowingly enter into transactions with or provide or assist in providing, directly or indirectly, financial services to, or for the benefit of, states, entities, and individuals targeted by applicable Economic Sanctions and other anti-terrorism measures

• Staff and others required by legislation are trained to recognise and react appropriately to unusual or potential money-laundering activity, unusual or potential terrorist financing activity or activity that is potentially in violation of applicable Economic Sanctions and understand their legal obligations to block or report activity and transactions/attempted transactions as applicable and required by law

• Required regulatory reporting is completed

• EFA has effective oversight and controls to reasonably ensure ongoing compliance with regulatory requirements

• Appropriate records are retained for at least five years after the account in question is closed or after a transaction is completed, as required.

EFA’s policies require that their businesses establish processes to identify unusual activities and transactions in each jurisdiction in which they operate, to ensure timely reporting of activities deemed to be reasonably suspicious of money laundering or terrorist activity financing is completed as required in accordance with applicable legislation. EFA’s compliance has established anti-money laundering/anti-terrorist financing Financial Intelligence Units that review and investigate reports submitted by staff as well as transactions and activity identified as unusual through monitoring and analytical processes, with the objective of ensuring that reports are filed with relevant authorities and client relationships that represent an unacceptable risk to EFA are exited.

Audit

EFA’s Internal Audit Service (IAS) conducts regular, independent testing of the effectiveness of EFA’s AML Program, including testing of execution activities using a risk-based approach. IAS reviews business units’ Anti-Money Laundering, Anti-Terrorism, Economic Sanctions and Client Due Diligence Programs for compliance with the relevant policies, procedures and regulations as a component of regular audits it conducts across the enterprise, and also by conducting audits focused just on the AML/ATF Program.

Technological Tools

In order to meet all relevant requirements, regulations and internal policies, EFA has implemented a number of automated systems and other processes for ongoing scanning of client names and payment information against applicable terrorist, sanctions and other control lists. EFA has similarly developed and implemented various solutions and mechanisms to assist in complying with the transaction monitoring and reporting obligations.

Oversight

EFA is committed to preventing the use of our financial services for money laundering, terrorist activity financing, or in violation of applicable economic sanctions. EFA’s Board of Directors has ultimate responsibility for ensuring that EFA maintains an AML program that meets both regulatory expectations and effectively manages EFA’s AML risk. The Board fulfils this responsibility by ensuring sufficient and appropriately qualified resources to enable EFA to implement and maintain robust and effective AML regulatory risk management and compliance controls, and through effective monitoring and oversight.

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To this end, EFA has established a senior-level management position and a Global AML Compliance team dedicated to the task of overseeing its global policies, practices and procedures with regard to anti-money laundering and anti-terrorist financing enterprise-wide. Senior Management is accountable to implement unit-level AML programs across EFA businesses, while the Global AML Compliance team supports and oversees the development of appropriate AML controls and compliance procedures within the various businesses. Global AML Compliance provides regular reporting to Senior Management and the EFA Board with respect to the effectiveness of the AML Program.

1.9 INSURANCE

1.9.1 POLICIES HELD

Insurance policies are held for the following:

• Directors’ and officers’ liability up to £10m

• Fund liability up to £10m

• Management liability up to US$5m

• Professional indemnity or errors/omission up to US$5m

1.10 INTERNAL POLICIES

1.10.1 CONFLICTS OF INTEREST

AIML has a conflicts of interest policy which records the services and activities in which a conflict of interest may arise:

• Wherever a conflict of interest is identified, a senior manager will be allocated the responsibility of managing the firm’s arrangements.

• All staff are required to identify actual or potential conflicts of interest as they arise and record them on the conflict of interest record sheet and report them to the compliance officer.

• The compliance officer will maintain a conflicts of interest register.

• All senior staff have to confirm completeness of the register of interests annually.

• The Board approves the conflicts of interest policy annually.

1.10.2 PERSONAL DEALING

The Company holds a Personal Dealing Policy. Employees must obtain written approval from the Compliance Officer before entering into a personal securities transaction. Full details of this policy can be found in the Alquity Employee Handbook.

1.10.3 WHISTLE BLOWING

Alquity Investment Management Limited encourages its staff with concerns to blow the whistle internally about matters that are relevant to the functions of the FCA. The Company has adopted procedures for dealing with disclosures, which are notified to staff through the Alquity Employee Handbook.

1.10.4 BUSINESS CONTINUITY PLAN

EFA is the fund administrator and SEB the custodian. EFA and SEB respectively have full BCP and DR capability via IT system backup and alternate office facilities in Luxembourg. EFA and SEB respectively test their BCP and report outcomes via East Capital Asset Management to the Fund Board annually. Business resumption is four hours. AIML in London has a separate BCP plan which was updated in February 2020. These IT systems are fully backed up via an outsourced IT provider on an hourly basis.

Core operations are defined as (1) portfolio monitoring, (2) trade execution and settlement and (3) email communication to clients/brokers. The business essential software is deemed to be:

• Email – is hosted on the cloud on Microsoft 365 platform. Microsoft offer >99% uptime and have fail over to alternate data centres

• EFA/SEB online portal – access to all portfolio reporting, trade instruction upload and compliance checking can all be made via EFA/SEB’s respective online portals which are available from any web-based browser

• Limina – trade management system and portfolio management system is cloud based and can be accessed from any web-based browser

Business continuity can be maintained by AIML from any PC with an internet enabled web browser with items (1) and (2) above. The BCP is tested annually and was last tested in February 2020 and the business was able to maintain core operations.

PAGE 14

2. ALQUITY SICAV2.1 INVESTMENT MANAGER

INFORMATION

2.1.1 INVESTMENT MANAGER

AIML is the appointed investment manager for the Alquity SICAV.

2.2 EXTERNAL SERVICE PROVIDERS

2.2.1 ADMINISTRATORFUNDROCK MANAGEMENT COMPANY S.A.

33, Rue de Gasperich, L-5826 Hesperange

Grand Duchy of Luxembourg

Appointed: 1 July 2021

2.2.1.1 SUB-ADMINISTRATIVE, SUB-REGISTRAR AND TRANSFER AGENTEUROPEAN FUND ADMINISTRATION S.A.

2, rue d’Alsace, L-1122 Luxembourg



2.2.2 AUDITORDELOITTE

20 Boulevard de Kockelscheuer, 1821 Luxembourg


Appointed: 21 May 2019

2.2.3 CUSTODIAN & PAYING AGENTSKANDINAVISKA ENSKILDA BANKEN AB Luxembourg Branch

4, rue Peternelchen, L - 2370 Howald



2.2.4 LEGAL ADVISORSELVINGER HOSS PRUSSEN

2, place Winston Churchill , L-1340 Luxembourg


2.2.5 DOMICILIARY AGENTEAST CAPITAL ASSET MANAGEMENT S.A.

11, rue Sainte-Zithe, L-2763 Luxembourg



2.3 FUND INFORMATION

2.3.1 INVESTMENT PROPOSITION

Alquity is an asset management business that connects investors to their investments and social progress in order to deliver better financial outcomes for all.

