1.1 First Sentier Investors (“FSI”) is committed to protecting the identity of individuals and safeguarding their Personal data.
what Personal data FSI collects
how FSI collects and stores Personal data
how FSI uses Personal data
how Personal data can be disclosed to others
how an individual can access or correct their Personal data
how to complain if an individual has concerns about how FSI has managed their Personal data.
2.1 This Policy applies to all subsidiaries and affiliates within FSI. FSI is the corporate group comprising the following and all of their direct and indirect subsidiaries:
First Sentier Investors Holdings Pty Limited; and
First Sentier Investors (US) LLC.
2.2 Please refer to Appendix A for the list of companies and investment funds in Europe and the United Kingdom to which this Policy applies.
3. What is Personal data?
3.1 Personal data is information or an opinion about an individual from which the individual can be reasonably identified.
4. What Personal data does FSI collect?
4.1 The Personal data FSI may collect will depend on the circumstances of collection, including whether we collect the information from individuals as an investor or client, a supplier, contractor, stakeholder, job applicant, employee or in some other capacity. For example in some locations business contact details of a company representative with whom we deal are considered to be Personal data.
4.2 FSI collects Personal data so that we can provide products and services and engage suppliers and comply with our legal obligations such as those under taxation and anti-money laundering and counter-terrorism financing laws. If FSI does not collect Personal data, we may not be able to provide a product or service or enter into a supplier arrangement.
4.3 The product or service that we are providing or receiving will also determine what information we will collect. This information may include a name; address (including proof of name and address); photo identification; contact details both personal and work (for example, email and phone numbers); hobbies and interests; job title and company; nationality; citizenship; tax residency; date of birth; passport details; government issued identifying numbers (eg. tax numbers and national identity); adviser details; investment details; banking details; signed contracts ; business cards, contact sheets and biographies; financial dealings; family connections; details of company’s directors, secretaries, authorised signatories and identification documents; details of any complaints made; data required to conduct due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); responses to surveys and competitions; fraud enquiries (for example, information from police reports); images captured by CCTV cameras on our premises(in locations where there are cameras present); recordings of telephone conversations and electronic communications with our staff.
4.4 We may also collect Personal data using cookies on this site. The collection is managed in accordance with our Cookies Policy.
4.5 We may collect Personal data from third parties, depending on the nature of the business relationship, in particular the following:
Third party service providers to our funds (for example, transfer agents, registrars, administrators, distributors, custodians and paying agents) – information received includes personal details of investors obtained from fund application forms such as: name; address; contact details; nationality; government issued identity numbers (eg. national insurance number); date of birth; tax residency; adviser details; investment details; bank account details.
Advisers (including independent financial advisers) – information received may include an investor’s or client’s name; address; gender; date of birth; bank details.
Suppliers such as Experian and Refinitiv – information received includes the results of “Know Your Client”, anti-money laundering, politically exposed persons and sanctions checks.
Publically available sources such as MandateWire and LinkedIn – information available includes contact details of institutional investors (MandateWire) and details of job title, company, former employers and roles, and connections (LinkedIn).
4.6 In the context of FSI’s recruitment process for employees and contractors, we may collect (including through a recruitment agency), and hold, the following kinds of Personal data: applicant’s or employee’s name, contact details, date of birth, citizenship, employment references, background checks, regulatory accreditation, media (including social media), directorships, driver’s licence information, education, employment history and credential validation. Applicants for job vacancies in the United Kingdom and Europe will receive a separate Privacy Notice as part of the application process.
4.7 In the employment context, we may also collect and hold the Personal data listed above, as well as tax number, financial information, banking details, and other Personal data that may be collected in the use of FSI systems or assets. This information may be collected to assist us in monitoring compliance with our internal policies and perform other necessary functions and activities. All employees and contractors receive a separate Privacy Notice in relation to their employment.
5. How does FSI collect and store Personal data?
5.1 We collect from time to time, Personal data on investors, clients, suppliers, contractors, stakeholders, job applicants, employees and other business contacts from a number of sources, including from: investor application forms; other FSI forms (including website forms); client investment management agreements; various forms of correspondence; conversations; advisers; intermediaries; business cards; third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents); client advisers; other third parties; and from public sources. This information may be collected directly from investors, clients, intermediaries and business contacts, or indirectly from third parties.
Collecting information from visits to FSI’s website
5.2 We may collect information based on FSI’s website usage. FSI uses “cookies” and other data collection methods such as pixel tags to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our site. This information is collected to analyse and improve our website, our marketing campaigns and to record statistics on web traffic.
5.3 If account information is accessed online through one of the secure areas of FSI’s website, we will collect information about the visit using “cookies” to track the use of our website and to allow visitors to effectively access their account information. This information is collected for security purposes and to protect the integrity of visitor’s account details. For more information, please see our Cookies Policy.
6. How is Personal data protected?
6.1 Personal data held by us will be kept confidential.
6.2 We hold Personal data in secure computer storage facilities (whether in-house, at our service providers, or on cloud based systems), on paper-based files and in other formats. We take reasonable steps to protect information from loss and unauthorised access, destruction, use, modification or disclosure.
6.3 Access to Personal data held by FSI is controlled to prevent misuse or unauthorised disclosure of the information. We utilise a range of technical security measures such as secure authentication, password controls, encryption, firewalls and anti-virus technology to prevent unauthorised access to information. Physical access to our buildings is controlled by security pass.
6.4 How long we hold Personal data for will vary and will be determined by various criteria including:
the purpose for which we are using it – we will need to keep the Personal 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 Personal data.
