Select a Role Terms and conditions Table of Contents For Professional Clients Role Definition Terms of Use Cookie Policy Privacy Policy Accessibility Statement For Professional Clients You are about to enter the J.P. Morgan Asset Management website for Advisers & Asset/Wealth Managers. It is for professional investors, also known as professional clients. Please read the following legal and regulatory information, which applies to our company status, use of this website and information about investment in our products referred to in this website (the "Site"). By using this Site you agree to the placement of certain cookies on your computer – please follow the link to our cookie policy at the top of this page for more information. Role Definition Definitions for investor types Advisers are professional investors who are authorised by relevant regulators to provide their clients with investment and/or pension advice. Asset or Wealth Managers are financial planners, investment portfolio managers and other professional investors. The 'Institutional' site is for pension schemes, consultants or other professional investors. The 'Global Liquidity' site is for professional investors who are looking for liquidity investment opportunities. Personal investors (also known as 'retail clients') are client organisations or individuals who cannot meet both (i) one or more of the professional client criteria laid down in Annex II to the Markets in Financial Instruments Directive (Directive 2004/39/EC), and (ii) one or more of the qualified investor criteria set out in Article 2 of the Prospectus Directive (Directive 2003/71/EC). The personal investor category gives investors the greatest level of protection under the regulations and ensures investors get full information about any products they invest in. If you are a retail investor but would like to be categorised as a professional investor, you should know that this is allowed but it would mean: You could receive less information about our investments products and services; and you wouldn't be entitled to receive a suitability report or appropriateness assessment in cases where they would be required for personal investors. If you are a professional investor (also known as a 'professional client') but would like to be categorised as a personal investor, this is allowed but it doesn't necessarily mean you can refer any complaints to the Financial Ombudsman Service and you may not be eligible for compensation under the Financial Services Compensation Scheme. Professional investors (also known as 'professional clients') The definition of a professional client comes from the MiFID directive which provides definitions for professional and retail clients as well as eligible counterparties. MiFID adopts two main categories of client: retail and professional. There is a separate and distinct third category for a limited range of business: eligible counterparty (ECP) has the lowest level of protection under MiFID. Professional clients are those who may be deemed to possess the experience, knowledge and expertise to make their own investment decisions and properly assess the risks associated thereto. The list below taken from the official Journal of the European Union (L 145/44 EN Official Journal of the European Union 30.4.2004) should be understood as including all authorised entities carrying out the characteristic activities of the entities mentioned: entities authorised by a Member State under a Directive, entities authorized or regulated by a Member State without reference to a Directive, and entities authorised or regulated by a non-Member State: Credit institutions Investment firms Other authorised or regulated financial institutions Insurance companies Collective investment schemes and management companies of such schemes Pension funds and management companies of such funds Commodity and commodity derivatives dealers Locals Other institutional investors Large undertakings meeting two of the following size requirements on a company basis: balance sheet total: EUR 20 000 000 net turnover: EUR 40 000 000 own funds: EUR 2 000 000 National and regional governments, public bodies that manage public debt, central banks, international and supranational institutions such as the World Bank, the International Monetary Fund (IMF), the European Central Bank (ECB), the European Investment Bank (EIB) and other similar international organisations Other institutional investors whose main activity is to invest in financial instruments, including entities dedicated to the securitisation of assets or other financing transactions Please note that the above summary is provided for information purposes only. If you are uncertain as to whether you can be classified both as a professional client under the Markets in Financial Instruments Directive and classed as a qualified investor under the Prospectus Directive then you should seek independent advice. Terms of Use 1. General information The information on this Site is approved for issue by JPMorgan Asset Management (UK) Limited, which is part of the J.P.Morgan Asset Management ("JPMAM") marketing group (hereafter referred to as ‘we’ or ‘us’), which sells investments, life assurance and pension products. It is authorised and regulated in the UK by the Financial Conduct Authority under registration number 122754. This Site has been produced for information purposes only and the views contained in it are not to be taken as advice or a recommendation to buy or sell any investment. (Reliance upon information in the Site is at the sole discretion of the reader). This Site provides information about J.P. Morgan investment funds ("JPM Funds"). This Site is strictly limited to information ends and is not allowed to be used for subscription or transactions of units/shares in JPM