Our funds target attractive returns, defined as performance in the top quartile of our peer group over the long-term (3-5 years), via a high conviction, fundamentally driven process.

This approach emphasises not only macro analysis and financial valuation but also Environmental, Social and Governance (ESG) factors to assess management quality, operational excellence and firm values. This results in “quality growth” focused portfolios that monetise long-term themes via transparent companies, with effective management who are aligned with all stakeholders.

Alquity funds are therefore responsible by construction, targeting consistent out-performance whilst contributing to long-term development. This philosophy resonates across the broader business; we encourage fund manager engagement and are happy to share our analysis. Our fund managers actively engage with companies on material ESG issues incorporating our Key Progress Indictors (KPIs) which drive behaviours supporting the principles enshrined in the UN Global Compact.

Further, we recognise that responsible investment alone is insufficient to engender social progress. Therefore, at the corporate level we donate a minimum of 10% of our management fees to development projects in the regions in which we invest. By contributing to long-term sustainable economic development, we create more opportunities for our companies to succeed, closing the Alquity virtuous circle. In this way, our business aligns the incentives and values of investors, employees, holdings and communities.

We believe these shared investment values are key to achieving enduring financial success and sustainable social progress.

PAGE 15

2.3.2 FUND FACTS

2.3.2.1 TYPE OF COMPANY ENTITY

Open-ended umbrella structure SICAV operated under the Undertakings for Collective Investments in Transferable Securities (UCITS V) directive.

2.3.2.2 PLACE & DATE OF INCORPORATION

Place: Luxembourg

Date: 13 April 2010

2.3.2.3 REGISTERED NUMBER OF SICAV

The Company is entered in the Registre de Commerce et des Sociétés in Luxembourg under the number B152520.

2.3.2.4 DOMICILED

Luxembourg

2.3.2.5 BANKS USED BY FUND

Skandinavska Enskilda Banken AB Luxembourg Branch

4, rue Peternelchen, L - 2370 Howald


2.3.2.6 APPLICATION FORM

The application form is available to download from our website.

2.3.2.7 COUNTRIES REGISTERED FOR SALE

The Alquity SICAV is registered for sale in:

• Luxembourg

• United Kingdom

• Switzerland (qualified investors)

• Sweden

• The Netherlands

• Hong Kong

• France

• Singapore

Figure 4

PAGE 16

2.3.2.8 COSTS CHARGED TO THE FUND

The fees payable to the service providers will be within a range of 0.35-0.50% with a minimum fee of up to EUR 70,000 applicable per sub-fund per annum. The fees are payable monthly and accrued on each Valuation Day. The actual amount paid by the Company will be disclosed in the periodic reports of the Company.

All marketing and distribution related costs are

borne by AIML and are not charged to the fund.

2.3.2.9 SUBSCRIPTION FREQUENCY

Daily

2.3.2.10 REDEMPTION FREQUENCY

Daily

2.3.2.11 SUBSCRIPTION CASH SETTLEMENT TIME PERIOD

For approved institutions: received on the fourth business day after a confirmed subscription deal.

For retail clients and unapproved institutions: subscriptions are settled on receipt of cash settlement.

2.3.2.12 REDEMPTION CASH PROCEEDS TIME PERIOD

Paid on the fifth business day after the relevant Valuation Day.

2.3.2.13 FUND HOLIDAY CALENDAR

The fund holiday calendar for all administration including dealing is Luxembourg.

2.3.3 LIQUIDITY

2.3.3.1 REDEMPTION NOTICE PERIOD

There is no redemption notice period.

2.3.3.2 TRANSFERRING UNITS BETWEEN NOMINEES

It is possible to transfer units between nominees.

2.3.3.3 LIQUIDITY PERIODS

Based on one-third of three month trailing average daily volume, the exposures of each fund can be liquidated according to a minimum of:

• 33% of the portfolio within five working days

• Full redemptions for the top five fund investors within five working days

• 90% of the portfolio within 90 working days

2.4 INVESTMENT RULES AND GUIDELINES

Please note that the rules stated in the Prospectus for the Alquity SICAV and those within UCITS documentation are the definitive investment rules for all funds. The following investment rules and guidelines are purely for indicative purposes and should not be seen as exhaustive.

2.4.1 INVESTMENT INSTRUMENTS

Asset Allocation

The Alquity funds are equity focused and will almost always be invested exclusively in the equity asset class.

A maximum 33% of the portfolio may be allocated to fixed income, money market instruments and other transferable securities listed on regulated markets. Typically, this will be in the form of bonds, where equity-type returns are available and this enhances the risk-adjusted profile of our investments.

Derivatives may be used to generate income by selling covered calls and, in rare circumstances, for protection and hedging.

Futures are used for efficient portfolio management.

The funds are generally expected be fully invested but up to 10% of the portfolio can be held in cash. In extreme circumstances, funds can hold cash balances over 10% for up to 30 days with Board approval required to extend the period.

Universe

The funds may invest in eligible assets listed on regional stock exchanges and stocks listed on non-regional stock exchanges if > 50% revenue/profit is generated in the region or is expected to do so in near future.

2.4.2 PORTFOLIO COMPOSITION

2.4.2.1 ISSUER CONCENTRATION

A maximum of 10% in a single issuer

The sum of all holdings greater than 5% must be less than 40%

The sum of related companies, i.e. a holding company and its subsidiary, may not exceed 20%

2.4.2.2 NUMBER OF POSITIONS

Between 25 and 75 for Africa, Asia, Future World and India. Between 75 and 125 for Global Impact Fund.

2.4.2.3 OVERDRAFT FACILITY

Allowed to be overdrawn up to 10% of AUM temporarily

2.4.2.4 COUNTRY EXPOSURE

Africa: Unconstrained

Asia/: : +/- 20% vs index

Indian Subcontinent: Unconstrained

Future World: +/- 10% vs index

Global Impact Fund: +/- 15% vs index

PAGE 17

2.4.2.5 SECTOR/INDUSTRY EXPOSURE (BASED ON MSCI GICS®)

+/- 20% vs. index exposure to any single industry.

2.4.2.6 UNLISTED SECURITIES AND INVESTMENTS WITH LEVERAGE

No physical commodities, physical real estate, underwriting, warrants (P-Notes not included as these are listed and do not have leverage), loans, guarantees, uncovered sales, private equity.

Up to 10% allowed in transferable unlisted securities.

2.4.2.7 SECURITIES LENDING

Over time, we may use stock lending to enhance investor returns. However, this is not currently undertaken and investors would be advised in advance.