7. How does FSI use Personal data
7.1 The information we use will depend on the nature of the business relationship, as follows:
In relation to prospective investors and clients, we may process Personal data for identification purposes (prior to becoming an investor in our funds or a client of ours under an investment management agreement), for the purposes of anti-money laundering, counter terrorist financing, suitability and appropriateness assessments, “Know Your Client” and credit-worthiness checks, and for any other applicable legal or regulatory reasons. Failure to provide relevant information will mean that we will not be able to on-board a potential investor or client.
In relation to investors in our funds, we may process information collected for the purpose of account administration and other general business purposes (for example, for processing subscriptions and investments; maintaining the share register of investors, carrying out investor instructions; handling any complaints and enquiries; sending investor communications, including financial reports, valuations, corporate actions). In addition, in order to comply with regulatory obligations, we may collect and disclose certain information about our investors and certain related persons and their investments to the local tax authority and and/or other relevant tax authorities overseas.
In relation to our investment management clients, we may process Personal data for the purpose of managing and administering clients’ accounts, including providing valuations and periodic reports and informing clients of relevant information as required by the investment management agreement.
We may from time to time process Personal data of investors and clients to comply with legal and regulatory requirements impacting our business. In particular, we may need in the context of our business: to obtain legal advice on legal and regulatory requirements; to report to relevant regulators; to comply with market opening and registration requirements in the conduct of our business; prevent or investigate any actual or suspected fraud; unlawful activity or misconduct; consider any concern or complain raised against FSI and/or to manage any legal action against FSI.
In relation to intermediaries who introduce investors into our funds (such as distributors, platforms and independent financial advisers), we may process Personal data to conduct market research, gauge product sales or product performance or assess the creditworthiness of intermediaries. In addition, we may process the Personal data of investors introduced to our funds, as outlined above.
In relation to our general business contacts (including consultants and intermediaries who act for our mutual clients), we may process Personal data for general business purposes such as: for public relations and corporate communications purposes; providing thought leadership articles; networking/relationship building; conducting market research and gathering industry statistics; evaluating products and services; when visiting our offices; and assisting with any queries.
We may process Personal data to analyse the performance of IT systems, monitor usage of resources and systems and to improve products, services and usability of our technology platform, including telephone calls and electronic communications with our staff which may be recorded for the purposes of retaining a record of communications; in the interests of security; for training and compliance monitoring purposes and/or to comply with legal or regulatory obligations.
In relation to job applicants, to consider an application for employment.
In relation to employees and contractors, we may process Personal data for the purpose of complying with tax, employment/labour and workplace health and safety regulations (including management of working hours, sick leave and the health and safety of personnel, talent management including promotions and position assignments/reassignments and the administration and payment of wages and benefits). Personal data of employees may also be used for the purposes of managing or ending the employment or other contractual relationship and disputes with employees, including defending claims brought by employees. We may also use information for other purposes required or authorised by or under law (including purposes for which consent has been provided).
7.2 We are entitled to use 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 Personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates);
The use of Personal data is necessary for the performance of a contract;
Consent to us processing Personal data has been provided (other than for marketing purposes);
Consent has been provided for us to process Personal data for the purposes of informing (for example, by telephone, mail or email) individuals about other products and services available from the other companies within FSI and about marketing campaigns and event invitations.
8. How is Personal data disclosed to others
8.1 We may disclose Personal data to other companies within FSI, for internal business and administrative purposes (including to administer our products and services and for prudential and risk management purposes) and, where consent has been given, to provide individuals with information on related products and services.
8.2 We may also disclose Personal data relating to our clients to other companies within FSI to whom we sub-delegate our services (for example, trade order execution and portfolio management). When we disclose Personal data to other companies within FSI, we will take appropriate measures to ensure that such Personal data is shared and treated securely and in accordance with this Policy.
8.3 FSI related companies and third parties are located in jurisdictions including, but not limited to, Australia, Canada, Cayman Islands, France, Germany, Hong Kong, India, Ireland, Japan, Luxembourg, New Zealand, Singapore, United Kingdom, and the United States.
8.4 We may disclose Personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us.
8.5 The following is a list of the types of third parties who process Personal data on our behalf:
third party service providers to our funds (for example, transfer agents, administrators, distributors, platform providers, custodians, paying agents and researchers). These third party service providers may also disclose and transfer your Personal data to their subsidiaries or affiliates or other third party contractors;
credit reference agencies, debt collection agencies and other companies for use in credit decisions, for fraud prevention, to pursue debtors and for the verification of identity;
document execution vendors in relation to the execution of contracts with our clients;
mailing houses or printing companies;
recruitment agencies and payroll administrators;
information technology providers; and
8.6 Where a financial adviser (as indicated on the investor application forms) or other professional adviser is used, then details of an individual’s investments and valuations may also be provided to their adviser and their respective service providers.
8.7 We may disclose to relevant tax authorities, regulators, government departments, competent authorities of the UK or of other countries, or other government or law enforcement agencies (without limitation) any Personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) in order to comply with a court order or to meet legal and regulatory requirements arising in the conduct of our business. Such disclosure may be made directly to such regulators or competent authorities etc. or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.
8.8 With your consent, we may also disclose Personal data to other third parties and for other purposes. That consent may be written, verbal or implied from conduct.
For those located in the United Kingdom or Europe,
8.9 In relation to data transfers outside of the European Economic Area (“EEA”) or UK, we may transfer Personal data of individuals located in the UK or Europe to our affiliates (including outside the EEA or UK) and/or allow the information to be accessed by our affiliates and their employees outside the EEA or UK as well as within it. It may also be processed by personnel operating outside the EEA or UK who work for us or for one of our third party service providers.
