Jump to navigation Order execution policy Overview CCLA Investment Management Ltd (“CCLA IM”) and CCLA Fund Managers Limited (“CCLA FM”) are authorised and regulated by the Financial Conduct Authority and registered and incorporated in the United Kingdom. CCLA IM provides MiFID II services and activities for all CCLA clients and is the manager of the CBF Church of England Funds, the Public Sector Deposit Fund and all the Segregated client accounts. CCLA FM acts as the manager of the Alternative Investment Funds comprising of the COIF Charity Funds, the Local Authorities’ Property Fund and the Diversified Income Fund, which all fall within the scope of AIFMD. CCLA FM is a wholly owned subsidiary undertaking of CCLA IM. CCLA FM, as an AIFM, has delegated the portfolio management function to CCLA IM. CCLA IM’s permissions enable it to advise on investments, arrange deals in investments, deal in investments as agent and make arrangements with a view to transactions in investments and manage investments. As an investment manager, CCLA IM makes the decisions to deal and subsequently either transmits or actually executes these decisions on behalf of clients , and therefore CCLA IM is subject to COBS 11.2 of the FCA Handbook of rules and guidance (the “FCA Handbook”) issued by the United Kingdom Financial Conduct Authority (the “FCA”). In accordance with COBS 11.2, CCLA IM will, when executing orders (either directly with counterparties or passing orders to third party brokers for execution), take all sufficient steps to obtain the best possible result on behalf of its clients. (“Best Execution”). This Execution Policy sets out how CCLA IM will seek to achieve Best Execution. For the purposes of this policy, CCLA refers to CCLA Investment Management Limited. This Execution Policy is intended to function as a guideline for ensuring Best Execution by the investment making teams within CCLA. It is not intended to be interpreted or applied in a rigid manner that unnecessarily restricts or limits CCLA’s ability to achieve the best result for clients in any given situation. Please note that although the procedures set out in this Execution Policy are generally expected to produce the best possible result for clients, there is no guarantee that circumstances will enable this to be achieved in every single transaction. This Execution Policy is owned by the CCLA Chief Investment Officer (“CIO”), with support from CCLA’s investment and compliance teams and subject to oversight by CCLA Investment Risk Committee. Scope This Execution Policy applies only to CCLA in respect of Financial Instruments (as such terms are defined for the purposes of MiFID and the FCA Handbook) where CCLA executes orders directly with counterparties or transmits orders to third party brokers for execution. Therefore, throughout this Execution Policy, references to execution of orders should be interpreted as executing orders directly with counterparties or passing orders to third party brokers for execution. CCLA will be arranging deals for clients whether by way of (i) arranging and executing purchases or sales of listed securities, loans, bonds or other instruments in the secondary market or (ii) arranging and executing participations in primary transactions, including new loan or bond financings. Execution of ancillary transactions such as the execution of foreign exchange or other derivative transactions (“Ancillary Transactions”) shall also be covered by this Execution Policy. Some of these transactions may not be regarded as “financial instruments” (for example loan agreements). However, in line with CCLA’s commitment to high regulatory standards, it will seek to apply equivalent compliance standards to all transactions as part of its best practices. Client CCLA’s clients consist of collective investment schemes and segregated mandates (“clients”). CCLA’s strategies and order types Execution of orders by CCLA may take place in the context of the following strategies: • Liquid investments: orders are executed on a global Recognised Market stock exchange or through the Transfer Agent of a recognised collective investment scheme that is readily realisable on a daily basis. This includes Money Market funds. • Illiquid investments: orders are executed in relation to the primary participation or secondary purchase of loans, bonds, alternative investment funds or other instruments that are generally illiquid and/or not regularly traded in any market. • Liquid investments: orders are executed in relation to the secondary purchase of loans, bonds and other liquid instruments. Traders generally will execute transactions in respect of liquid investments in open market transactions with a broad number of regulated broker-dealers. • Ancillary Transactions: orders are executed in relation to derivatives, particularly FX derivatives, and generally as part of a hedging policy to manage portfolio risk. Execution Factors When executing orders on behalf of CCLA in relation to a financial instrument, CCLA will take sufficient steps to achieve Best Execution to ensure CCLA clients are treated fairly. CCLA will exercise its discretion in assessing the factors that it needs to take into account (and their relative importance) to provide CCLA clients with Best Execution. CCLA does not receive third-party payments or non-monetary benefits in relation to its selection of execution venue as per COBS 18 Annex 1 2.1R. CCLA may receive minor non-monetary benefits from Brokers such as macro research which is not considered to be “research” for the purposes of the FCA research payments rules. CCLA operates a separate policy of research and operates a fully unbundled approach to execution payments. The relative importance of the execution factors will be judged on an order by order basis in line with CCLA’s commercial judgement and experience in light of current market information and taking into account: • the characteristics