Funds. Any research described in the Site has been obtained by us for our own purpose. The results of such research are being made available as additional information and do not necessarily reflect our views. Any forecasts, figures, opinions, statements of financial market trends or investment techniques and strategies expressed are unless otherwise stated our own at the date of the relevant content. They are considered to be reliable at the time of writing, may not be all-inclusive and their accuracy and any forecasts are not guaranteed. They may be subject to change without reference or notification to you. This information should not be regarded as giving you legal, investment or tax advice about our products. If you are unclear about any of the information on this Site or its suitability for you, please contact your legal, financial or tax adviser, or an independent legal, financial or tax adviser before making any investment or financial decisions. This Site should not be accessed by any person in any jurisdiction where (by reason of that person's nationality, residence or otherwise) the publication or availability of this Site is prohibited. In particular, this Site is reserved exclusively for non-US Persons*. The information in this Site is not for distribution to and does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States of America to or for the benefit of US Persons. Messages that you send to us by e-mail may not be secure. We recommend that you do not send any confidential information to us by e-mail as it may be intercepted by a third party. If you choose to send any confidential information to us via e-mail you do so at your own risk with the knowledge that a third party may intercept this information and we do not accept any responsibility for the security or integrity of such information. We will try to keep this site operational at all times. However, we cannot guarantee that this Site or any of the various features upon it will always be available. The hyperlinks provided on this Site are only provided for information and convenience purposes. JPMorgan Asset Management (UK) Limited is not responsible for the content of external internet sites that link to or are accessible from this Site. JPMorgan Asset Management (UK) Limited does not assume any responsibility or liability with respect to any website accessed via this Site. Prospective investors should consult their own professional advisers on the tax implications of making an investment in, holding or disposing of any JPM Fund and the receipt of distributions with respect to such a fund. 2. Privacy and cookie policies Please refer to our Privacy and Cookie Policies via the footer link. 3. Where our funds are available for sale The countries our funds are authorized for sale will depend upon your country of domicile for tax purposes. To the extent you have questions about your status, you should consult your financial or other professional advisor. 4. Key investment risks It is important that you read the relevant documentation (funds prospectus, Key Investor Information Document ‘KIID’) before you invest in JPM Funds to ensure you understand the specific risks involved and to determine whether it is a suitable product for you. A copy of the funds prospectus, the Key Investor Information Document ‘KIID’, as well as the annual and semi annual reports of the JPM Funds are available free of charge upon request from JPMorgan Asset Management (UK) Limited. The value of shares/units of JPM Funds and any income from them can go down as well as up and you may not get back all that you have invested. Estimates of future returns or indications of past performance on this Site are for information purposes only and should not be construed as a guarantee of current or future returns or performance. Exchange rate changes may cause the value of underlying overseas investments to go down as well as up. Changes in currency rates of exchange may have an adverse effect on the value or income (if any) of the JPM Funds. When investing in emerging market funds, emerging markets may be more volatile and the risk to your capital is greater. The level of tax benefits and liabilities will depend on individual circumstances and may be subject to change in the future. 5. Combating financial crime We are committed to combating financial crime and the prevention of money laundering. Accordingly we may need to verify your identity and carry out appropriate security checks. 6. Company information J.P. Morgan Asset Management is the brand name for the asset management business of JPMorgan Chase & Co. and its affiliates worldwide. JPMorgan Asset Management (UK) Limited, which is authorised and regulated by the Financial Conduct Authority. Registered in England No. 288553. Registered address: 25 Bank St, Canary Wharf, London E14 5JP, United Kingdom. JPMorgan Asset Management (Europe) Société à responsabilité limitée, has its registered offices at 6, route de Trèves, L-2633 Senningerberg, Luxembourg. 