8.10 Where we transfer such Personal data outside the EEA or UK, we will ensure that it is protected in a manner that is consistent with how Personal data is protected by us in the EEA or UK or that the transfer is otherwise compliant with data protection laws. This can be done in a number of ways, for example:
the country that we send the data to might be approved by the European Commission or the UK Information Commissioner’s Office (“UK ICO”);
the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission or UK ICO, obliging them to protect your Personal data; or
where data protection laws permit us to transfer Personal data outside the EEA or UK
8.11 Individuals can obtain more details of the protection given to Personal data when it is transferred outside the EEA or UK (including a sample copy of the model contractual clauses) by contacting infoUK@firstsentier.com.
9. An individual’s rights in relation to their data
9.1 Individuals have a right to access the Personal data that we hold about them and if they wish to make an application to access or obtain this Personal data, they can contact us using the details in section 12 below. In some circumstances, individuals have the right to receive some Personal data in a structured, commonly used and machine-readable format and/or request that we transmit that Personal data to a third party where this is technically feasible. Please note that this right only applies to Personal data which individuals have provided to us.
9.2 Generally we do not charge a fee to request access to Personal data. However, if we do propose to charge a fee we will advise beforehand, so that the applicant can decide whether to proceed. Any fee charged would be to cover the cost of obtaining the information. For example, searching, retrieving and despatching the information.
9.3 We must verify the applicant’s identity before giving access to, or correcting the Personal data.
9.4 We take reasonable steps to ensure that the Personal data we collect, use or disclose is accurate, complete and up to date. Individuals are encouraged to contact us if any of the details they have provided change or if they believe that the Personal data we have about them is not accurate, complete or up to date.
9.5 In certain circumstances, FSI may not be able to correct or provide applicants with access to their Personal data. In these circumstances, we will write to the applicant to explain and provide the reasons why.
9.6 If an individual wishes us to erase or restrict using their Personal data, they are encouraged to contact us. We may need to discuss the basis of the request with the applicant as there may be circumstances where we are legally entitled to continue processing the Personal data or refuse the request.
9.7 If individuals have previously provided their consent to our use of their Personal data (other than for marketing purposes) and they wish to withdraw such consent, they are encouraged to contact us. We may need to discuss with the individual whether our use of their Personal data needs to continue for lawful purposes (i.e. because we have another legitimate reason for doing so).
9.8 If an individual has previously consented to being sent information about other products and services available from the First Sentier Investors group of companies, they may withdraw such consent by contacting us.
10. Expressing concerns or complaints about the management of Personal data
10.1 If an individual has a complaint related to how FSI has managed their Personal data, they are encouraged to contact us using the contact information in section 12 below. We may ask the complainant to place their concerns in writing in order for us to fully understand and investigate the issues they have raised.
10.2 We will acknowledge any complaint within five business days of it being received and make every effort to resolve the issue within a reasonable time of us being notified.
10.3 If an individual suspects misconduct, they are encouraged to Speak Up. Please refer to the Global Whistleblower Policy for more information on reporting misconduct.
10.4 Please refer to Appendix B for details of the external parties to contact for complaints that remain unresolved.
11. Notifiable data breaches
11.1 We have put in place procedures to deal with any suspected Personal data breach and will notify potentially impacted individuals and any applicable regulator of a breach where we are legally required to do so.
12. How to contact us
12.1 For any other Personal data related queries, access or Personal data correction requests, individuals may contact their FSI relationship manager or should they not have a relationship manager contact the Data Protection or Privacy Officer, as relevant, at the following:
Contact details in your location
First Sentier Investors
Level 5, International Tower 3
300 Barangaroo Avenue,
Barangaroo NSW 2000
Data Protection Officer
First Sentier Investors (Japan) Limited
6F, Cross Office Uchisaiwaicho
1-18-6 Nishishinbashi Minato-ku Tokyo
United Kingdom & EEA
Data Protection Officer
First Sentier Investors
7th Floor, Finsbury Circus House
15 Finsbury Circus
London EC2M 7EB
Data Protection Officer
First Sentier Investors (Hong Kong) Limited
Level 25, One Exchange Square
8 Connaught Place
Central, Hong Kong
Data Protection Officer
First Sentier Investors (Singapore)
79 Robinson Road
Chief Compliance Officer
First Sentier Investors
10 E. 53rd St.
21st Fl NY
Appendix A – Relevant companies and investment funds in Europe and the United Kingdom Companies
First Sentier Investors (UK) Funds Limited*
First Sentier Investors (UK) IM Limited*
First Sentier Investors (UK) Services Limited
First Sentier Investors Europe Holdings Limited
First Sentier Investors International IM Limited*
First Sentier Investors (Ireland) Limited**
*Authorised and regulated by the Financial Conduct Authority of the United Kingdom
**Authorised by the Central Bank of Ireland
European Diversified Infrastructure Fund FCP-SIF
European Diversified Infrastructure German Feeder Fund SCA, SICAV-SIF
European Diversified Infrastructure Feeder Fund II SCA, SICAV-SIF
European Diversified Infrastructure Fund II SCSp
EDIF II Feeder Fund SCA RAIF
EDIF II FF II SCA RAIF
European Diversified Infrastructure Fund III SCSp
EDIF III Feeder Fund SCA SICAV-RAIF
Appendix B – External contact details for complaints
If the individual’s complaint remains unresolved, they may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (“OAIC”) to have the complaint heard and determined. The OAIC may be contacted on the privacy hotline: 1300 363 992.