2.4.3 CAPACITY

Given our expectations for the markets in which we invest, we anticipate the capacity of our fund range to be a minimum of:

• Africa: USD 500m

• Asia: USD 500m

• Future World: USD 500m

• Indian Subcontinent: USD 350m

• Global Impact: USD 5,000m

Capacity is reviewed by assessing maximum potential AUM of our current universe according to:

• Our internal liquidity limits and estimates for market growth.

• Market size such that no holding would represent greater than 10% of the outstanding shares of that company, combined across all the funds with that holding in their portfolio.

2.4.4 COMMISSIONS, SOFT COMMISSIONS & BEST EXECUTION UNBUNDLING

We do not use soft commissions.

Best execution and commissions are reviewed on a bi-annual basis according to a standardised process.

2.4.5 ROLE OF THE PORTFOLIO & RISK COMMITTEE

Alquity has a comprehensive approach to our ensuring our investment team follows a robust and consistent approach to ESG investing. Specifically, we have governance in place to monitor, evaluate and support the team’s investment process, our funds’ performance, our ESG ratings and Investment Risk.

The Performance and Risk Committee (PRC) oversees the majority of these functions. The PRC meets a minimum of 9 sessions per year, is chaired either by Alquity’s CEO or our Head of Quantitative Risk, and is composed of the senior investment team.

The committee’s role is to review 1) the performance of the strategies, including attribution, 2) our ESG research and ratings process, 3) a suite of quantitative risk analysis that helps the investment team measure and understand risks in the portfolio, and supports

the team’s investment decisions to maintain the best ESG portfolios for our clients and meet portfolio objectives. 4) The PRC also reviews our ‘guardrails’ policy of individual security drawdowns exceeding internal thresholds, which occur on an as needed basis throughout the

year.

2.4.6 TRANSPARENCY OF OUR PROCESS

We are proud of our investment process and stocks notes and portfolios (on a one month lag) are available to all investors.

2.4.7 ENGAGEMENT WITH COMPANIES

Our forward-looking ESG Analysis highlights material non-financial factors to shape our view of management.

The aim of our ongoing engagement process is threefold:

• To help us understand the intentions and authenticity of management in delivering positive future improvements to these factors.

• To actively drive improvement, and ultimately produce better financial returns, by highlighting areas where companies can enhance their practices. We also transmit our knowledge and experience through sharing best practice or introducing them to other portfolio companies where we think there can be learning opportunities.

• We also take investors to visit our holdings to learn more about how their money is being invested. This also provides us with another channel to engage our companies beyond the investor relations teams.

2.4.8 OUTSIDE SOURCES

Over 99% of our research effort is done in-house. This allows a consistency of approach and a degree of rigour we do not believe we could achieve elsewhere. Moreover, ESG analysis is an integral part of our investment strategy (as opposed to a screening or secondary consideration) and therefore occurs alongside traditional financial analysis.

In addition to in-house proprietary research and databases, the following are examples of external sources of information available to the investment manager:

• External stock analysis for specific stocks

• In terms of Environmental, Social and Governance (ESG) research, we work in partnership with the US-based company MSCI ESG to cross-reference our research in this area.

These external sources are used as means to cross-reference our own research but, as previously stated, the vast majority of our team’s research is generated internally, making the most of their expertise and long-term investments in the regions.

Step 3: Determine country risk appetite

PAGE 18

2.4.9 COMPANY VISITS

Company visits form an integral part of the investment process and active engagement both for investment analysis purposes and for ESG advocacy. Our engagement on specific issues can often continue over a number of months as we pursue improvement or greater transparency.

It is anticipated that each company invested in by the funds will be seen twice per annum.

2.4.10 STOP LOSS LIMITS

We do not use automatic stop loss limits.

Emerging markets are volatile and stocks may fall suddenly due to spurious rumours or weight of selling pressure, for example due to underlying redemption pressure on investors. In such a situation, a stop loss limit would force us to sell, whereas (following an analysis of why the stock price is moving, and a confirmation that our investment thesis remains intact) in fact we should use the unwarranted volatility to buy. Our investment thesis is predicated on a long-term view, and we accept that short-tem volatility may occur in our investments.

Once a quarter the investment committee meets with the investment team and is responsible for holding the investment team to account. They are provided with detailed attribution data, including the current portfolio and any changes to the holdings which have been made during the quarter. The investment team is challenged on their positioning and strategy going forward. It would be extremely rare for the committee to intervene directly on the portfolio, but a veto right is held with respect to ESG standards.

2.4.11 AVERAGE HOLDING PERIOD OF INVESTMENTS

The expected average holding period is expected to be in excess of three years.

2.4.12 NEW CAPITAL

For large flows into the funds, new capital is generally invested in line with the existing portfolios, although the fund managers may adjust this for market movements.

For smaller flows, new capital will generally be invested in a minimal number of existing stocks to keep transaction costs low.

2.4.13 CAPITAL FLOWS

Our strategy and trading processes have not changed over time due to capital flows.

2.4.14 CASH MANAGEMENT POLICY

The investment policy is to be fully invested in all normal market environments. In exceptional cases, we may raise cash up to 10% as a protective tool.

2.5 TRADING AND OPERATIONS

2.5.1 TRADE CONFIRMATION PROCESS

The Alquity portfolio managers perform pre-trade compliance checks by inputting trades in to the Limina trading system. Once cleared, the instruction is sent via FIX connection from Limina directly to our master broker CF Global, who then pass the orders to the executing brokers, in line with the semi-annual commission schedule supplied by the relevant investment team and subject to best execution.

CF Global then executes the trades and receives confirmations and these are transmitted back into the Limina system. Alquity operations also receives a trade file from CF Global by close of business on the trade date. Alquity operations performs a series of checks, and cross references this with the broker confirmations. Alquity operations then uploads them into SEB’s Online Portal.

Once uploaded into SEB’s Online Portal, the SEB Custody Team instructs their sub-agent to settle the trade with the underlying broker. Any queries or issues regarding settlements are directed to Alquity Operations/CF Global and any amendments made via the SEB’s Online Portal. Once the trades are matched between the sub-agent and the underlying broker, SEB in its role as Depository, settles in the security currency and then spot FX non-USD exposures to USD in line with a standing instruction. Alquity operations capture the trades in the internal portfolio management system and reconcile to settled cash to ensure that they match expected net settlement. Alquity also has manual procedures in place to ensure urgent trade execution when all other options are unavailable.

2.5.2 INTERACTION WITH BROKERSOver 99% of the work undertaken by the investment team is internally generated, thus interaction with brokers for research ideas and stock modelling is minimal. Where it does occur, it is primarily so that we can understand ‘consensus’ or ‘market’ views on the stocks or economies.