of the client; • the characteristics of the transaction in question; • the characteristics of the financial instrument(s) in question; and • the characteristics of the possible Execution Venues to which the order may be directed. In many circumstances, the Execution Venue will be the counterparty to the trade. For liquid investments, CCLA maintains a list of approved Execution Venues that are included in Appendix A. CCLA may take into account the following execution factors for market traded or OTC securities: • price (relative importance – generally high); • location of assets which are the subject of the deal (relative importance – generally medium); • location of professional support (relative importance – generally medium); • market impact (relative importance – generally high); • costs and tax issues (relative importance – generally high); • order size (relative importance – generally high); • certainty of execution (relative importance – generally high); • speed of execution (relative importance – generally high); • settlement (relative importance – generally high); and • any other criteria relevant to the execution of the order. CCLA may prioritise other factors at its discretion. Due to the differences between CCLA’s strategies and the types of instruments in which CCLA transacts, different execution factors may apply to each strategy and/or instrument. In addition, the nature of CCLA’s business means that Best Execution will not necessarily be entirely dependent upon any one of the traditional execution factors (price, cost, speed, settlement, likelihood of execution, liquidity) nor upon execution venue. CCLA, therefore, applies its Best Execution obligations in a manner which takes into account the circumstances associated with the execution of orders in relation to the strategies and particular types of financial instruments in which CCLA deals, including: • credit fundamentals, investment thesis, risks and mitigation factors; • deal structure; • likelihood of deal completion; • capital structure; • jurisdiction; and • financial analysis. Bonds Orders for bonds are generally placed on over-the-counter (“OTC”) markets. The OTC markets, which are characterised by proprietary trading transactions, are decentralised, fragmented and may have low transparency, because the counterparties generally do not make the prices quoted available to a broad market. Rather, these prices are negotiated on a bilateral basis with the counterparties. The choice of counterparties for bonds is often limited. In many cases, as the products are only offered by a limited number of counterparties, there is not much transparency in terms of liquidity or price. In volatile non-transparent markets, it may be necessary to accept the first price offered without the opportunity to obtain or request other prices. Moreover, there may be bonds offered exclusively through one counterparty, or for which settlement of an order of a certain size can only be guaranteed by one counterparty, in which cases it is not possible to obtain a comparative offer. Loans Primary orders for loans are agreed and made directly with the counterparty (i.e., the borrower). Secondary orders for loans are generally placed with investment banks or other counterparties and are traded by such counterparties making markets for specific issues. If CCLA wishes to purchase a loan in a secondary trade it must contact the counterparty to agree a price. As a general rule, loans are less liquid and are traded less frequently than bonds and the choice of counterparties may be even more limited and the lack of market transparency even more marked. An order can be executed between two participants without others being aware of the price at which the transaction was affected. Equities The types of equity instruments in which CCLA invests will generally be traded on recognised markets. In addition, equity instruments may be ancillary to a primary debt investment where a company issues an equity instrument in the same transaction where a debt investment has been made.Derivatives Orders for derivatives are generally executed via trading intermediaries (broker-dealers). All derivatives must be traded under industry standard legal documentation. CCLA’s choice of counterparty for trading derivatives is limited to those counterparties where the required documentation is in place. Given the nature of the particular financial instruments that CCLA deals in, some execution factors may not be applicable to the orders executed by CCLA. When executing orders, in the absence of any specific instructions, CCLA will give precedence to the factors that allow it to deliver Best Execution in terms of total consideration, representing the price and the costs associated with the execution, which includes all expenses incurred by CCLA which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees, and any other fees paid to third parties involved in executing an order. Price will ordinarily merit a high relative importance in obtaining the best possible result. However, in some circumstances, CCLA may appropriately determine that other execution factors are more important than price in obtaining Best Execution. In order to make any such determination, our front office staff will use their commercial judgement and experience in light of available market information to achieve the best balance across a range of sometimes conflicting factors. This does not necessarily mean achieving the best price for every order, but the best possible result that can reasonably be expected given the resources available to our front office staff. In determining the “price” of a financial instrument, we will take into account a number of considerations including market parameters (i.e., the price at which a financial instrument may be trading on a regulated market or Multilateral Trading Facility (“MTF”)), level of market liquidity and volatility, valuation, and