When we write to the individual about our decision, we will explain how to access an external dispute resolution scheme or make a complaint to the OAIC.
An individual can lodge a complaint with the Office of the Privacy Commissioner for Personal data. For more information and instructions visit: https://www.pcpd.org.hk
Please send the individual’s complaint to:
Address: Room 1303, 13/F, Dah Sing Financial Centre, 248 Queen's Road East, Wanchai, Hong Kong;
Fax: 852 2877 7026; or
Email to email@example.com
If an individual has a complaint in relation to the way we have used the individual’s information, they should contact us in the first instance. Contact can also be made with a local consumer center or the Personal Information Protection Commission (“PPC”). Contact details for the PPC are:
Address: Kasumigaseki Common Gate West Tower 32nd Floor, 3-2-1, Kasumigaseki, Chiyoda-ku, Tokyo, 100-0013, Japan
Inquiry Line for Act on Protection of Personal Information: 03 6457 9849 (in Japanese only)
The PPC mediates the complaints with regard to the handling personal information.
The Personal data Protection Commission (“PDPC”) encourages individuals who have concerns about the ways in which an organisation has handled their Personal data to first approach the organisation to clarify the reasons for the organisation's actions and seek an amicable resolution of the matter. Nonetheless, should the individual want to report the complaint to the PDPC, they can contact https://www.pdpc.gov.sg/Complaints-and-Reviews.
If an individual has a complaint in relation to the way we have used the individual’s information, they should contact us in the first instance. They also have the right to lodge a complaint with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel: 0303 123 1113).
If an individual has a complaint in relation to the way we have used the individual’s information, they should contact us in the first instance. They also have the right to lodge a complaint with the Irish Data Protection Commission at 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (Tel: +353 578 684 800) if they think that any of the individual’s rights have been infringed by us.
- What is Personal Data?
- What Personal data does FSI collect?
- How does FSI collect and store Personal data?
- How is Personal data protected?
- How does FSI use Personal data
- How is Personal data disclosed to others
- An individual’s rights in relation to their data
- Expressing concerns or complaints about the management of Personal data
- Notifiable data breaches
- How to contact us
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By choosing to view or make use of this website and the materials on it you do so on the basis that you have informed yourself of any regulatory or other consequences of your doing so.
In Hong Kong, this website is communicated by First Sentier Investors (Hong Kong) Limited and has not been reviewed by the Securities & Futures Commission in Hong Kong. First Sentier Investors and Igneo Infrastructure Partners are business names of First Sentier Investors (Hong Kong) Limited.
In Singapore, this website is communicated by First Sentier Investors (Singapore) whose company registration number is 196900420D. Advertisements or publications on this website have not been reviewed by the Monetary Authority of Singapore. First Sentier Investors (registration number 53236800B) and Igneo Infrastructure Partners (registration number ) are business divisions of First Sentier Investors (Singapore).
In Japan, this website is communicated by First Sentier Investors (Japan) Limited.
In Hong Kong, “Professional Investor” is defined under the Securities and Futures Ordinance, Chapter 571 of the laws of Hong Kong as may be amended from time to time.
In Singapore, “Institutional Investor” is defined under the Securities and Futures Act, Chapter 289 of the laws of Singapore as may be amended from time to time.
In Japan, “Institutional Investor” shall refer to “Qualified Institutional Investor (tekikaku kikan toshika)” defined under Item 1, Paragraph 3, Article 2 of the FIEA and Paragraph 1, Article 10 of Cabinet Office Ordinance regarding Definitions Provided in Article 2 of the FIEA.
First Sentier Investors (Hong Kong) Limited, First Sentier Investors (Singapore) and First Sentier Investors (Japan) Limited are a part of the investment management business of First Sentier Investors, which ultimately is owned by Mitsubishi UFJ Financial Group, Inc. (“MUFG”), a global financial group. First Sentier Investors includes a number of entities in different jurisdictions.
MUFG and its subsidiaries are not responsible for any statement or information contained in this website. Neither MUFG nor any of its subsidiaries guarantee the performance of any investment or entity referred to in this website or the repayment of capital. Any investments referred to are not deposits or other liabilities of MUFG or its subsidiaries, and are subject to investment risk, including loss of income and capital invested.
Links to other web sites
Our web site may contain links to non- First Sentier Investors web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
First Sentier Investors (FSI) is committed to maintaining high standards of corporate governance, ethics and behaviour in all of its activities, as part of which FSI requires that its employees display the highest levels of professionalism in all aspects of their work to facilitate compliance with its code of conduct and all applicable laws.
FSI is also committed to providing a culture where all staff are encouraged to raise concerns about unacceptable practice and misconduct. This extends to others with a connection to FSI such as directors, contractors, consultants, suppliers and service providers or a relative or dependent of these individuals or their spouse.
Individuals as noted above with information in relation to serious wrongdoing (including unethical, illegal, corrupt or other inappropriate conduct) are encouraged to contact the FSI Whistleblowing Protection Officer via:
• The First Sentier Investors
The global direct access telephone hotline on +1-844-319-1607, or a local toll free number in the following locations:
• Australia: 1-800-515-184
• Hong Kong: 800-93-3975
• United Kingdom: 0808-234-5817
• Singapore: (StarHub) 800-001-0001 OR (SingTel) 800-011-1111 then 844-319-1607
In Hong Kong, this website is issued by First Sentier Investors (Hong Kong) Limited and has not been reviewed by the Securities & Futures Commission in Hong Kong.