Each investment team determines the targeted commission allocation to each broker on a six monthly basis.

2.5.3 RECONCILIATION OF BROKER CONFIRMATIONS

Trades are reconciled to broker confirmations whenever a trade is placed.

2.5.4 RECONCILIATION OF CASH POSITIONS

Cash position are reconciled on a daily basis.

2.5.5 RESTRICTED STOCK BUYING LIST

There is a restricted stock buying list for the purposes of insider information.

PAGE 19

2.6 INVESTOR SERVICING & REPORTING

2.6.1 NAV CALCULATIONThe administrator, EFA, calculates the NAV.

2.6.2 FREQUENCY OF NAV CALCULATION

The NAV is calculated on a daily basis.

2.6.3 COMMUNICATION OF FUND PERFORMANCE

The NAV for each sub-fund is published daily on the website and on many data services such as Bloomberg, Morningstar and Financial Express.

2.6.4 REPORTS & CORRESPONDENCE SENT TO CLIENTS

Monthly factsheets are sent to clients which are also displayed on the website. Clients are also updated regularly on key facts and figures that support the investment case for the regions that the sub-funds invest in.

2.6.5 HISTORICAL REPORTS

Historical reports can be provided on request.

2.7 RISK MANAGEMENT

2.7.1 RISK MANAGEMENT

Operational risk is defined as the risk of loss resulting from inappropriate internal processes and procedures, people and systems.

Responsibility for Operational Risk at Alquity

• Paul Robinson – Executive Chairman and Founder

• Brad Crombie – Chief Executive Officer

• Francisco Almada – Chief Operating Officer

Operational Risk Framework

A key focus for the team is the identification of operational risk and careful attention is given to processes and procedures designed to mitigate those risks.

The operational risk management process is run as follows:

• All operational processes and tasks are registered and linked to procedures and process documentation.

• The operational processes and tasks register is updated on an ongoing basis and reviewed in depth quarterly.

• On a quarterly basis:

• An operational risk rating is assigned to each item on the procedures and tasks register, and is used to create a Red, Amber and Green dashboard, which is reviewed by senior management.

• A financial impact analysis is carried out on the register and probabilities are assigned to create an expected financial impact.

• A reputational impact score is assigned using subjective estimates.

2.5.6 USE OF ‘SOFT DOLLARS’

The company does not make use of soft dollars.

2.5.7 LEVERAGE EXPOSURE & MANAGEMENT OVER MARKET CYCLES

The funds operate with no leverage, although the funds are able to utilise an overdraft for efficient management of the portfolio.

2.5.8 PORTFOLIO HEDGING

We are long-term investors, not traders. Hedging may be used infrequently in periods of exceptional change or turmoil.

Credit will be used opportunistically where equity type returns are available and this enhances the risk-adjusted profile of our investments.

Listed index futures may be used for efficient portfolio management, and in extreme case for protection and hedging.

2.5.9 USE OF P-NOTES

We invest locally wherever we can, as we believe in acting responsibly in everything we do, including in terms of paying tax. P-Notes may be initially required at launch, given set up delays, but this will not be an ongoing strategy.

2.5.10 FORECASTING FX RATES

We do not explicitly forecast FX rates.

Exchange rate movements are partly down to economic fundamentals, but in the short term are heavily influenced by sentiment and government intervention.

Relying too heavily on FX assumptions that will react to un-forecastable factors will lead to incorrect investment decisions. Our macroeconomic analysis does incorporate a broad view on currencies but is not based on explicit forecasts.

All sub-funds’ share classes are un-hedged.

2.5.11 TRADING/IPO/PLACING ALLOCATION

Where a purchase is made for more than one fund, allocation must be on a pro-rata basis at average prices (wherever allowed by local market practice). Where a holding is sold from a regional fund, to the extent it is not motivated by redemptions, it must be sold from broader funds.

For example, a sale of an Indian stock from the Indian Subcontinent Fund, which also sits in the Asia and Future World funds, must be sold from all three. This is not required in reverse; a holding may be sold from Future World, the broadest “best ideas” product, and remain in any of the focused regional funds.

In the event of an IPO or placing which could qualify for more than one fund, it is at the portfolio manager’s discretion to choose the destination. However, to the extent multiple funds are chosen, this must be allocated pro-rata.

PAGE 20

• Process improvements are prioritised according to the combined expected financial and reputational impact.

• Controls to mitigate material risks are documented and implemented.

• Process improvements are made to reduce operational risks to an acceptable level.

• An error log is maintained and reviewed monthly to identify trends and issues and is used to assist in the operational risk assignment process.

• Included on the register of procedures and processes is the key man risk for each and rotation of duties is planned and carried out to ensure that any process can be covered adequately.

Implementation of Operational Risk Framework

Training on controls and procedures to mitigate operational risk is provided to new employees as part of the induction process. Ongoing training on processes and procedures is provided on a regular basis to reinforce knowledge and update employees with regard to changes.

Operational Risk Monitoring Process

A monthly operational risk meeting is held to review error logs, the process improvement priority list and the operational risk dashboard.

An annual operational risk meeting is held at senior management level to:

• Review the operational risk framework

• Monitor progress made on high priority items

• Assess the level of awareness of operational risk throughout the organisation and training requirements for the team

PAGE 21

3. ALQUITY AFRICA FUND3.1 SUB-FUND INFORMATION

3.1.1 FUND INTRODUCTION

The Alquity Africa Fund is a unique investment opportunity, committed to generating attractive, long-term returns for investors through investments across the African continent. It invests in companies quoted on African stock exchanges together with companies quoted outside Africa but where more than 50% of their revenue and/or profit comes from the African continent.

The fund invests in ordinary shares principally but has the flexibility to invest in fixed-income securities and money-market instruments. The fund is an actively managed, long-only, non-benchmarked orientated fund and aims to generate attractive, risk-adjusted returns over a three to five year time horizon.

The fund is structured as an open-ended SICAV which operates under the Undertakings for Collective Investments in Transferable Securities (UCITS V) directive and regulated by the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg.