7. Legal information We believe that the information contained on this Site is accurate as at the date of publication. We cannot guarantee the accuracy, suitability or completeness of any such information or the availability of the Site. We accept no liability for any data transmission errors such as data loss or damage or alteration of any kind. Accordingly JPMorgan Asset Management (UK) Limited excludes any liability for any loss and/or damage (direct or consequential) arising from the use of any part of this Site. All copyright, patent, intellectual and other property in the information contained in this Site is held by JPMorgan Asset Management (UK) Limited, unless otherwise indicated. No rights of any kind are licensed or assigned or shall otherwise pass to persons accessing this information. You may download or print copies of the reports or information contained within this Site for your own private non-commercial use only, provided that you do not change any copyright, trade mark or other proprietary notices; all other copying, reproducing, transmitting, distributing or displaying of material on this Site (by any means and in whole or in part) is prohibited. * US Person includes, but is not limited to, a person (including a partnership, corporation, limited liability company or similar entity) that is a citizen or a resident of the United States or is organised or incorporated under the laws of the United States. Certain restrictions also apply to any subsequent transfer of Shares in the United States or to US Persons. Should a Shareholder become a US Person and such US Person is not compulsory redeemed, such US Person may be subject to US withholding taxes and tax reporting. Cookie Policy This policy explains how cookies are used on this website and other websites that link to this page and are made available by J.P. Morgan Chase Bank, N.A. and its worldwide affiliates and subsidiaries (collectively, “J.P. Morgan,” “we,” or “us”). This policy may be amended or updated from time to time to reflect changes in our practices or changes in applicable law. We encourage you to read this policy carefully and regularly check this page to review any changes we may make. By using this site, you agree to J.P. Morgan’s use of cookies on your device in accordance with the terms of this policy. If you do not wish to accept cookies from this site, please either disable cookies or refrain from using this site. 1. What are Cookies? A cookie is a small text-only file of information that is sent or transferred to your device (such as your computer, smartphone or other web-enabled device) when you access a website. Cookies allow the website to recognise your device when you revisit and remember certain information about your prior visit such as which pages you visited, choices you made from menus, any specific information you entered into forms and the time and date of your visit. Among other things, cookies help us evaluate what parts of our websites are useful and which need improvement. 2. What Types of Cookies Do We Use? The main types of cookies we use on our websites are: Strictly Necessary cookies allow the technical operation of our websites or apps (e.g., cookies that enable you to navigate a website or app, and to use its features). Some may also increase the usability of our websites or apps by remembering your choices. You may be able to disable some or all necessary cookies by adjusting your browser settings. If you choose to do so, however, you may experience reduced functionality or be prevented from using our websites or apps altogether. Performance cookies help us enhance the performance and usability of our websites or apps. If you choose not to accept these cookies you may experience less than optimal performance. Analytics cookies help us ensure that we understand our audience as clearly as possible, and that any information that is provided to you is as relevant as possible to your interests and preferences. Marketing cookies help us evaluate the effectiveness of our marketing campaigns or to provide better targeting for marketing. These cookies may collect personal data such as your name as well as information about how you interact with our websites, apps or marketing materials. 3. First Party and Third Party Cookies Cookies can be set by the operator of the websites you visit or by third parties that may or may not have a relationship with that operator. First party cookies are set by the operator to gather information for use by the operator. For example, we set first party cookies that help us evaluate whether our websites are performing as intended. In addition to cookies which send information to us, our websites also use cookies which collect information and send it to third parties. These are third party cookies and are set by an external organisation. An example of this is Google Analytics. We use Google Analytics to help collect and compile information like the number of visitors to our site, where visitors have come to the site from and the pages they visited. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. We also use certain Microsoft advertising features such as Universal Event Tracking to assist with our online marketing efforts. Please read the Microsoft Privacy Statement for information about Microsoft’s privacy practices. Where this site allows third party cookies to be set or you access other websites from our site using the links provided, please note that these websites will use cookies in accordance with their own cookies policy which may differ from ours. You may be able to block first and third-party cookies through your browser settings. 4. Cookies and Personal Data Some of our cookies may collect and store your personal data, such as your name, email address or IP address. We are committed to respecting and protecting your privacy and will ensure that personal data we collect is kept and treated in accordance with our privacy policy. For further details of how we process personal data, please refer to our privacy policy. 5. Your Rights to Disable or Refuse Cookies on this Site Most browsers are initially set to accept cookies. However, you typically have the ability to disable cookies if you wish by changing your internet software browsing settings. To manage your use of cookies there are various resources available to you. For example, the ‘Help’ section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s ‘add-on settings’ or visiting the website of its manufacturer. Privacy Policy Effective from 12th May 2021 1. This policy This Policy is issued by J.P. Morgan Asset Management International Limited on behalf of itself, its branches, its subsidiaries and its affiliates, identified as Controllers in the table in Section 13 below (together, “J.P. Morgan Asset Management”, “we”, “us” or “our”) and is addressed to individuals outside our organisation with whom we interact, including visitors to our websites (our “Sites”), customers, Personnel of corporate customers, investors and vendors, and other recipients of our services (together, “you”). Defined terms used in this Policy are explained in Section 14 below. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. 2. Processing your personal data Collection of Personal Data: We collect Personal Data about you, subject to applicable law, from a variety of sources as follows: We obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means). We collect your Personal Data in the ordinary course of our relationship with you (e.g., in the course of managing your transactions or your investment in our funds). We collect Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible). We receive your Personal Data from third parties who provide it to us (e.g., your employer; our customers; credit reference agencies; law enforcement authorities; etc.). We receive your Personal Data from third parties, where you purchase any of our products or services through such third parties. We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data. Creation of Personal Data: We may also create Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to applicable law. Relevant Personal and Sensitive Personal Data: The categories of Personal Data about you that we may Process, subject to applicable law, are as follows: Personal details: given name(s); preferred name; nickname(s), gender; date of birth / age; marital status; Social Security Number; Passport number(s); other Government(s) issued numbers (tax identification number, Green Card(s) number(s) including Driving Licence number); nationality; lifestyle and social circumstances; images of Passports; images of Driving Licences; images of Gun Licence(s); images of signatures; authentication data (passwords, mother maiden name, challenge/response questions and answers, PINs, face recognition, voice recognition) and photograph, visual images, personal appearance and behaviour. Family details: names and contact details of family members and dependents. Contact details: address; telephone number; fax number; email address; and social media profile details. Employment details: industry; role; business activities; names of current and former employers; work address; work telephone number; work fax number; work email address; and work-related social media profile details. Education history: details of your education and qualifications. Financial details: billing address; bank account numbers; credit card numbers; cardholder or accountholder name and details; instruction records; transaction details; and counterparty details. Views and opinions: any views and opinions that you choose to send to us, or publish about us on (including on social media platforms). Electronic Identifying Data: IP address cookies, logs, online identifiers, device IDs, geolocation. Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where: the Processing is necessary for compliance with a legal obligation (e.g., to comply with our diversity reporting obligations); the Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law; you have manifestly made those Sensitive Personal Data public; the Processing is necessary for the establishment, exercise or defence of legal rights; we have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way); or Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests. We only Process Criminal Offences Data, and national identification numbers, to the extent required or permitted by applicable law. Purposes for which we may Process your Personal Data, and legal bases for Processing: The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we may perform such Processing, are: Processing activity Legal basis for processing AML/KYC: fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies (including but not limited to the European Union and the United Nations Security Council) and/ or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions. The Processing is necessary for compliance with a legal obligation; or The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of protecting against fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures. The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of on-boarding new clients (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). Provision of products and services to you: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services. The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). Marketing / Prospecting: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate. We have a legitimate interest in carrying out the Processing for the purpose of conducting marketing and prospecting (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). Operation of our Sites: operation and management of our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites. The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). IT operations: management of our communications systems; operation of IT security; and IT security audits. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing and operating our IT systems and ensuring the security of those systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of providing a safe and secure environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary to protect the vital interests of any individual. Financial management: sales; finance; corporate audit; and vendor management. We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services. We have a legitimate interest in carrying out the Processing for the purpose of conducting research and producing analysis (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems). The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). Legal compliance: compliance with our legal and regulatory obligations under applicable law. The Processing is necessary for compliance with a legal obligation. Legal proceedings: establishing, exercising and defending legal rights. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services. We have a legitimate interest in carrying out the Processing for the purpose of improving our products or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). Risk Management: Audit, compliance, controls and other risk management. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing the levels of risk to which our business is exposed (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). Fraud prevention: Detecting, preventing and investigating fraud. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). 3. Disclosure of personal data to third parties We may disclose your Personal Data to other entities within the J.P. Morgan group, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law. In addition, we may disclose your Personal Data to: you and, where appropriate, your family, your associates and your representatives; clients and customers of our businesses; credit reference agencies; anti-fraud services; Governmental, legal, tax and regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation; accountants, auditors, financial and tax advisors, lawyers, notaries and other outside professional advisors to J.P. Morgan Asset Management or our funds, subject to binding contractual obligations of confidentiality in accordance with applicable law; banks, non-bank lenders, company administrators, trade and corporate registries and depositaries; general partners of funds we advise or manage; debt-collection agencies and tracing agencies; data aggregation services; accreditation bodies; third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section 3; any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law; any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law; to any relevant party in connection with AML/KYC requirements; any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation) or the assets or business of our funds; the press and the media; and voluntary and charitable organisations. Our Sites may use third party plugins or content. If you choose to interact with any such plugins or content, your Personal Data may be shared with the third party provider of the relevant social media platform. We recommend that you review that third party’s privacy policy before interacting with its plugins or content. If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. 4. International transfer of personal data Because of the international nature of our business, we may need to transfer your Personal Data within the J.P. Morgan group, and to third parties as noted in Section 3 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard, to those that apply in the country in which you are located. Where we transfer your Personal Data to other countries, we do so on the basis of: European Commission’s adequacy decisions; our binding corporate rules; suitable standard contractual clauses; or other valid transfer mechanisms. If you want to receive more information about the safeguards applied to international transfers of personal data, please use the contact details provided in Section 12 below. 5. Data security We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. You are responsible for ensuring that any Personal Data that you send to us are sent securely. 6. Data accuracy We take reasonable steps designed to ensure that: your Personal Data that we Process are accurate and, where necessary, kept up to date; and any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay. From time to time we may ask you to confirm the accuracy of your Personal Data. 7. Data minimisation We take reasonable steps designed to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy. 8. Data retention We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows: (1) we will retain copies of your Personal Data in a form that permits identification only for as long as: a. we maintain an ongoing relationship with you (e.g., where you are a recipient of our services, or you are lawfully included in our mailing list and have not unsubscribed); or b. your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your personal data are included in a contract between us and your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data), plus: (2) the duration of: a. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and b. an additional two (2) month period following the end of such applicable limitation period (so that, if a person bring a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim), and: (3) in addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim. During the periods noted in paragraphs (2)a and (2)b above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law. Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either: permanently delete or destroy the relevant Personal Data; archive your Personal Data so that it is beyond use; or anonymize the relevant Personal Data. 9. Your legal rights Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including: the right to request access to, or copies of, your Personal Data that we Process or control, together with information regarding the nature, processing and disclosure of those Personal Data; the right to request rectification of any inaccuracies in your Personal Data that we Process or control; the right to request, on legitimate grounds: erasure of your Personal Data that we Process or control; or restriction of Processing of your Personal Data that we Process or control; the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable; where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf. This does not affect your statutory rights. Subject to applicable law, you may also have the following additional rights regarding the Processing of your Personal Data: the right to object, on grounds relating to your particular situation, to the Processing of your Personal Data by us or on our behalf; and the right to object to the Processing of your Personal Data by us or on our behalf for direct marketing purposes. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section 13 below. 10. Cookies A cookie is a small file that is placed on your device when you visit a website (including our Sites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology, in accordance with our Cookie Policy. 11. Direct marketing We may process your Personal Data to contact you, primarily by mail and email and also on occasion by telephone, so that we can provide you with information concerning products and services that may be of interest, in accordance with applicable law. If you do not wish to receive marketing communications from us you can opt out at any time by contacting your regular J.P. Morgan contact, or by electronically unsubscribing from emails we have sent to you. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any Services you have requested. 12. Contact details If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by J.P. Morgan Asset Management, please contact your regular J.P. Morgan client service contact, or by using the following email: am.data.privacy.control@jpmorgan.com. Alternatively, you could contact the J.P. Morgan Asset Management Data Protection Office via post by addressing your letter to the relevant Controller entity as listed below in section 13. If you would like to contact the JPMC Data Protection Officer, please send an email to EMEA.Privacy.Office@jpmchase.com. 13. Controllers For the purposes of this Policy, the relevant controllers are: Controller entity Business address J.P. Morgan Asset Management Real Estate (France) SAS 14 place Vendôme, Paris F-75001, France J.P. Morgan RE Luxembourg Management Company S.A. 6, route de Trèves, Senningerberg, L-2633 Luxembourg JPMorgan Asset Management (Europe) S.à r.l. 6, route de Trèves, Senningerberg, L-2633 Luxembourg JPMorgan Funds Limited 60 Victoria Embankment, London, EC4Y 0JP, UK J.P. Morgan Trustee & Administration Services Limited 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Life Limited 60 Victoria Embankment, London, EC4Y 0JP, UK J.P. Morgan Investment Management Inc., London Branch 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Asset Management (UK) Limited 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Asset Management (Switzerland) LLC Dreikönigstrasse 37, Zurich 8002, Switzerland Other entities acting as controllers: Controller Entity Business address JPMorgan Funds (Ireland) ICAV 200 Capital Dock, 79 Sir John Rogerson’s Quay, Dublin 2, D02 RK57, Ireland JPMorgan ETFs (Ireland) ICAV 200 Capital Dock, 79 Sir John Rogerson’s Quay, Dublin 2, D02 RK57, Ireland JPMorgan Elect Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Japanese Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK The Mercantile Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Global Growth & Income Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan European Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Japan Small Cap Growth & Income Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan US Smaller Companies Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan American Investment trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Claverhouse Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Mid Cap Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Asia Growth & Income Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Global Emerging Markets Income Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Indian Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan China Growth & Income Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan European Smaller Companies Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan UK Smaller Companies Investment Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Emerging Markets Investment trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Russian Securities Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Multi-Asset Trust Plc 60 Victoria Embankment, London, EC4Y 0JP, UK JPMorgan Global Core Real Assets Ltd 60 Victoria Embankment, London, EC4Y 0JP, UK 14. Defined terms Controller The entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws. Data Protection Authority An independent public authority that is legally tasked with overseeing compliance with applicable data protection laws. Personal Data Information that is about any individual, or from which any individual is identifiable1. Process or Processed or Processing Anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Personnel Any current, former and prospective directors, officers, consultants, employees, temporary staff, individual contractors, interns, secondees and other personnel. Processor Any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller). Sensitive Personal Data Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, or any other information that may be deemed to be sensitive under applicable law. Criminal Offences Data Personal Data about any actual or alleged criminal offences or penalties. 1It should be noted that the concept of personal data in the data protection laws of Austria and Switzerland includes information about corporate bodies as well as individuals. 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