In Singapore, this website is issued by First Sentier Investors (Singapore) (Co. Reg No. 196900420D). This website has not been reviewed by the Monetary Authority of Singapore.
In Japan, this website is issued by First Sentier Investors (Japan) Limited, authorised and regulated by the Financial Service Agency (Director of Kanto Local Finance Bureau (Registered Financial Institutions) No.2611).
Please click the "I agree" button below if you have read and understood this page and confirm that you are an Institutional Investor (as defined in the relevant jurisdiction) and agree to abide by its contents, otherwise click "Cancel" to leave the website.
Terms and Conditions
Before you access the Igneo Infrastructure Partners website, we would like you to read and understand the website’s terms and conditions, the personal data we collect and how we use it. This information is set out in the terms and conditions below:
1. Terms and Conditions
2. Privacy Notice
Terms and Conditions
It is important that you read this page. The use of www.igneoip.com (this “Website”) is subject to the following terms and conditions (the “Terms”). If you do not agree to these Terms, please refrain from using this Website.
IMPORTANT INFORMATION ABOUT ACCESS TO THIS WEBSITE
In the UK and Switzerland this Website is operated and communicated by First Sentier Investors International IM Limited, registered office 23 St Andrew Square, Edinburgh, Scotland, EH2 1BB, which is authorised and regulated by the Financial Conduct Authority of the United Kingdom (FCA reference number 122512). Igneo Infrastructure Partners is a UK trading name of First Sentier Investors International IM Limited. In the EEA this website is operated and communicated by First Sentier Investors (Ireland) Limited, registered office 70 Sir John Rogerson’s Quay, Dublin 2, Ireland, (CBI registration number C182306). The information on this Website constitutes a financial promotion and an invitation or inducement to engage in investment activity and/or a marketing communication.
This Website (and the information on it) is not directed at or made available to Retail Clients and is directed only at persons who are Professional Clients or Eligible Counterparties for the purposes of UK law, the Markets in Financial Instruments Directive (“MiFID”) or as otherwise defined under applicable local regulations, and at persons whom this Website (and any information on it) may lawfully be directed in any relevant jurisdiction. Access to this Website is not open to persons resident in, or citizens of any territory where, to allow such access would require any registration, filing, application for any licence or approval or other steps to be taken by Igneo Infrastructure Partners in order to comply with local laws or other regulatory requirements in such overseas territory. The information on this Website should not be treated as an offer, invitation or inducement to distribute or purchase interests in funds or enter into an investment agreement to any person in any jurisdiction unless in the relevant jurisdiction such an offer, invitation or inducement could lawfully be made to them.
Telephone calls with Igneo Infrastructure Partners may be recorded.
The First Sentier Investors entities referred to on this Website are part of First Sentier Investors, a member of Mitsubishi UFJ Financial Group, Inc (MUFG), a global financial group. First Sentier Investors includes a number of entities in different jurisdictions. MUFG and its subsidiaries do not guarantee the performance of any investment or entity referred to on this Website or the repayment of capital. Any investments referred to are not deposits or other liabilities of MUFG or its subsidiaries, and are subject to investment risk including loss of income and capital invested.
Selling Restrictions: The distribution of the information on this Website may be restricted by law in certain countries. This Website, and the information on it, are not addressed to any person resident in the territory of any country or jurisdiction where such distribution would be contrary to local law or regulation. By choosing to view or make use of this Website you do so on the basis that you have informed yourself of any regulatory or other consequences of your doing so.
Igneo Infrastructure Partners and its affiliates disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation in the country of which you are a citizen or in which you are residing or domiciled. If your country of residence or domicile changes, you must access this Website selecting your new country of residence.
No Advice: The information on this Website is provided for information only and does not constitute, and should not be construed as, investment advice or a recommendation to buy, sell or otherwise transact in any investment. The information on this Website is provided solely on the basis that you will make your own investment decisions and Igneo Infrastructure Partners has not taken any account of your particular investment objectives or financial situation in preparing the information on this Website. In addition, nothing in this Website shall, or is intended to, constitute financial, legal, accounting or tax advice. We strongly recommend that you seek professional investment advice before making any investment decision. The value of investments and the income from them can go down as well as up and investors may not get back the amount originally invested and may lose all of their investment.
Information on this Website: Igneo Infrastructure Partners has taken reasonable care to ensure that the information contained on this Website is accurate, current, complete, fit for its intended purpose and compliant with relevant legislation and regulations. However, errors or omissions may occur due to circumstances beyond Igneo Infrastructure Partners’ control and no warranty is given, or representation made, regarding the accuracy, validity or completeness of the information on this Website and no liability is accepted by such persons for the accuracy or completeness of such information. You must conduct your own due diligence and investigations rather than relying on any of the information in this Website. Any person who acts upon, or changes his or her investment position in reliance on, the information contained on this Website does so entirely at his or her own risk.
Information posted on this Website is current only as at the date it is first posted and may no longer be true or complete when viewed by you. Igneo Infrastructure Partners cannot guarantee that content will be accurate, complete and current at all times. To the extent that any information on this Website relates to a third party, such information has been provided by that third party and is the sole responsibility of such third party and Igneo Infrastructure Partners accepts no liability for such information. All content on the Website is subject to modification from time to time without notice. Please contact Igneo Infrastructure Partners for further information regarding the validity of any information contained on this Website.