SHARE CLASS CURRENCY REPORTING

AVAILABLESHARE CLASS

INCEPTION DATE ISIN TYPEMINIMUM INITIAL

INVESTMENT

ENTRY CHARGE

EXIT CHARGE AMC PERFORMANCE FEE

USD A $ $/ € 25/08/2010 LU0455925619 Retail/Cap $2,000 0-5% 0% 1.9% 20% (USD 1y FED)

GBP A £ £ 25/08/2010 LU0455925700 Retail/Rep £1,000 0-5% 0% 1.9% 20% (GBP 1y SONIA)

USD B $ $/ € 30/06/2010 LU0455925882 Retail/Cap $10,000 0% 0-5% 1.9% 20% (USD 1y FED)

GBP B £ £ 25/08/2010 LU0455925965 Retail/Rep £5,000 0% 0-5% 1.9% 20% (GBP 1y SONIA)

USD I $ $/ € 30/06/2010 LU0457369972 Institutional/Cap $1,000,000 0% 0% 1.4% 20% (USD 1y FED)

GBP I £ £ 30/12/2010 LU0457370475 Institutional/Rep £500,000 0% 0% 1.4% 20% (GBP 1y SONIA)

USD M $ $ 21/06/2012 LU0727489998 Institutional/Cap $2,000 0-5% 0% 1.9% 20% (USD 1y FED)

EUR M € € 17/01/2018 LU1617837908 Institutional/Cap € 2,000 0-5% 0% 1.9% 20% (EUR 1y ESTR)

USD W $ $ 20/02/2017 LU1145751191 Institutional/Cap $5,000 0-5% 0% 1.1% 15% (USD 1y FED +3%)

GBP X £ £ 05/12/2014 LU1070050486 Retail/Rep £1,000 0% 0% 0.3% 0%

GBP Y £ £ 24/05/2012 LU0727491382 Institutional/Rep £2,500,000 0-5% 0% 1.1% 0%

USD Z $ $ 19/12/2011 LU0708699268 Institutional/Cap $2,000,000 0-5% 0% 1.9% 0%

Figure 5


Mike Sell Portfolio Manager

Kieron Kader

Investment Analyst

Dan Billis Investment Analyst

Gergely ÜrmössyMacro Strategist

3.1.3 FUND INCEPTION DATE

30 June 2010

3.1.4 FUND FACTS

For a full breakdown of Fund Facts please see Figure 7 below.

Other share classes are available. Please see the Alquity SICAV prospectus for more information.

PAGE 22

4. ALQUITY ASIA FUND4.1. SUB-FUND INFORMATION


The Alquity Asia Fund is a unique investment opportunity, committed to generating attractive, long-term returns for investors through investments across the Asian continent (excluding Japan). The fund invests in companies quoted on Asian stock exchanges, together with companies quoted outside Asia, but where at least 50% of their revenue, income or assets can be contributed to Asia.

The fund invests in ordinary shares principally but has the flexibility to invest in fixed-income securities and money-market instruments. The fund may invest in derivatives (primarily listed index futures) for the purposes of efficient portfolio management. The fund is an actively managed, long-only, non-benchmarked orientated fund and aims to generate attractive, risk-adjusted returns over a three to five year time horizon.

The fund is structured as an open-ended SICAV which operates the Undertakings for Collective

Investments in Transferable Securities (UCITS

V) directive and regulated by the Commission de Surveillance du Secteur Financier (CSSF)

in Luxembourg.



Kieron Kader

Associate Portfolio Manager


Gergely Ürmössy Macro Strategist


30 April 2014

4.1.4 FUND FACTSFor a full breakdown of Fund Facts please see Figure 8 below.



INCEPTION DATE ISIN TYPE MINIMUM INITIAL INVESTMENT

ENTRY CHARGE


USD A $ $/€/£ 30/04/2014 LU1049766626 Retail/Cap $2,000 0-5% 0% 1.6% 15% (USD 1y FED+3%)

USD B $ $/€/£ 30/04/2014 LU1049766899 Retail/Cap $10,000 0% 0-5% 1.6% 15% (USD 1y FED+3%)

USD M $ $/€/£ 30/04/2014 LU1049767277 Institutional/Cap $2,000 0-5% 0% 1.6% 15% (USD 1y FED+3%)

EUR M € € 17/01/2018 LU1617838468 Institutional/Cap € 2,000 0-5% 0% 1.6% 15% (EUR 1y ESTR+3%)

GBP R £ $/€/£ 05/05/2014 LU1049766972 Retail/Rep £5,000 0-5% 0% 1.1% 15% (GBP 1y SONIA+3%)

USD R $ $ 11/01/2018 LU1730018436 Retail/Rep $5,000 0-5% 0% 1.1% 15% (USD 1y FED+3%)

EUR R € € 17/01/2018 LU1730018519 Retail/Rep € 5,000 0-5% 0% 1.1% 15% (EUR 1y ESTR+3%)

USD W $ $ 20/02/2017 LU1145752835 Institutional/Cap $5,000 0-5% 0% 1.1% 15% (USD 1y FED+3%)

USD Y $ $ 01/09/2016 LU1070051617 Institutional/Cap $5,000,000 0-5% 0% 0.9% 0%

EUR Y € € 03/08/2016 LU1070051880 Institutional/Cap € 5,000,000 0-5% 0% 0.9% 0%


Figure 6

PAGE 23

5. ALQUITY FUTURE WORLD FUND5.1 SUB-FUND INFORMATION


The Alquity Future World Fund is a unique investment opportunity, committed to generating attractive, long-term returns for investors through investments in Latin America, Asia and Africa. The fund invests in companies that are listed on regulated markets in Latin America, Asia and Africa, plus those stocks listed outside the region, which realise at least 50% of their profit or revenue from the region.

The fund invests in ordinary shares principally but has the flexibility to invest in fixed-income securities and money-market instruments. The fund is an actively managed, long-only, non-benchmarked orientated fund and aims to generate attractive, risk-adjusted returns over a three to five year time horizon.

The fund is structured as an open-ended SICAV which operates the Undertakings for Collective Investments in Transferable Securities (UCITS IV) directive and regulated by the Commission de Surveillance du Secteur Financier (CSSF)

in Luxembourg.

Figure 7




ENTRY CHARGE


USD A $ $/€/£ 17/12/2015 LU1049768911 Retail/Cap $2,000 0-5% 0% 1.9% 20% (USD 1y FED)

USD B $ $/€/£ 09/10/2014 LU1049769059 Retail/Cap $10,000 0% 0-5% 1.9% 20% (USD 1y FED)

USD M $ $/€/£ 04/06/2014 LU1049769307 Institutional/Cap $2,000 0-5% 0% 1.9% 20% (USD 1y FED)

EUR M € € 17/01/2018 LU1617839193 Institutional/Cap € 2,000 0-5% 0% 1.9% 20% (EUR 1y ESTR)

GBP R £ $/£ 05/11/2014 LU1049769133 Retail/Rep £5,000 0-5% 0% 1.1% 20% (GBP 1y SONIA+3%)

EUR R € € 17/01/2018 LU1730018949 Retail/Rep€5,000

0-5% 0% 1.1% 20% (EUR 1y ESTR+3%)

USD W $ $/£/$ 20/02/2017 LU1145753569 Institutional/Cap $5,000 0-5% 0% 1.1% 15% (USD 1y FED+3%)

GBP X £ £ 07/01/2015 LU1049769992 Retail/Rep £1,000 0-5% 0% 0.9% 0%






Gergely Ürmossy Macro Strategist

Kieron Kader




4 June 2014

5.1.4 FUND FACTSFor a full breakdown of Fund Facts please see Figure 9 below.


PAGE 24

6. ALQUITY INDIAN SC FUND6.1 SUB-FUND INFORMATION


The Alquity Indian Subcontinent Fund is a unique investment opportunity, committed to generating attractive, long-term returns for investors through investments in the Indian Subcontinent. The fund invests in companies quoted on stock exchanges on the Indian Subcontinent, together with companies quoted outside the Indian Subcontinent, but where at least 50% of their revenue, income or assets can be contributed to the Indian Subcontinent.