the risks incurred by entering into transactions. Examples of specific scenarios where price may not be the most important execution factor are: • Certainty of execution: in some circumstances, CCLA’s ability to actually execute the order may be the primary factor to be considered, for example where the instrument is illiquid or rarely traded or the size of the order is very large. • Costs and tax issues: where charges, taxes or other settlement costs may make the consideration prohibitive, then this may be the most important factor for CCLA to consider. • Order size: The best price in a market is usually represented by the opportunity to trade in a particular size which may not match the size of the CCLA order. Where the order is bigger than the typical quoted size, then the part of the order executed over and above the threshold may only be available at a less favourable price. Similarly large orders may be available at a more favourable price than smaller orders. Execution Venues When CCLA transacts directly with a counterparty, the counterparty is the execution venue for that trade. For more liquid investments, broker-dealers and other similar market participants is likely to be the relevant execution venue. Having assessed the relevant execution factors and relative importance of the execution factors specific to that order to achieve consistently the best overall result as well as any specific instructions, CCLA will select the most appropriate Execution Venue(s) from those available (when there is a choice) and execute the order accordingly. For purposes of MIFID, a “venue” includes an exchange, a multilateral trading facility, a broker, a market maker, a systematic internaliser or another liquidity provider. CCLA expects to use a selection of Execution Venues. Sometimes there is only one appropriate venue, and, in such cases, CCLA will only use a single venue. CCLA may execute otherwise than on a Regulated Market or MTF where bringing together the parties of a transaction in relation to a financial instrument which is not traded on a traditional execution venue, for example when arranging or participating in a primary lending transaction. The factors affecting choice of Execution Venue are price, the need for timely execution, market liquidity, the size and nature of the order and counterparty risk. Our choice of venue may be constrained by the fact that there may be no choice of venue where an order can be executed due to the nature of the order or requirements by CCLA or due to the nature of the particular instrument (e.g. an illiquid loan is likely to have no choice of venue) and the fact of execution may itself constitute Best Execution. Price In the context of selecting execution venues, price refers to whether an execution venue generally offers prices that are as good as, or better than, its competitors. Price is therefore a relevant factor in selecting execution venues to execute orders. Counterparty risk While trading of bonds generally settle quickly, primary or secondary settlements in respect of loans may be more extended, particularly if the asset is trading under distressed circumstances. In order to manage counterparty risk in respect of Execution Venue, CCLA monitors and manages extended settlements through its weekly settlement update with a view to minimising, where possible, settlement time, thereby managing counterparty risk. In addition, CCLA maintains a list of approved brokers or counterparties. CCLA expects to undertake appropriate due diligence of approved brokers to mitigate counterparty risk, with a particular focus on the following criteria: financial soundness; market presence; rating; and no material adverse market information. The Execution Venues typically used by CCLA will vary depending on the type and geographical location of the transaction. Private Market transactions Execution of orders by CCLA on behalf of clients may take place in private market type transactions; including private equity, venture capital, loans and real assets such as property. The execution of such a transaction is generally by way of signing a contract, by CCLA as agent of its client, directly to take ownership of, or a percentage of, an asset. The asset will generally be illiquid and/or not regularly traded in any market. For these particular investments CCLA may take into account the following execution factors: • price (relative importance – generally high); • location of professional support (relative importance – generally medium); • costs and tax issues (relative importance – generally high); • yield (relative importance – generally high); • certainty of execution (relative importance – generally medium); and • any other criteria relevant to the execution of the transaction. The relative importance of the execution factors will be judged on a transaction by transaction basis in line with CCLA’s commercial judgement and experience in light of relevant information and taking into account the characteristics of: • the client; • the transaction in question, including liquidity and yield; • the asset type in question; and • the execution venue the order may be executed. In private market transactions, CCLA will transact as an agent of its client directly with the counterparty and in private market trades, the counterparty will be the execution venue. Specific Client Instructions As an investment manager/adviser of funds and segregated accounts, CCLA’s client is unlikely to provide specific instructions. In the event that a client does provide CCLA with specific instructions to deal on their behalf, it will execute the orders in accordance with those specific instructions and will have complied with its obligation to obtain the best possible result when executing that order by following those instructions. Where the instructions relate to only part of an order, CCLA will continue to apply its Execution Policy to those