To the extent that this Website contains any expression of opinion or forecast, such opinion or forecast is based on sources believed by Igneo Infrastructure Partners to be reliable, but is not guaranteed or warranted as to its current validity, accuracy or completeness. Opinions expressed represent the opinions of Igneo Infrastructure Partners at the date of publication only, reflecting prevailing market conditions and certain assumptions (which may not prove to be valid), are subject to change and should not be relied on by users of the Website.
Certain content (the “Restricted Content”) on this Website including, but not limited to, webcasts shall be made available only on the granting of permission by Igneo Infrastructure Partners or a third party appointed by Igneo Infrastructure Partners. Igneo Infrastructure Partners reserves the right, in its absolute discretion, not to grant access to such Restricted Content. Where you are granted access to such Restricted Content, such access is granted for your personal use only. You must treat this Restricted Content as confidential and you must not disclose it to any third party or allow any third party to access such Restricted Content. Igneo Infrastructure Partners may revoke access to the Restricted Content in its absolute discretion at any time without notice.
Linked Websites: Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them. Igneo Infrastructure Partners accepts no responsibility for information contained on any other sites which can be accessed by hypertext link from this Website or for these sites not being available at all times. Igneo Infrastructure Partners has not reviewed, and will not review or update, such websites or information and any use that you make of such websites and information is at your own risk. Please note that when you click on any external site hypertext link you will leave this Website.
Liability: No warranty is given that the contents of this Website are compatible with all computer systems or browsers or that this Website shall be available on an uninterrupted basis. Igneo Infrastructure Partners does not accept any liability for any damages or losses arising from changes or alterations made to this Website by unauthorised third parties.
The internet is not a completely reliable transmission medium and neither Igneo Infrastructure Partners nor any of its affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from Igneo Infrastructure Partners or any of its affiliates. Any such transmission of information is entirely at your own risk and any material downloaded from this Website is downloaded at your own risk.
The information on this Website is provided “as is”. To the extent permitted by law, Igneo Infrastructure Partners, its affiliates and its and their directors, officers, employees and agents expressly exclude all conditions, warranties, representations and other terms which might otherwise be implied by statute, common law or the law of equity. Igneo Infrastructure Partners and its affiliates will only be liable to you in respect of any direct losses arising from your use of, or inability to use, this Website in the event of Igneo Infrastructure Partners’ gross negligence, wilful default or fraud. In no event will Igneo Infrastructure Partners or any of its affiliates be liable to any person for any indirect, special or consequential damages arising out of any use of, or inability to use, this Website or the information contained on it or on any other hyper-linked site including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment or otherwise, even if Igneo Infrastructure Partners is expressly advised of the possibility or likelihood of such damages. This does not affect Igneo Infrastructure Partners’ liability for any loss or damage which cannot be excluded or limited under applicable law.
Nothing in these Terms is intended to exclude or restrict any duty or liability that Igneo Infrastructure Partners has to its clients under the "regulatory system" in the United Kingdom (as such term is defined in the Financial Conduct Authority Rules), under applicable local regulatory rules or which may not be excluded or restricted as a matter of applicable law.
Access: Igneo Infrastructure Partners reserves the right to suspend or withdraw access to any page(s) included on this Website without notice at any time and accepts no liability if, for any reason, these pages are unavailable at any time or for any period.
Compliance with Law and Regulation: When using this Website you must comply with all applicable local, national and international laws including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on this Website in certain countries and Igneo Infrastructure Partners, its affiliates and its and their directors, officers, employees and agents disclaim all responsibility if you download any information from this Website in breach of any law or regulation of the country in which you reside.
(a) Unless otherwise specified, Igneo Infrastructure Partners is the owner or the licensee of all intellectual property rights in and to this Website, its content and the information, imagery and data published on it including but not limited to copyright and trade mark rights (whether registered or unregistered). Those works are protected by copyright laws and treaties around the world. All such rights, save as expressly granted, are reserved.
(b) Notwithstanding paragraph (a) above, no warranty or indemnity is given that the use of the Website, or any information or material taken or downloaded from the Website will not infringe the intellectual property rights of any third party.
(c) Reproduction in any form of any part of the content, information, imagery or data from, or underlying, this Website, save for in strict compliance with these Terms, is prohibited without the prior written consent of Igneo Infrastructure Partners. All such intellectual property rights shall continue to be held by Igneo Infrastructure Partners or its licensors and no rights of any kind in such rights shall pass to you.
(d) The information held on this Website is for your own personal use only. You may print off or download copies of, or extracts from, pages from this Website for your personal reference but you must not modify those copies or extracts in any way. Igneo Infrastructure Partners (and any identified contributors), as the authors of material on this Website, must always be acknowledged.
(e) Any unauthorised downloading, re-transmission or other copying or modification of any of the contents of the Website may be in breach of statutory or common law rights which could be the subject of legal action. Igneo Infrastructure Partners disclaims all liability which may result from any unauthorised reproduction or use of the information on the Website.
(f) All trade marks, service marks, company names or logos are the property of their respective holders. The display of any trade names or trade marks on the Website does not imply that any licence has been granted to any third party in respect of the same. Any use by you of these marks, names and/or logos may constitute an infringement of the holders’ rights.
The Internet: Please note that there is no guarantee that any e-mail sent by you will be received by us, or that the contents of any such e-mail will remain private during internet transmission. Any information is sent at your own personal risk.
Data Protection: Please see our Privacy Notice for information relating to how Igneo Infrastructure Partners and other companies associated with it protect your personal data. In agreeing to these Terms you agree to the terms of our Privacy Notice.
