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Policy on Personal Information and Electronic Communications

This policy tells you about two things. First, it is a privacy notice and tells you what to expect when we collect personal Information from you. Second, it describes some of the risks that you should consider when you communicate with us electronically and the terms on which we do so.

Generation Investment Management LLP

Generation Investment Management US LLP

PRIVACY NOTICE

1. Privacy of your information

We appreciate that you, or a third party on your behalf, has provided us with your personal information. Obtaining personal information from our individual and institutional clients is central to our goal of providing exceptional service. However, we understand that in receiving this information, you expect us to treat it in an appropriate manner.

This policy is designed to provide you with further details on the type of information that we may collect about you, the purposes we might use that information for and the actions we may take to safeguard your information. When we use the term “Generation” below, we are referring to Generation Investment Management LLP, a limited liability partnership formed in England as well as its affiliates throughout the world including: Generation Investment Management US LLP, a United States based limited liability partnership.

2. Where we may collect information from

We will gather information from a number of sources. Typically, it is primarily drawn from applications to open an account with Generation directly or with one of the funds operated by it (a “Generation Fund”). Please note that by investing in a Generation Fund, you authorise that fund to release information about you to Generation. As a fund investor, you may but will not necessarily be a client of Generation directly. If you are unclear as to your status as a client of Generation, please contact our General Counsel at the address below.

After an account is established and as our business relationship develops, we may gather further information from you as you transact with us or the Generation Funds or make servicing requests of us.

In addition to the information provided directly by you, we may gather information about you from a broad range of third parties. This includes other persons that you may instruct to assist you with your dealings with Generation or a Generation Fund, for example, your professional advisers, custodian or investment manager. We may also seek information from credit and individual reporting agencies about you. Third parties may be asked to undertake due diligence about you to assist us in respect of our responsibilities to combat financial crime, to ensure we are in compliance with applicable sanctions regimes, as well as helping us establish and maintain client relationships which we believe are in the best interests of both Generation and our clients.

In line with market practice in the financial services industry, we may record communications with you, including monitoring your e-mails. We will do this in a proportionate manner and always in accordance with applicable laws and regulations designed to protect your privacy in this sensitive area. Typically we would not access your information regularly in this way. Rather, it will be used for compliance, internal control or security purposes to help us comply with our legal and regulatory obligations and as evidence of transactions.

Lastly, we may use close circuit television and recording systems in our offices to protect our staff and physical assets. The owners of the buildings we occupy may operate similar systems. As a result, your physical image may be captured by us on our premises.

3. The type of information we may collect

If you deal with Generation or a Generation Fund in an individual capacity or as the settler or trustee of a trust or the owner of an investment vehicle established on your behalf or that of your family, we may collect the following types of personal data about you.

Type of Data Examples
Personal details Name, age, occupation and relationship status.
Contact details Address, telephone, fax and email (both private and work related).
Identity documents Passport, national identity card, armed forces identity document, driver's licence, gun licence.
Personal identifiers Social Security Number, National Insurance Number, Tax File Number, Taxpayer Identification Number.
Photographs A head and shoulders photograph of you from one of the identity documents specified.
Video Images and Audio CCTV pictures and audio, recordings of phone conversations, presentations given by you to or with Generation.
Financial Information Your source of wealth, investment experience, investment objectives, tolerance of risk and certain representations required under applicable law or regulation or Generation internal policies concerning your financial resources.
Your Personal History Information about your current or former employers, education, business activities, affiliations, roles and responsibilities.

If you deal with Generation in the capacity of an officer, employee, director and or principal of one of our corporate or institutional clients the typical personal data we collect about you would additionally include your role/position/title and area of responsibility and your authority.

Of course, except as otherwise agreed in particular contexts with us, you are not required to supply any of the personal information that we may request from you. However, please note that failure to supply such information may result in you being unable to open or maintain an account with Generation or a Generation Fund. It may limit the services we can provide to you or your company. While we make reasonable efforts to ensure that all information we hold about you is accurate, complete and up to date, you can help us in this regard by promptly notifying us if there are any changes to your personal information. In certain cases, this is of such importance that we will ask you to represent that you will do so.

4. How we use your information

We may use your personal information in a range of different ways.

