The small print

Important Information

You have reached the europeanwealth.com domain for European Wealth entities located in the United Kingdom and internationally. Access to the information contained on this website may be restricted by laws and regulations applicable to the user. Persons in respect of whom such prohibitions apply must not access the European Wealth website. Country or regulatory requirements may prevent certain visitors from being solicited, offered certain services or financial products or engage in business with certain entities of European Wealth.

The European Wealth website is not directed at any person in any jurisdiction where, by reason of that person’s nationality, residence or otherwise the publication or availability of the European Wealth website is prohibited. Persons dealing with European Wealth entities outside the UK are not covered by the rules and regulations made for the protection of investors in the UK. This means that such persons will not have the benefit of rights designed to protect investors under the Financial Conduct Authority. In particular, such persons will not benefit from the right to claim through the Financial Ombudsman Service for losses resulting from a default of obligations owed under relevant regulations. European Wealth does not offer any investment services to persons located in the United States.

The European Wealth funds will only be distributed publicly in the countries in which the funds are authorised for public sales. Any investment in the European Wealth funds should only be made after reading the related legal documents such as management regulations, prospectuses, annual and semi-annual reports. These can be all be obtained from the funds’ representatives in each country where the funds are incorporated or registered.

On this website you may be offered automatic links to other sites. Following links to any other off site pages or other websites shall be at your own risk. European Wealth has not reviewed any such websites and does not endorse or accept any responsibility for their content, nor for any products, services or anything else offered through them.

All of the information and material contained within this Web Site is covered by this disclaimer and is protected by copyright law.

Access to this Web Site is subject to the following:

The Web Site is intended for information purposes only and you must not copy, distribute, store, or manipulate any material within it except for the purposes of private study or research. Use for any other purpose will require written prior permission from European Wealth.

No photographs or images within this Web Site may be reproduced for any purpose whatsoever without written prior permission from European Wealth.

Access to these pages is conditional upon your agreement to indemnify European Wealth and not to hold it liable in any way for the results of any action you may take, or may not take, based on the material within this Web Site.

Whilst you understand that while you may be able to access material through this website European Wealth makes no warranties or representations about the accuracy of any material within this Web Site, or of any other web site to which it may be linked, and neither will it be liable for the quality or completeness of any such material.  The availability of such information does not constitute a recommendation to buy or sell or otherwise trade all or any of the securities or products mentioned therin.

English law governs all matters in relation to this Web Site and all claims or disputes arising out of, or in connection with, this Web Site will be subject to the exclusive jurisdiction of the courts of England and Wales.

Any brand names or trade marks used within this Web Site are the property of their respective holders.

All information and material in this Web Site is copyright © European Wealth Management plc. Further enquiries should be addressed to European Wealth at 10 – 11 Austin Friars, London, EC2N 2HG.

Telephone recording

Telephone calls made to European Wealth may be recorded. These recordings may be used to monitor the accuracy of information provided by our callers and the staff of European Wealth. Recordings of calls may be used to assist companies in European Wealth to comply with regulatory requirements. European Wealth’s staff is aware that conversations may be monitored and recorded.

Privacy policy

At European Wealth we are dedicated to safeguarding and preserving your privacy when visiting our site or communicating electronically with us. This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you when you are on this site.

We do update this Policy from time to time so please do return and review this Policy regularly.

Information we collect

In operating our website we may collect and process information that you provide by filling in forms on our website when you registered for information.

Use of your information

The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, we may use it to provide you with information requested from us relating to our products or services. If you are an existing client, we may contact you with information about our services. If you are a new client, we will only contact you when you have requested information or services from us.

Storing your personal data

Any personal information that we do obtain from you will be handled in accordance with the Data Protection Act 1998.

Access to information

The Data Protection Act 1998 gives you the right to access the information that we hold about you. Please note that any demand for access may be subject to payment of a fee of £10 which covers our costs in providing you with the information requested. Should you wish to receive details that we hold about you please contact us at the email address below.

Contacting us

We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at info@europeanwealth.com.