The fund invests in ordinary shares principally but has the flexibility to invest in fixed-income securities and money-market instruments. The fund may invest in derivatives (primarily listed index futures) for the purposes of efficient portfolio management. The fund is an actively managed, long-only, non-benchmarked orientated fund and aims to generate attractive, risk-adjusted returns over a three to five year time horizon.



Mike Sell Head of Asian Investments

Kieron Kader



Gergely Ürmossy Macro Strategist


30 April 2014

6.1.4 FUND FACTS

For a full breakdown of Fund Facts please see




ENTRY CHARGE





EUR M € $/ € 30/04/2014 LU1617838625 Institutional/Cap €2,000 0-5% 0% 1.6% 15% (EUR 1y ESTR+3%)


EUR R € $/€/£ 05/05/2014 LU1730018782 Retail/Rep €5,000 0-5% 0% 1.1% 15% (EUR 1y ESTR+3%)

USD W $ $/€/£ 20/02/2017 LU1145752165 Institutional/Cap $5,000 0-5% 0% 1.1% 15% (USD 1y FED+3%)

GBP Y £ $/€/£ 05/05/2015 LU1070052268 Institutional/Rep £2,500,000 0-5% 0% 0.9% 0%



Figure 8

PAGE 25

7. ALQUITYGLOBAL IMPACT FUND7.1 SUB-FUND INFORMATION


The Alquity Global Equities Impact Fund invests in companies that position themselves for long-term financial returns whilst aiming to address all stakeholders’ interests. This includes minimizing the exploitation of people and planet and its negative impact on human and environmental conditions. Our investments are geared to supporting the social and economic conditions for people to thrive and evolve.

The Fund targets superior risk-adjusted returns relative to broad global equity market indices by investing in companies with high ESG and sustainability credentials. The Fund aims to efficiently manage the systemic risk in the broad global market indices whilst tilting towards companies who are advocates of positive environmental and social impact.

The outcome is a portfolio that we believe will outperform relevant global stock indices whilst striving to achieve more favourable impact measures in areas such as carbon intensity, gender equality, social progress and responsible consumption.



Marnie Aragon-Uy Senior Portfolio Manager

Cyn Cano


Gergely Ürmossy Global Macro & Portfolio Strategist


29 January 2021

3.1.4 FUND FACTS

For a full breakdown of Fund Facts please see Figure 11 below.





ENTRY CHARGE





EUR M € €/$ 17/01/2018 LU1617838203 Institutional/Cap €2,000 0-5% 0% 1.6% 15% (EUR 1y ESTR+3%)


EUR R € $/€/£ 17/01/2018 LU1730018352 Retail/Cap €5,000 0-5% 0% 1.1% 15% (EUR 1y ESTR+3%)

USD W $ $/€/£ 20/02/2017 LU1145753130 Institutional/Cap $5,000 0-5% 0% 1.1% 15% (USD 1y FED+3%)




Figure 9

PAGE 26

8.1 OVERVIEWAlquity is an asset management business that connects investors to their investments and social progress in order to deliver better outcomes for all.

At the heart of Alquity lies a fundamental belief that by aligning the values of investors, employees, holdings and communities we can deliver enduring success.

Transforming Lives is how Alquity actively participates in the economic development of the communities within the regions in which we invest. We do this from the ground up, creating opportunities for individuals and communities to pursue and realise their ambitions. In this way we help build fairer, more sustainable economies that respect all their constituents.

By harnessing this energy and talent, economies create wealth and provide more opportunities for businesses, including our fund holdings, to grow over the long term. This helps our funds deliver attractive returns for our investors and completes the Alquity Virtuous Circle.

8.2 SOURCE OF DONATIONSIncorporated into the fundamental tenets of the business is a commitment to donate a proportion of revenues towards charitable projects in regions that our funds invest in. This is set at a minimum of 10% of revenue. Alquity has the option to increase this share based upon the funds available after the financial commitments of the firm have been met.

A proportion of revenues rather than profits was chosen so that from the outset we were able to deliver and develop the “proof of concept” for the full Alquity business model. It also ensures clear transparency of the amounts donated as revenue, unlike profit, is not easily manipulated. Alquity is securely funded and designed to enable the donation to be generated whilst delivering an attractive fund proposition and the high quality customer service expected from a leading asset management business.

Initially, the donations were managed and allocated to charities by the firm directly, but in 2015 we launched the independent Alquity Transforming Lives Foundation (the “Foundation”), which is now fully responsible for the governance and allocation of the monies to approved charity partners. This structure maximises the impact of our donations while ensuring the Alquity team focuses on growing the business and hence donations by delivering an exceptional investment management offering.

8.3 THE ALQUITY TRANSFORMING LIVES FOUNDATIONThe Alquity Transforming Lives Foundation is a UK registered charity (Charity Number: 1162494) that distributes the donation generated by the Alquity business to charities in the regions in which the Alquity funds invest.

The Foundation is governed separately from the Alquity business and the Board of Trustees consists of independent experts, as well as Paul Robinson, Executive Chairman and Founder of Alquity.

The Transforming Lives Manager runs the day-to-day operations of the Foundation and acts as the key liaison between the business, Foundation Trustees and charity partners.

The Foundation was established with a remit to achieve the following charitable objective:

• To contribute to sustainably improving the economic situation of the poorest communities in the countries where Alquity invests by:

• Supporting local entrepreneurs and small to medium enterprises to develop or grow their businesses

• Providing loans for community microfinance groups to increase their household income and better care for their families

• Investing in formal education for young adults

• Investing in vocational and business training for young adults

• Increasing the relevant skills available in underdeveloped communities to make them an attractive place for businesses to start and develop

The Foundation makes an important contribution to the Alquity business by motivating and inspiring employees to deliver strong performance and drive further donations.

The Foundation also provides valuable communication to our customers ensuring there is transparency on how the donations are being allocated and clear measurement of the impact

8. TRANSFORMING LIVES

PAGE 27

being delivered.

The Foundation is governed by the Charity Commission for England and Wales and submits an annual report on its activities. These can be viewed on the Charity Commission website at www.charitycommission.gov.uk. The Foundation started making grants on behalf of Alquity in January 2017.