Activity Details
Account Opening We, or funds operated by us, will use your personal information to set up your account facilities. Examples would include entering your name as shareholder, compliance with our regulatory “know your customer” obligations and ensuring we have the correct records to comply with our tax reporting obligations.
Contact Details We will maintain records of your contact details and the manner in which you wish to be contacted, for example, by phone, fax, post or e-mail.
Reporting We may use personal information to provide you with details of your account or your investment in a Fund operated by us including issuing confirmations and periodic statements.
Provision of Research and other services We may use personal information to provide you with information (such as investment research), recommendations or generic advice concerning your account or products offered by Generation.
Provision of Advice On express agreement with Generation that it is to provide this service to you, we may use the information to form the basis of any personal recommendation or advice we offer.
Provision of Discretionary Investment Management On express agreement with Generation that it is to provide this service to you, we may use the information to inform any discretionary investment management activities we undertake on your behalf.
Internal Controls and Processes We may use personal information to facilitate our internal business operations, including assessing and seeking to manage risk as well as fulfilling our legal and regulatory requirements.
Compliance Matters We may use personal information to carry out various compliance checks as required by law, regulation or Generation’s or its service providers (including those of Generation Funds) internal policies and procedures. Such policies are designed to review creditworthiness, guard against money laundering or fraud and to ensure compliance with sanctions regimes. We may also use personal information to help us determine appropriate client relationships by reviewing political affiliations and records of criminal offences committed or alleged to have been committed and searching media databases.
Regulator Interaction We may use personal information to ensure compliance with our regulatory notification and reporting requirements anywhere in the world (including national and international regulatory bodies and other law enforcement agencies).
Litigation If we are subject to a court action or other proceedings or require, to the extent necessary, to exercise and defend our legal rights we may be required to use your personal information.
Recording We may record (visual and audio) and/or monitor communications, (including: cctv, e-mail, instant messaging, facsimile, telephone and other electronic communications), with you or your agent(s) for compliance, internal control and security purposes and as evidence of transactions.

5. When we will disclose your information within Generation

In order to service you better, and reflecting the globally integrated nature of our business, more than one entity within Generation may be given, or given access to, your personal information. For example, our UK entity might share your information with our US entity in order to facilitate your instructions or the maintenance of your accounts. At the date of this policy, Generation has established offices in the United Kingdom, the United States and Australia. It may in the future open offices in other jurisdictions and will transfer your personal information between such present and future offices. In doing this, we will adhere to applicable legal and industry standards regarding the protection of personal information but the jurisdictions concerned may not have data protection laws as strict as those in the UK, Australia or the United States.

6. When we will disclose information to persons outside Generation

Generation only discloses your personal information to third parties in accordance with this policy. We may provide your personal information to non-affiliated companies that perform support services for your account or to a Generation Fund operated by us - this includes any outsourcing arrangements made by Generation in respect of its business.

If we are transacting as agent on your behalf, we may disclose your personal information to third parties such as settlement agents, counterparties, banks or exchange or clearing houses to whom we disclose in the course of providing products and services to you. We may also disclose personal information to persons who provide professional, legal or accounting services to us. In addition, we may also disclose your personal information to fulfil your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent.

Lastly, in a limited range of circumstances, we may disclose your personal information to third parties in accordance with applicable laws and regulations or pursuant to internal policies and procedures designed to facilitate compliance with such laws and regulations. Examples of this would be: when responding to a writ or similar legal process; cooperation with law enforcement or regulatory authorities or with organisations such as exchanges and clearinghouse; making enquiries designed to assist with our client identification programme; prevent fraud or other financial crime. Non-affiliated companies that assist Generation or a Generation Fund in providing services to you are required to maintain the confidentiality of such information and to use it only in the course of providing such services and for the purposes that Generation specifies.

These third parties may operate from locations outside the European Economic Area, Australia and United States. Again, some of these jurisdictions may not have data protection laws as strict as those in the European Economic Area, Australia or the United States.

7. We will not sell your information

Generation will not sell, rent or trade your personal information nor will it pass it on to third parties for their marketing purposes. Generation may occasionally, in accordance with applicable laws, contact you by post, telephone, electronic mail or facsimile with details of products and services, including Generation Funds, that we believe may be of interest to you. If you do not wish to be contacted in this way, please write to our General Counsel at the address below.

8. How we protect the privacy of your information

We endeavour to protect your personal information at all times. Primarily, we do this by utilising appropriate access controls to those data, so that only authorised Generation employees or agents and our third party service providers have access. We subject such third parties to confidentiality obligations. In addition, we maintain physical, electronic and procedural safeguards intended to protect your information against loss, misuse, damage or modification and unauthorised access or disclosure. Those policies and procedures include educating those working for or on behalf of Generation on information security policies and responsibilities.

