WEBSITE DISCLAIMERS
The information contained in this website is for general information purposes only. The information is provided by Hundle & Partners Limited ("Hundle") and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.

Through this website you are able to link to other websites which are not under the control of Hundle. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.
Every effort is made to keep the website up and running smoothly. However, Hundle takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.

Hundle is a trading name of Hundle & Partners Limited who is authorised and regulated by the Financial Conduct Authority.

ANTI-SLAVERY POLICY STATEMENT
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Hundle has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. Hundle has has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Hundle has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to our Compliance Officer.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

UK STEWARDSHIP CODE DISCLOSURE STATEMENT
Rule 2.2.3 of the Conduct of Business Sourcebook of the Financial Conduct Authority (“FCA”) Handbook requires Hundle Ltd to make a public disclosure in relation to the nature of our commitment to the UK Stewardship Code (“the Code”) published by the Financial Reporting Council (“FRC”).

The Code aims to enhance the quality of engagement between institutional investors and UK companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with UK investee companies and is to be applied by firms on a “comply or explain” basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

- Publicly disclose their policy on how they will discharge their stewardship responsibilities;
- Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
- Monitor their investee companies;
- Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
- Be willing to act collectively with other investors where appropriate;
- Have a clear policy on voting and disclosure of voting activity; and
- Report periodically on their stewardship and voting activities.

PRIVACY POLICY
Hundle is committed to the security, confidentiality and protection of personal data. This policy explains how we use personal data and should be read in conjunction with any other documentation provided directly to you.

PERSONAL DATA
According to the Information Commissioner’s Office (ico.org.uk) the GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier. The data we collect is detailed below.

DATA CONTROLLER
A controller determines the purposes and means of processing personal data. For the purposes of this policy, Hundle is a data controller in respect of any personal information we hold about you.

HOW WE OBTAIN YOUR PERSONAL DATA
We collect personal data through services that we provide and receive. Typically, it comes from the following sources:

- Contractual agreements or other material provided during our relationship.
- Correspondence received from you such as email, telephone conversations, facsimiles, letters, face to face discussions, text messages, contact through our website and other forms of communication. We may keep a record of all correspondence received. We are required to record telephone and electronic communications that contain order execution instructions.
- Depending on our business relationship, we may use third party firms for credit reference and money laundering checks.

PERSONAL DATA WE COLLECT
If you are a customer, we collect information to assist in the provision of services to you. This information may include:

- Your full name including title, maiden name, marital status, date of birth and gender.
- Contact details such as residential address, email and telephone numbers.
- Financial information, including your bank account and details of investments held with us and elsewhere. We may also record details of financial transactions placed across your accounts, whether held with us or elsewhere.
- Identifiers such as your national insurance number or equivalent in overseas jurisdictions, tax reference, driving licence number, passport number, internet protocol address and our own internal identifiers.
- Data used to access our client portal such as username, password, online preferences, and usage information.
- Information required to conduct ‘know your client’ checks such as details relating to your passport or other photographic identification, your credit history, current and previous addresses and source of funds.

If you are a business associate, we collect information to monitor services we have contracted for, or to assess services that are available to us. This information may include:

- Your full name including title.
- Your occupation and job title.
- Contact details for you at your place of business such as address, email and telephone number.

Please note, we do not request any special categories of personal data. Under the GDPR, special category data is more sensitive and therefore needs more protection. Categories include race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; sexual orientation.

When requested, you are not required to provide personal information, however, in doing so, we may not be able to proceed with a business relationship.

OUR USE OF YOUR INFORMATION
We collect and use information to provide services to you, or to receive services from you, in accordance with contractual obligations. We only use your information for our legitimate interests or, in certain circumstances, for those of a third party.

Our legitimate interests are:

- To administer and operate customer account(s) and to provide regulated activities including investment management and advisory services.
- To provide information relevant to the services we provide.
- To facilitate our business operations and to ensure compliance with any legal and regulatory requirements that we are subject to.

INFORMATION DISCLOSURE
Personal information may be disclosed to third party associates who provide us with professional, legal, accounting or other services. This may include providing personal data to third parties to comply with anti-money laundering regulations. Such processing may involve the use of automated decision making to confirm your identity.

All third parties are required to maintain the confidentiality of your personal data and to treat it in accordance with the law. Third parties are not permitted to use your data for any purpose other than that covered by their contractual arrangements with us.

We may disclose your personal information as required by, or to comply with, legal, regulatory or statutory requirements, or at the request of supervisory or governmental bodies.

Your personal data is not shared with any other organisations for marketing purposes and will not be used by us for marketing purposes unless explicit consent has been provided by you.

YOUR RIGHTS
Data protection laws provide you with the following rights:

- The right to check if we hold personal information about you.
- The right to see the information we hold about you.
- The right to have inaccurate information rectified.
- The right to be forgotten and to have certain information erased.
- The right to restrict processing of your personal data.
- The right to request that your personal information is transferred to a commonly used machine-readable format and provided to you or a third party.
- The right to object to the use of your information, including the right to restrict marketing.
- The right to restrict automated decision making and profiling.
- The right to withdraw consent previously provided to us to handle your information.

To exercise any of these rights, please get in touch using the contact details at the bottom of this policy.

Please note, if you are a client, by executing some of these rights, we may not be able to continue providing services to you.

If you are not satisfied with how we have handled your information you have a right to complain to the Information Commissioner’s Office (ico.org.uk).

RETENTION
We can retain your personal information for as long as required to provide services to you. After the termination of contracts, we may retain data for a period of six years to comply with legal and regulatory requirements.

After the expiration of six years, your personal data will be deleted.

If compelled to do so by statutory, regulatory or governmental bodies, we may retain your personal data for longer than six years.

THIRD PARTY WEBSITES
Our website may include links to others, but we are not responsible for the accuracy or completeness of information supplied by third party sites. We suggest you read the individual privacy policies for any websites visited.

COOKIES
When accessing our website and client portal, cookies, small text files placed on your computer, may be used. Browsers recognise when a cookie is offered and permit you to refuse or accept it.

We cannot see your IP address when you access our website, however, it may be used by Google Analytics to track user behaviour.

CONTACT US
If you have any questions, or wish to exercise any of the rights detailed above, please email hello@hundle.co