The Foundation is also able to accept and direct donations from fundraising activities undertaken by Alquity employees, our partners and customers.

8.4 CHARITY PARTNER SELECTION PROCESSThe Foundation has a clear selection process for identifying best in class charitable organisations and projects to support. Through the selection process the Foundation aims to ensure that the grants provide sustainable support for local communities as opposed to a one-off symptom relief.

The process commences with the Foundation sending a request for proposal to potential organisations, which it has identified as working in areas it wishes to target in line with the charitable objectives.

Proposals received must include:

• Background and structure of the charity organisation and individuals

• Breakdown of historical income sources and costs incurred in delivery of services (i.e. what proportion of donation is committed directly to impact delivery)

• Previous partnerships experience and two testimonials from significant independent donors

• How the delivery and impact of services is monitored and evaluated.

• How the charity can work with the Foundation to support communication of its impact to Alquity employees, partners and customers.

The proposals will be reviewed and shortlisted by Alquity’s Transforming Lives Manager before

referral to the Foundation Board of Trustees for final assessment and sign off.

The Foundation seeks to work with organisations with demonstrable excellence in delivery of projects and this is determined through references, reputation and the receipt of credible awards. The Foundation values accountability and transparency and will only work with organisations that are able to provide full financial audits, together with monitoring and evaluation processes evidenced through risk management policies, for example, bribery, child protection and anti-corruption policies.

Successful organisations are selected upon the quality of their submissions, external validation and alignment with the Foundation’s objectives. The Foundation will only engage in a partnership once the appropriate due diligence of the proposal has been undertaken. The timing of the donation will also be selected to ensure it will generate the maximum impact.

The Foundation uses a single measure described as “lives transformed” to determine the impact of projects. This is fully described in the “measuring impact” section below.

Customers and partners are encouraged to nominate projects and charities for the Foundation to consider but they must be based in a region the funds invest, meet the Foundation objectives and pass the selection criteria detailed above.

8.5 MONITORING CHARITY PARTNERSIt is the policy of the Foundation to monitor all grants made. Before a grant is confirmed, conditions are stipulated appropriate to the work to be carried out and progress will be assessed against agreed targets and milestones. If the grant is payable in instalments, then payment of subsequent grant instalments will be dependent on demonstration of satisfactory progress. The Foundation trustees reserve the right to withdraw any uncommitted funds or future grants if these conditions are not met or the Foundation becomes aware of any other relevant information.

Failure to submit reports at the time specified by the trustees may also jeopardise the continuation of the charity’s support. In addition to reports detailing progress, grant recipients will be expected to provide:

• Monthly updates that can be shared through social media and other channels

• Quarterly short updates or case studies from direct beneficiaries of the charity projects

• Bi-annual impact reporting

1. Copies of any published articles, papers or other outputs which may result from the project.

Monitoring visits by the Alquity’s Head of Transforming Lives or charity trustees are also targeted during the period of a grant.

Following the conclusion of the project, the

PAGE 28

grant recipient will be expected to submit a final report, normally within three months of the end of the grant, detailing fully the use of funds and the impact from the project. The grant recipient should inform the charity of any extenuating circumstances whereby the submission of the final report is delayed, to allow a mutually acceptable date for submission to be agreed.

8.6 MEASURING IMPACTThe Foundation has defined a single measure termed “lives transformed” to enable it to consolidate and report to all stakeholders the combined impact of the donations. As the Foundation supports a range of projects in different regions, it is impossible to use a single definition to quantify the overall impact. The Foundation takes a pragmatic approach leveraging the expertise of its charity partners alongside its own monitoring and evaluation process to amalgamate the numbers into a meaningful “ lives transformed” measure.

The “lives transformed” number encompasses the direct beneficiaries from the charity projects (i.e. loan recipients, individuals trained) as well as the indirect beneficiaries (i.e. the direct dependents of loan recipients). Each charity partner is expected to provide evidence (through sample beneficiary questionnaires and independent assessments) of the lives their projects transform and report this to the Foundation.

Most projects are delivered over a specified period of time and often involve a start-up phase. In these situations, the Foundation estimates the total lives transformed by the project and allocates this pro-rata across the lifetime of the project. So if a grant lasts for 12 months and will impact 1,200 lives, the number of lives added to

the total each month will be 100.

8.7 CURRENT PARTNERS & PROJECTSFigure 12 details the current charity partners for each of our funds and the range of projects the Foundation supports through donations.

This list is correct at time of production of this DDQ. As new projects are being initiated regularly, please contact us for an up to date project summary.

8.8 CONNECTING INVESTORS AND PROJECTSAs with our investments, we provide our customers with complete transparency about the destination and impact of the donations generated through their investments in Alquity funds. We do this in two ways:

• Frequent reporting and communication of case studies through all our communication channels.

• Insight Trips during which our customers are able to visit the projects for themselves, question the operational staff from the charity and meet the beneficiaries directly. Customers also visit the holdings in our funds and witness how the projects contribute to economic development in the regions in which these

companies operate.

8.9 BENEFITS TO THE ALQUITY BUSINESSAlquity’s Transforming Lives principle also provides the business with indirect benefits including:

• The ability to access new sales channels (such as fund platforms) at an earlier stage in our business lifecycle as the Alquity model is recognised as being unique and provides a differentiated product proposition to traditional fund providers.

• Strengthened customer and partner relationships as we are able to engage their employees through jointly delivered legacy CSR programmes, such as the Ubuntu Challenge programme with Generali International

CHARITY PARTNER LOCATION ACTIVITY DONATION

TARGET LIVES TRANSFORMED

(DIRECT)

TARGET LIVES TRANSFORMED

(INDIRECT)SDG FOCUS

Afrikids Ghana Employability £17,220 45 0 4 and 8

Hand in Hand Kenya Microfinance £15,000 240 220 4 and 8

Amantani Peru Employability £12,951 20 32 4, 8 and 10

Shivia India Entrepreneurship £10,000 135 675 5, 8 and 10

Reach Vietnam Employability £32,324 771 0 4, 8 and 10

Figure 10

PAGE 29

9. TRANSFORMING LIVES AWARDS

Identifying and supporting excellent social entrepreneurs & sustainable solution focused charities to help unleash potential in communities across Asia, Africa and Latin America.

9.1 OUR VISIONTo become the leading awards programme for sustainable, scalable solutions particularly those supporting growth in sustainable livelihoods and the achievement of UN Sustainable Development Goal 8; economic growth and decent work for all. In doing so, creating an ecosystem of “shared values” businesses who channel their donations through the awards to maximise their impact.

9.2 THE AWARDSTotalling $530,000 in 2019 the Awards recognise:

1. Non-profit organisations that have a proven approach to delivering high impact sustainable solutions and require additional support.