Amendment: Igneo Infrastructure Partners may delete or make changes to these Terms and to the information contained on this Website at any time. Where we make any changes to these Terms, you will be required to accept such changes in order to continue to use the Website. If you do not accept such revised Terms, you may no longer be able to access this Website.
If any provision of these Terms is found by any court or authority of competent jurisdiction to be illegal, void or invalid under the laws of any jurisdiction, the legality, validity or enforceability of the remainder of these Terms in that jurisdiction shall not be affected and the legality, validity and enforceability of the whole of these Terms in any other jurisdiction shall not be affected.
Third Parties: Igneo Infrastructure Partners’ affiliates shall have the benefit of the rights conferred on them by these Terms but otherwise no person who is not a party to these Terms may enforce its terms under the Contracts (Rights of Third Parties) Act 1999.
Applicable Law: These Terms and any non-contractual obligations arising from or connected with them shall be governed by, and these Terms shall be construed in accordance with, the laws of England and Wales.
Jurisdiction: You agree that the English courts shall have exclusive jurisdiction in relation to any legal action or proceedings arising out of or in connection with these Terms (whether arising out of or in connection with contractual or non-contractual obligations) (“Proceedings”) and waive any objection to Proceedings in such courts on the grounds of venue or on the grounds that Proceedings have been brought in an inappropriate forum. You further agree that this paragraph operates for the benefit of Igneo Infrastructure Partners and accordingly Igneo Infrastructure Partners shall be entitled to take Proceedings in any other court or courts having jurisdiction.
Contact Us: If you have any enquiries in relation to this Website or the information on it, please contact Igneo Infrastructure Partners at IR@igneoip.com
Important information about access to this website
GENERAL TERMS AND CONDITIONS OF THIS WEBSITE
All users of services accessible through this site acknowledge and agree to the terms and conditions set out below. If you do not accept the terms and conditions, you are not authorised to use this site.
Information on this site is provided by First Sentier Investors (US) LLC (“First Sentier Investors”), which is a member of MUFG, a global financial group (the “Group”). First Sentier Investors provides its services to or through wholly owned subsidiaries of the Group. Information provided on, and available from, this site does not constitute financial, insurance, legal, accounting or taxation advice, and shall not be relied upon by you in that regard. The information does not purport to be comprehensive, nor does it take into account the objectives and circumstances of the individual investor. You are responsible for ensuring that you are properly informed about any securities, taxation or other legislation or law that could affect your investment decision. You should obtain advice specific to your investment objectives, financial situation and particular needs before making any investment decision. This site shall not be used, or relied upon by you, as a substitute for your independent research or professional advice that may be provided to you in consultation with a First Sentier Investors representative and/or your other advisers.
You acknowledge and agree that past performance is not an indicator of future returns and that references to performance on this site are provided as historical benchmarks only.
First Sentier Investors’ products and services are available only in jurisdictions where they may be lawfully offered for sale or provided, and not all of First Sentier Investor’s products and services are available in all geographic regions. As such, certain products and services may not be available in your jurisdiction. You are responsible for complying with all relevant local, national and other laws. All First Sentier Investors’ products and services shall be subject to the terms and conditions of any applicable agreements. You agree that your use of this site shall be on an “as is” basis entirely at your risk. None of the Group, nor its affiliated companies, nor any officer, director, or employee thereof, nor any person associated with the creation of this site or its contents, shall be liable or responsible to any person for any harm, loss or damage that may arise in connection with your use of this site or the information contained thereon, including without limitation any direct, indirect, special, third party or consequential damages. Without limiting the foregoing, none of the Group, nor any of its affiliated companies shall be responsible for any detrimental reliance that you may place upon this site or its contents whatsoever.
Unless otherwise specifically stated, the material on this site is for information purposes only and nothing on this site:
- constitutes an offer of any financial product or an offer generally;
- constitutes an invitation to subscribe for a financial product, or
- amounts to a solicitation for any business in Australia, the United States or in any other place.
ACCURACY OF INFORMATION AND LIMITATION OF LIABILITY
The information contained on this site is subject to modification and update from time to time without notice. None of the Group, nor any of its affiliated companies warrants as to the accuracy, completeness or currency of information that is made available on or through this site.
None of the Group, nor any of its affiliated companies will be liable for or in connection with any harm, loss or damage that may arise in connection with your use of this site or the information contained thereon, including without limitation any direct, indirect, special, third party or consequential damages, arising from any inaccuracies, errors or omissions in information made available through this site (whether arising in contract, from negligence or otherwise). However, First Sentier Investors will endeavour to update the information on this site as soon as practicable when it becomes aware that material changes have occurred.
THE INVESTMENT RISK
Investments in the products described on this site are not investments, protected accounts, deposits or liabilities of the Group or any of its affiliated companies for the purpose of the Banking Act of 1959 of Australia and are subject to investment and other risks. Furthermore, investments in the products described on this site are not insured or guaranteed by the United States Federal Deposit Insurance Corporation or any other governmental agency of the United States, Australia or any other jurisdiction. Neither the Group nor any of its affiliated companies guarantee the repayment of capital or the performance of any of the funds or any particular rate of return from the fund, or any taxation consequences of, any investment in a fund which is made under the information available from this site.