aspects of the order not covered by such specific instructions. Client’s should be aware that providing specific instructions to CCLA in relation to the execution of a particular order may prevent it from following this Execution Policy which is designed to obtain Best Execution for CCLA’s clients on a consistent basis taking into account the factors outlined above. Subject to any specific instructions that clients may give to CCLA (see the section above, this is unlikely to occur), CCLA may transmit an order to another entity which is affiliated with or related to CCLA or to an external entity for execution. In doing so, CCLA will act in the best interests of CCLA and consider the provisions of this Execution Policy. Monitoring and Review CCLA regularly monitors the effectiveness of this Execution Policy and its execution arrangements to identify, and where appropriate, correct any deficiencies. On a monthly basis a Best Execution report is provided by LiquidMetrix, an independent report, to the CIO or his designates. From time to time, CCLA’s Assurance team will also undertake a periodic review of concentration by broker to flag trading levels that appear off market or show high levels of concentration by broker. For more liquid investments, CCLA also expects portfolio managers to be able to monitor execution quality by comparison to the last Bloomberg price and current observable pricing and quotes at the time of the trade. The best execution obligation requires CCLA to take all sufficient steps to deliver the best possible result for clients. Although CCLA expects to find instances where it will be apparent that best execution was not provided, there may be legitimate reasons for this, or it may be that CCLA could have improved the service provided to clients. The relevant teams will work together to learn from these incidents and correct any deficiencies identified as a result of CCLA’s best execution monitoring. CCLA will review this Execution Policy at least annually or whenever a material change occurs that affects the firm’s ability to continue to obtain the best possible result for CCLA on a consistent basis using the methods described in this Execution Policy. This Execution Policy will be provided to CCLA clients. Consent Under MiFID and the FCA Handbook, CCLA requires the prior consent of each client to this Execution Policy and prior express consent to allow it to execute orders outside a Regulated Market or Multilateral Trading Facility. CCLA ordinarily obtains this consent in its management or advisory agreements with clients. January 2021 Approved Execution Venues Appendix A. The following are approved execution venues i.e. eligible securities markets, for the purposes of this Best Execution Policy: EEA Member States securities markets regulated in accordance with MiFID Austria Belgium Bulgaria Cyprus Czech Republic Denmark Estonia Finland France Germany Greece Hungary Iceland Ireland Italy Latvia Lithuania Luxembourg The Netherlands Norway Poland Portugal Slovak Republic Slovenia Spain Sweden United Kingdom Other EEA regulated markets: Alternative Investment Market (AIM) International Securities Market Association (ISMA) The Grey Book Market Non-EEA securities markets: Australia ASX Group Brazil BM&F BOVESPA Canada TMX Group Channel Islands Channel Islands and Securities Exchange Hong Kong Hong Kong Exchanges & Clearing Indonesia Indonesia Stock Exchange Israel The Tel-Aviv Stock Exchange Japan Japan Exchange Group The Fukuoka Stock Exchange The Nagoya Stock Exchange The Sapporo Securities Exchange Malaysia Bursa Malaysia Mexico Bolsa Mexicana de Valores New Zealand NSX Group Philippines The Philippines Stock Exchange Russia Moscow Exchange Singapore Singapore Exchange South Africa Johannesburg Stock Exchange Switzerland Swiss Exchange Taiwan Taiwan Stock Exchange Thailand The Stock Exchange of Thailand Turkey Borsa Istanbul United States of America NYSE MKT LLC BATS Exchange Inc CME Group NASDAQ Stock Exchange National Stock Exchange New York Stock Exchange (including NYSE MKT LLC and NYSE Arca) The Intercontinental Exchange (ICE) The following are approved Equity and Fixed Income Brokers that may be deemed an execution venue: Barclays Capital Securities Ltd Sanford C Bernstein Ltd Bank of America Merrill Lynch International Ltd BTIG Ltd Canaccord Genuity Ltd Cantor Fitzgerald Europe Carnegie Investment Bank AB CF Global Trading (UK) Ltd Cenkos Securities Ltd Citigroup Global Markets Ltd CLSA UK Limited Cowen Execution Services Ltd Credit Suisse Securities (Europe) Ltd Deutsche Bank AG Fidante Partners Europe Ltd HSBC Bank Plc Investec Bank Ltd Investment Technology Group Ltd J&E Davy Jefferies International Ltd Joh. Berenberg, Gossler & Co. KG JPMorgan Securities Plc King & Shaxson Limited Liquidnet Lloyds Bank Corporate Markets Plc Morgan Stanley & co Int PLC Mirabaud Securities Ltd Mitsubishi UFJ Securities International Plc Numis Securities Ltd N+1 Singer Capital Markets Ltd Panmure Gordon & Co Ltd Peel Hunt Stifel Nicolaus Europe Ltd Redburn Europe Royal Bank of Canada Europe Ltd Royal Bank of Scotland Plc RiA Capital Markets Ltd Seaport Europe UBS Limited Virtu Financial ireland Limited William Blair International Ltd Winterflood Securities Ltd The following are approved Foreign Exchange Approved Counterparties that may be deemed an execution venue: HSBC Banks Plc Commerzbank AG Northern Trust Email Print OUR POLICIES Anti-bribery and corruption statement Best Execution Policy: Cash Funds – UK Money Markets CCLA Modern Slavery Statement CCLA voting guidelines Climate change and investment policy Cluster munitions and landmines policy Conflicts of interest policy Engagement Policy Environmental policy Order execution policy Pillar 3 Disclosures Privacy policy Remuneration policy Website terms of use policy Click the Keep in Touch button to receive market updates, insights and news from CCLA. SITE Home About CCLA Investment