2. Non-profit organisations providing sustainable solutions that have a high potential and require additional support to build capacity and/or scale their operations.

3. Social entrepreneurs and businesses supporting one of the UN SDGs and require start-up capital, loan or second round equity funding to expand operations and accelerate growth.

The Awards offer new paths to capital, profile and expert advice so that winners can invest in their futures and the futures of those they serve.

Award funding is needs based and range from

$25k–$100k

in funding.

Africa

Genjemakers $50k Globalmamas $60k Educate! $100k

Latin America

Luta Pela Pez $60k

Laboratoria $100k

Asia

Phool $50k

Reach $60k

Plastics for Change $50k

2019 Award Winners

PAGE 30

$2.27m generated by the Alquity shared values business model

$530k committed to funding the 2019 awards

Applications will be open from the start of October, and will be sourced through an open portal and through selected referral partners. Following an extensive and participatory assessment and due diligence process, winners will be announced at a global awards event in Summer 2019.

9.3 ELIGIBILITYA core component of all the Awards will be to fund sustainable and/or scalable solutions. Award winners will need to demonstrate a pathway to a sustainable funding model, even if their current model requires donor funding.

9.4 REGIONSThere will be at least one Award in Asia, Africa and Latin America.

9.5 THE ALQUITY STORY SO FARThe Transforming Lives Awards are inspired by the Alquity shared values business model which has generated over $2m in charitable donations and contributed to transforming thousands of lives across Africa, Asia and Latin America.

Driven by the exponential growth of the business, the Transforming Lives Awards rejects the ambition of the rm to become one of the leading social impact businesses in the UK.

Alquity has committed an initial $540,000 to fund the awards, in addition to covering the programme costs. We are looking for additional partners to support the Awards and join our community of excellence.

9.6 FOR MORE INFO AND TO JOIN US.Visit: www.alquityfoundation.org/awards

The information in this document (this “Document”) is for discussion purposes only. This Document does not constitute an offer to sell, or a solicitation of an offer to acquire, an investment (an “Interest”) in any of the funds discussed herein. This Document is not intended to be, nor should it be construed or used as, investment, tax or legal advice. This Document does not constitute any recommendation or opinion regarding the appropriateness or suitability of an Interest for any prospective investor.

This material is for distribution to Professional Clients only, as defined under the Financial Conduct Authority’s (“FCA”) conduct of business rules, and should not be relied upon by any other persons. Issued by Alquity Investment Management Limited, which is authorised and regulated in the United Kingdom by the FCA and operates in the United States as an “exempt reporting adviser” in reliance on the exemption in Section 203(m) of the United States Investment Advisers Act of 1940.

The Alquity Africa Fund, the Alquity Asia Fund, the Alquity Future World Fund, the Alquity Indian Subcontinent Fund and the Alquity Global Equities Impact Fund are all sub-funds of the Alquity SICAV (“the Fund”) which is a UCITS Fund and is a recognised collective investment scheme for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the “FSMA”). This does not mean the product is suitable for all investors and as the Fund is invested in emerging market equities, investors may not get back the full amount invested.

This Document is qualified in its entirety by the information contained in the Fund’s prospectus and other operative documents (collectively, the “Offering Documents”). Any offer or solicitation may be made only by the delivery of the Offering Documents. Before making an investment decision with respect to the Fund, prospective investors are advised to read the Offering Documents carefully, which contains important information, including a description of the Fund’s risks, conflicts of interest, investment programme, fees, expenses, redemption/withdrawal limitations, standard of care and exculpation, etc. Prospective investors should also consult with their tax and financial advisors as well as legal counsel. This Document does not take into account the particular investment objectives, restrictions, or financial, legal or tax situation of any specific prospective investor, and an investment in the Fund may not be suitable for many prospective investors.

An investment in the Fund is speculative and involves a high degree of risk. Performance may vary substantially from year to year and even from month to month. Withdrawals/redemptions and transfers of Interests are restricted. Investors must be prepared to lose their entire investment, and without any ability to redeem or withdraw so as to limit losses.

References to indices herein are for informational and general comparative purposes only. There will be significant differences between such indices and the investment programme of the Funds. The Fund will not invest in all (or any material portion) of the securities, industries or strategies represented by such indices. Comparisons to indices have inherent limitations and nothing herein is intended to suggest or otherwise imply that the Fund will, or are likely to, achieve returns, volatility or other results similar to such indices. Indices are unmanaged and do not reflect the result of management fees, performance-based allocations and other fees and expenses.

All Fund performance results presented herein are unaudited and should not be regarded as final until audited financial statements are issued. Past performance is not necessarily indicative of future results. All performance results are based on the NAV of fee paying investors only and are presented net of management fees, brokerage commissions, administrative expenses, and accrued performance allocation, if any, and include the reinvestment of all dividends, interest, and capital gains. Net returns shown herein reflect those of an investor admitted at inception of the Fund, and are representative of a regular [shareholder], net of applicable expenses and reflect reinvestment of dividends and interest. In the future, the Fund may offer share in the Fund with different fee and expense structures.

The Fund’s investment approach is long-term, investors must expect to be committed to the Fund for an extended period of time (3-5 years) in order for it to have an optimal chance of achieving its investment objectives.

This Document may not be reproduced in whole or in part, and may not be delivered to any person (other than an authorised recipient’s professional advisors under customary undertakings of confidentiality) without the prior written consent of the Investment Manager.

CANADIAN INVESTORS

Alquity has engaged with Stikeman Elliott LLP as their legal representation and is relying on the International Dealer Exemption in the provinces of Quebec and Ontario. With respect to statutory rights of action along with connected and related issuer information please refer to our Canadian Wrapper and Prospectus. This material is for distribution to Professional Clients only and does not constitute any recommendation or opinion regarding the appropriateness or suitability of an investment for any prospective investor.

SWISS INVESTORS

The prospectus, the Articles of Association, the Key Investor Information Document “KIIDs” as well as the annual and semi-annual report of the Fund is available only to Qualified Investors free of charge from the Representative. In respect of the units distributed in Switzerland to Qualified Investors, place of performance and jurisdiction is at the registered office of the Representative. Funds other than the Luxembourg domiciled Alquity SICAV mentioned in this document may not be admitted for distribution in Switzerland.

Swiss Representative: FIRST INDEPENDENT FUND SERVICES LTD., Klausstrasse 33, 8008 Zurich.

Swiss Paying Agent: Neue Helvetische Bank AG, Seefeldstrasse 215, CH-8008 Zurich.

For more information on Alquity, please contact:

UK AND EUROPEAlex Boggis

+44 207 5577 850 [email protected]

MIDDLE EAST & ASIA & UKSuresh Mistry


NORTH AMERICARenee Arnold


www.alquity.com

/company/alquity-investment-management-limited@Alquity /Alquity

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