Complaints

We hope that you will never have reason to complain about our service to you. However, if something does go wrong please bring it to our attention as soon as you can. We will try to resolve the matter fairly and quickly.

If you remain dissatisfied with any aspect of our service, are entitled to make a complaint. We have a complaints procedure that is available on request. If you wish to register a complaint, please contact us:

In writing: 10-11 Austin Friars, London EC2N 2HG

By phone: +44 (0) 20 7293 0730

By email: Compliance@europeanwealth.com

Please be assured we treat complaints seriously. For your further protection if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (‘FOS’). Full details of the FOS can be found on its website at www.financial-ombudsman.org.uk.

Financial Services Compensation Scheme

We are also covered by the Financial Services Compensation Scheme (‘FSCS’). You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.

We may also, on occasion, advise on other financial products which are not regulated by the Financial Conduct Authority (FCA). The Financial Services Compensation Scheme does not apply to any of these products.

Further information about compensation scheme arrangements is available from the FSCS at www.fscs.org.uk/consumer.

The UK Stewardship Code

European Wealth Management Group (‘European Wealth’) complies with the UK Stewardship Code in relation to the seven main principles of this Code. The aim of the Code is to set the benchmark for institutional investors to meet ownership obligations in respect of UK Companies. Compliance with the Code requires it to be applied on a ‘comply or explain’ basis. This means that where a firm chooses not comply with a particular principle in the Code, it is still compliant with the overall Code where this is properly disclosed and explained. This statement sets out the approach European Wealth takes towards the governance of companies in which our firm invests in on behalf of such clients.

Principle 1 – Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

The Code is addressed in the first instance to firms who manage assets on behalf of institutional shareholders such as pension funds, insurance companies, investments trusts and other collective investment vehicles. We primarily manage the assets of Retail Clients but, as required by the rules of the Financial Conduct Authority, this policy statement focuses on our institutional investor clients where we are able to exercise voting rights on investments held on such institutional clients’ behalf. Where appropriate for such clients, we may vote on any issue affecting the long-term value of a company in which we have invested on our clients’ behalf.

Principle 2 – Institutional investors should have a robust policy on managing conflicts of interest in relation to stewardship and this policy should be publicly disclosed.

As an FCA regulated business, European Wealth seeks to place the interests of our clients first and to avoid conflicts of interest between different client groups and those of the company in accordance with the recommendations of the Code.

Principle 3 – Institutional investors should monitor their investee companies.

Monitoring companies in which we invest on behalf of clients is a fundamental part of our research process. This is primarily the responsibility of our Investment Management Committee which meets on a regular basis. We do not normally attend general meetings of the companies in which we invest although we may attend those meetings of companies where we have a major shareholding or where there may be a contentious issue that may affect the value of our shareholding.

Principle 4 – Institutional investors should establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value.

European Wealth has not adopted prescriptive guidelines for when and how we will escalate our activities and will depend on the materiality of the issue and our assessment of whether such engagement is in the best interests of our client. Given the relative size of our holdings, our ability to influence company management may be limited.

Principle 5 – Institutional investors should be willing to act collectively with other investors where appropriate.

European Wealth tends to invest only in companies that we feel are well run in the interests of shareholders. However, we would be willing to be approached by other investors and will consider collective engagement where we feel it is more likely to influence the outcome and protect our clients’ interests.

Principle 6 -Institutional investors should have a clear policy on voting and disclosure of voting activity.

Our standard policy is not to vote at meetings of companies in which we invest as given the relative size of our holdings our ability to influence company management may be limited. However, where we feel strongly on an issue or where we disagree with management on a particular matter we will vote accordingly. In this instance we may not inform the company in advance of that intention or the reasons why.

Principle 7 – Institutional investors should report periodically on their stewardship and voting activities.

As we have a standard policy not to vote in meetings, European Wealth believes that it is inappropriate to disclose activity as a matter of course whether on this website or elsewhere, as we do not consider that making these records public would serve our clients’ interests. We are happy to report on such matters in confidence directly to clients on request.