First Sentier Investors and related logos are trademarks registered in United States. Copyright in the information provided on, and available from this site is owned by First Sentier Investors and its affiliates. You may not alter or modify this information in any way. This information may be viewed on-line and may be reproduced in hard copy only for your personal reference. You may only use the trademarks and copyright material at this site with First Sentier Investor’s express permission and in accordance with First Sentier Investor’s directions from time to time. The use of, and creation of links to, this site are at the risk of the user and are subject to First Sentier Investor’s rights and the user's general legal obligations. First Sentier Investor’s Limited makes no warranty and accepts no liability in relation to use of the trademarks outside Australia. For further information about creating links to this site and about using the First Sentier Investor’ material, see our guidelines below or contact our office on +1 212 497 9980 or firstname.lastname@example.org.
If you wish to create a link from your site to this site, in addition to the general terms and conditions you have read and agreed to above, you acknowledge and agree to the following.
If First Sentier Investor’s allows you to use its copyright material you may use it only in accordance with its directions from time to time, using only material supplied or approved by it, without any alteration and incorporating notices indicating First Sentier Investor’s ownership of copyright material.
First Sentier Investor’s may take legal action in respect of any use of the its name or copyright material, without the its permission, other than in accordance with the its directions or in breach of the Group 's rights or your general legal obligations.
Reference on this site to products or services of third parties does not mean that First Sentier Investors endorses or approves such products or services, and is provided only for convenience. First Sentier Investors neither endorses nor approves links to other web sites or third parties and their products or services, and is not responsible for any incompatibility, inconvenience, or contamination by computer viruses or worms, Trojan horses or any other destructive agent originating from these sites. Linking to other sites is at your own risk, and First Sentier Investors will not be held liable for any damage caused by such links.
Internet e-mails and other electronic communications
The confidentiality and security of transmission of e-mails and other electronic communications via the Internet are not guaranteed. E-mail and other electronic communications are not confidential and may be intercepted, lost, or even modified. First Sentier Investors is not responsible for any harm or damage that you or any other person may incur by transmitting via the Internet to First Sentier Investments e-mails or other electronic communications containing personal or confidential information, or by receiving from First Sentier Investors e-mails sent to you at your request. Please click the "I have read and agree to the above information" button below if you have read and understood this page and agree to abide by its contents, otherwise click "Cancel" to leave the website.
First Sentier Investment (US) LLC, as a member of the Mitsubishi UFJ Financial Group (MUFG), a global financial group. MUFG Group respects your concerns about privacy. This Privacy Notice describes the types of personal information we obtain about users in connection with First Sentier Investments (US) LLC products and services that link to this Privacy Notice, how we may use the information, with whom we may share it, and the choices available to users regarding our use of the information. The Privacy Notice also describes the measures we take to safeguard the personal information and how individuals can contact us about our privacy practices. This Privacy Notice does not apply to other MUFG Group products and services that post separate privacy notices.
1. How is your personal data dealt with?
In the course of doing business we outsource certain tasks to third party administrators or agents. These third parties are bound by confidentiality arrangements when handling your personal data. Your personal data may also be used by us to:
establish your identity and assess applications for products and services
price and design our products and services
administer our products and services
manage our relationship with you
manage our risks and help identify and investigate illegal activity, such as fraud
contact you, for example if we suspect fraud on your account or need to tell you something important
conduct and improve our businesses and improve the customer experience
comply with our legal obligations and assist government and law enforcement agencies or regulators
identify and tell you about other products or services that we think may be of interest to you.
We may also collect, use, and exchange your information in other ways where permitted by law.
If you used a financial advisor in relation to your investment then details of your investments may also be provided to such financial advisor (or any replacement or additional advisor which you inform us of).
We aim to ensure that the personal information we retain about you is accurate, complete, and up to date. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking.
2. What personal data do we collect?
First Sentier Investors (US) LLC collects personal data on investors, clients, intermediaries and business contacts via application forms, other First Sentier Investors (US) LLC forms, investment management agreements, correspondence, business cards, phone, fax, e-mail, and on-line. Personal data collected may include:
your mailing address
your phone numbers
your e-mail address
your personal and financial information (e.g., income, net worth, marital status, etc.)
your social security or tax identification number
3. How we protect personal information
We maintain administrative, technical, and physical safeguards designed to protect personal information we obtain in connection with the Services against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyze and improve our website. These cookies are ‘session’ cookies.
The browsers of most computers, smartphones, and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different; check the "Help" menu of your browser to learn about how to change your cookie preferences.
Please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work. More information about cookies can be found on allaboutcookies.org.
5. Links to other web sites
Our web site may contain links to non-First Sentier Investors (US) LLC web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
6. Telephone services
We may monitor and record telephone calls for training and security purposes.
7. Data transfers
We may transfer the personal information we obtain about you to countries other than the country in which the personal information originally was collected, including the United States. Those countries may not have the same data protection laws as the country in which the information initially was provided. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.
8. Retention of personal information
To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Notice or (2) we have another lawful basis for retaining that data beyond the period for which it is necessary to serve the original purpose for collecting the data.
9. Updating your information
It’s important that we have your correct details, such as your current address and telephone number. You can check or update your information by contacting your relationship manager. If the information we hold is inaccurate, incomplete or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will, unless prevented by law or regulation, let you know why.
If you have any questions or would like further information on our privacy and information handling practices, please contact us.
10. Children’s personal information
We do not knowingly collect or solicit personal information from children under the age of 13. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Privacy Notice.
11. Updates to our Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post or provide a notice to notify you of significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated.
12. How to contact us
If you have any questions about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by e-mail at email@example.com, or by phone at (212) 497-9980.
You also may write to us at:
First Sentier Investors (US)
10 East 53rd Street, Floor 21
New York, NY 10022
United States of America