9. What rights do you have under European data protection laws?

You have certain specific rights provided under European Union ("EU") data protection law. If you wish to access a copy of your personal data; or you wish to modify any personal data which we hold about you, you can do so by written request to our General Counsel at the address set out below. You are also entitled to have Generation modify or delete any information that is incorrect or out of date; and in some limited circumstances you may have a right to object to our processing of your personal data.

In the case of a request for access to personal data, we and our affiliates reserve the right to charge an appropriate fee, if applicable. You may be asked to supply a valid means of identification as a security precaution to minimise unauthorised disclosure. We will process your request within the time provided by applicable law.

10. Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The website of Generation Investment Management may utilise cookies in accordance with applicable law and regulation. You may delete and block all cookies from this site, but parts of the site will not work.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

11. Ending Your relationship with Generation

If your relationship with Generation or a Generation Fund ends, we will continue to treat your personal information, to the extent we retain it, in accordance with this policy as updated from time to time.

IMPORTANT INFORMATION ON ELECTRONIC COMMUNICATIONS

1. Confidentiality

When you receive an e-mail or other forms of electronic communication from Generation, please be aware the information contained in or accompanying that communication may be confidential, subject to legal privilege, or otherwise protected from disclosure and (unless it expressly states otherwise) it is intended solely for the use of the intended recipient. If you receive a communication from Generation and you are not the intended recipient of the communication, please delete it and destroy all copies in your possession, notify us that you have received the communication in error and note that any review or dissemination of, or the taking of any action in reliance on, any such electronic communication sent in error is expressly prohibited.

2. Right to request traditional delivery

If you have requested electronic delivery of any information, you have the right to request paper copies of any information that is sent to you electronically at any time after the consent noted below. No additional fees are charged for requesting paper copies after consenting to electronic delivery and, thereafter, you will receive paper copies.

3. Risk of interception, viruses and defects

Electronic communications may contain computer viruses or other defects, may not be accurately replicated on other systems or may be intercepted, deleted or interfered with without the knowledge of the sender or the intended recipient. Generation makes no warranty in relation to these matters. As a result, it may be that you are not comfortable with the risks associated with e-mail messages and other forms of electronic communication. If that is the case, please get in touch with your Generation contact and we will be pleased to arrange another means of communication with Generation.

4. Prohibition on publication and alteration of information

Unless you have the express written consent of Generation, you are not permitted to publish, transmit, or otherwise reproduce any information received from Generation, in whole or in part, in any format to any third party. In addition, you are not permitted to alter, obscure, or remove any copyright, trademark or any other notices that are provided to you in connection with the information. Generation reserves the right, at any time and from time to time, in the interests of its own editorial discretion and business judgement to add to, modify, or remove any of the information delivered to you.

5. Generation’s rights in respect of information

Unless there is express written agreement with Generation to the contrary, no information sent to you is intended to, and will not, transfer or grant any rights in or to that information and all rights not expressly so granted herein are reserved by Generation or, if applicable, the third party providers from whom Generation has obtained the information.

6. No warranties made as to content; responsibilities to update

Neither Generation nor its third party providers make any warranty, express or implied, concerning electronic communication. If you elect to receive electronic communications, that is at your sole risk. Generation expressly disclaims any implied warranty of satisfactory quality or fitness for a particular purpose, including any warranty as to the use or the results of the use of information with respect to its correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability.

7. Content not to be construed as a solicitation or recommendation

Unless it expressly agreed between the parties to the contrary, material provided electronically is for information purposes only without regard to the particular recipient’s investment objectives, financial situation, or means. Generation is not soliciting any action based upon it. Any such material is not to be construed as a recommendation, or an offer to buy or sell, or the solicitation of an offer to buy or sell any security or financial product in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. You should neither construe any of the material contained in an electronic communication as legal, regulatory, tax, or accounting advice nor make any services provide by us the primary basis for any investment decisions made by you or your advisers.

8. No representations made as to other sites or links

Our electronic communications may provide links to certain Internet sites ("Sites") maintained by third parties. In this case, Generation is providing such links solely as a convenience to you. Accordingly, Generation makes no representations concerning the content of the Sites. The fact that Generation has provided a link to the Sites does not constitute an endorsement, authorisation, sponsorship, or affiliation by Generation with respect to the Sites, their owners, or their providers.

Changes to our policy

This policy provides a general overview of the ways in which we seek to protect your personal information and important information on electronic communication. Please be aware that we may request certain further confidentiality arrangements be put in place in respect of your interaction with us, especially when we believe there is a risk such information could be material price sensitive information. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our website.

This version of the Policy is effective July 1, 2011.

Contact

General Counsel
Generation Investment Management LLP
20 Air Street
London
United Kingdom
W1B 5AN
+44 207 534 4700