solutions Client resources Contact us HELPFUL LINKS Sitemap Processing times Pricing and valuation tool European MIFID Template (2019) European MIFID Template (2018) European MIFID Template (2020) Complaints Policy Announcements Assessment of Value RTS 28 Disclosures Vacancies SFDR Disclosure Report OUR POLICIES Anti-bribery and corruption statement Best Execution Policy: Cash Funds – UK Money Markets CCLA Modern Slavery Statement CCLA voting guidelines Climate change and investment policy Cluster munitions and landmines policy Conflicts of interest policy Engagement Policy Environmental policy Order execution policy Pillar 3 Disclosures Privacy policy Remuneration policy Website terms of use policy CCLA Investment Management Limited (registered in England and Wales, number 2183088) and CCLA Fund Managers Limited (registered in England and Wales, number 8735639) are authorised and regulated by the Financial Conduct Authority. © CCLA Investment Management Limited 2021. All rights reserved. Terms and conditions CCLA Website Terms of Use Welcome to CCLA's website for: fund management services for CCLA Funds (details of and documentation relating to all CCLA Funds is available on CCLA’s website); and discretionary investment management services for individual client portfolios. This page provides you with information about CCLA and the legal terms and conditions (Terms of Use or Terms) on which you can access and use this website. By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them. Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these Terms you must not use or access this website. Where necessary, we may amend these Terms of Use from time to time by updating this page. We therefore recommend that you check this page periodically to ensure that you understand the Terms which will apply from time to time. 1. About us (CCLA) 1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable). 1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281. 1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707. 1.4 The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing clientservices@ccla.co.uk. 2. Who may use this website 2.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the CCLA Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors). Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland. Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003. 2.2 Please ensure that you understand whether or not you are an eligible investor in respect of the CCLA Funds, investments and investment services referred to on this website. 3. The purpose of this website 3.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice. 3.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. 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Past performance is no guarantee of future returns. 4.2 Please refer to the Funds’ individual scheme particulars or prospectus for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance. 4.3 Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision. 5. Complaints and compensation 8.1 All complaints will be handled in accordance with CCLA’s Complaints Policy which can be found at https://www.ccla.co.uk/helpful-links/ccla-complaints-policy. If either CCLA IM or CCLA FM cannot meet its obligations (for example, where it has stopped trading and there are insufficient assets to meet its obligations), investors may be eligible to claim compensation up to a maximum of £85,000 from the Financial Services Compensation Scheme. There are limits on who is eligible to claim and which funds are covered. For further information about the Financial Services Compensation Scheme please refer to www.fscs.org.uk or phone 0800 678 1100. 6. CCLA's liability 6.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA. 6.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider. 6.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. 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Third party websites 7.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. You will be responsible for complying with the terms and conditions of use for any linked website. 8. Copyright and trade marks 8.1 CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. 8.2 You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors. 8.3 No use of CCLA's name, logos and/or other trademarks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion. 9. Data protection 9.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes. 9.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you (you may inform CCLA at any time if you do not want to receive such communications); and (vii) as otherwise agreed by you. 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In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner. 9.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years. 9.6 By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET. 9.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request. 10. Cookies 10.1 This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website. 10.2 When you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information. 10.3 You can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser. 10.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit www.allaboutcookies.org. 11. Recording of communications Your telephone calls and electronic communications with CCLA may be recorded. You agree that CCLA may deliver copies or transcripts of such recording to any court or competent regulatory authority. Such records of conversation and/or communications with you will be available on request for a period of five years (or, where requested by the FCA, for a period of up to seven years) from the date when a record is made. 12. General 12.1 Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect. 12.2 If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. 12.3 These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use. 18 August 2021 Accept Decline