UWC Endowment Management Limited (“UWCEM”) is authorised and regulated by the Financial Conduct Authority in the UK with reference number 984693. UWCEM is a private limited company incorporated in England and Wales with company number 14298175. Its registered address is 3rd Floor, 55 New Oxford Street, London, WC1A 1BS, United Kingdom.

The content of this website is for information only and is not intended to be independent investment research. It is not an invitation to buy or sell an investment and is not advice on investments, taxation or on any other matter.

This information is not intended to be used by or distributed to any person or entity in a jurisdiction or country where this would be contrary to local law or regulation. Within the EEA, the fund is only available to Professional Investors as defined by local Member State law and regulation. Outside the EEA, the fund is only available to Professional Clients or Eligible Counterparties as defined by the FCA, and in compliance with local law. This content is not intended for distribution in the United States (“US”) or for the account of US persons, as defined in the Securities Act of 1933, as amended except to persons who are “Accredited Investors”, as defined in that Act and “Qualified Purchasers” as defined in the Investment Company Act of 1940, as amended. It is not intended for distribution to retail clients.

Past performance does not necessarily predict future results and the capital value of investments, and the income generated can fluctuate. Where investments are exposed to currencies other than the base currency of the fund, they may be subject to foreign exchange rate fluctuations.

“UWCEM”, “we”, “us” and “our” means UWC Endowment Management Limited (the “Investment Manager”) and we are committed to respecting your privacy. UWCEM is authorised and regulated by the Financial Conduct Authority in the UK with reference number 984693. UWCEM is a private limited company incorporated in England and Wales with company number 14298175. Its registered address is 3rd Floor, 55 New Oxford Street, London, WC1A 1BS, United Kingdom.

For the purposes of data protection law, we are a data controller in respect of your personal data. UWCEM is responsible for ensuring that it uses your personal data in compliance with data protection law. This privacy notice applies to you if you are providing or have provided UWCEM personnel with any personal data in support of an investment (or potential investment) in a Fund managed by us. The privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

We will collect and process the following personal data about you: 1. Information that you provide to us or one of our affiliates. This includes information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include: your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information. 2. Information that we collect or generate. This might include information relating to your (or an applicant’s) investment in the Fund, emails (and related data), call recordings and website usage data. 3. Information we obtain from other sources. This might include information obtained for the purpose of the Fund’s know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources and information received from the applicant’s advisers or from intermediaries.

Your personal data may be stored and processed by us in the following ways and for the following purposes:

• Assessing your suitability and determining whether you would meet the FCA’s criteria that would enable us to accept and process your application for shares in the Fund and other share dealings, including performing know-your-client procedures, issuing and redeeming shares, receiving payments from and making payments to the applicant, calculating net asset value, and overseeing these processes.
• General business administration, including communicating with future, existing and former investors, communicating with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products.
• Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.
• In respect of information shared with UWCEM and its affiliates, in their business activities relating to the Fund, such as investor relations, discussions with the Fund’s service providers and counterparties, decision-making in relation to the Fund, and business strategy and development.

We are entitled to use your personal data in these ways because:

• We have legal and regulatory obligations that we have to discharge.

• We may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings.

• The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:

• Carrying out the ordinary or reasonable business activities of the Fund, the Investment Manager, the Fund’s administrator or other persons, or other activities previously disclosed to the Fund’s investors or referred to in this privacy notice.

• Ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud.

• Establishing, exercising or defending legal rights or for other purposes relating to legal proceedings.

• Ensuring the security of information systems.

We may from time to time, in accordance with the purposes described above, disclose your personal data to other parties, including (a) to a fund managed by us (b) professional advisers such as law firms, fund administrators, accountancy firms and their affiliates, (c) other service providers providing services to us or a fund managed by us, including technology service providers, (d) counterparties and (e) courts and regulatory, tax and governmental authorities. Some of these persons will process your personal data in accordance with our or a fund’s instructions and others will themselves be responsible for their use of your personal data. These persons may be permitted to further disclose the personal data to other parties.

We may also share your personal data outside of UWCEM and our affiliates:

• to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements, and they will only use your personal data as described in this privacy notice; and
• to the extent required by law, for example if we are under a duty to disclose your personal data to comply with any legal obligation, establish, exercise or defend our legal rights.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers. Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. For example, the country that we send the data to might be approved by the European Commission, the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data, or where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme. In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

How long we hold your personal data for will vary. The retention period will be determined by various criteria including the purpose for which we are using it (we will need to keep the data for as long as is necessary for that purpose), and legal obligations (laws or regulation may set a minimum period for which we have to keep your personal data).

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

• The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you.
• The right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so.
• In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us.
• The right to request that we rectify your personal data if it is inaccurate or incomplete.
• The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it.
• The right to object to, and the right to request that we restrict our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request.
• The right to lodge a complaint with the data prote

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below. You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to Joanne Francis (jo@uwcendowment.com)

The Modern Slavery Act 2015 came into force on 29 October 2015 and requires businesses in scope to produce an annual statement setting out the steps they have taken to ensure that there is no modern slavery in their own business or in any of their supply chains. Modern slavery includes slavery, servitude and forced or compulsory labour and human trafficking.

UWCEM is a private limited company, which employs a global fund of funds strategy on behalf of the UWC Endowment Fund. UWCEM has given careful consideration to Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015. UWCEM sources the majority of its services from traditionally low-risk countries, such as the UK where modern slavery is not prevalent. Its review has concluded that the services it provides are very unlikely to be affected by slavery, as are the supply chains of those it uses for the purchase of services. Accordingly, it has been deemed unnecessary for UWCEM to take any further action in respect of this legislation at this time.

UWCEM does not condone any activity which constitutes a criminal and/or civil offence. The effectiveness of the steps taken by UWCEM to ensure that slavery and human trafficking is not taking place in its business or supply chain will be kept under periodic review.

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, an FCA authorised firm managing investments for a professional client is required to disclose a statement about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the "Code").

The Code is voluntary and sets out a number of principles relating to investor engagement. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their approach. UWCEM, on behalf of its clients, pursues a global fund of funds strategy, however it may also invest on behalf of its clients in global direct equity investments. UWCEM’s approach is to exercise underlying clients’ rights as a shareholder in a manner that seeks to serve clients’ best interests, as determined by UWCEM in its discretion, taking into account relevant factors, including, but not limited to, the impact on the value of securities.

UWCEM takes a global approach to investing and, while UWCEM generally supports the objectives that underlie the Code, it is not considered appropriate to commit to a particular voluntary code of practice relating to a specific jurisdiction.