Legal information

Arundel (Securities), Inc. is a member of the Financial Industry Regulatory Authority (“FINRA”) (www.finra.org ) and a broker dealer registered with the U.S. Securities and Exchange Commission.

BrokerCheck — Please click on this link brokercheck.finra.org to go to the BrokerCheck homepage. A summary of the Business Continuity Plan of Arundel (Securities) Inc is set out below. Membership of FINRA does not mean that FINRA has endorsed or approved of Arundel (Securities) Inc.

Arundel (Securities) Inc. is a member of the Securities Investor Protection Corporation (“SIPC”) which protects securities of customers of its members up to $500,000 (including $250,000 for claims for cash). Information on SIPC, including the SIPC brochure, may be obtained from their website www.sipc.org or by telephoning SIPC on (202) 371-8300.

Arundel Group Limited is authorised and regulated by the Financial Conduct Authority of 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom (“FCA”).

Arundel (Mauritius) Limited is regulated by the Financial Services Commission in Mauritius.

Arundel Group Limited is registered in England and Wales with registered number 2722984. Its registered office is Arundel House, 31a St. James’s Square, London, SW1Y 4JR. Arundel Group Limited is registered for VAT with registration number 606 0428 72.

This financial promotion is approved by Arundel Group Limited. The value of investments and income therefrom may fluctuate and your capital may be at risk. The services offered hereunder may not be suitable for all persons. Past performance is not a reliable indicator of future results. Separate taxation advice should always be taken. Tax treatment depends on the individual circumstances of each person and may be subject to future change. Arundel Group Limited will only act for professional clients and eligible counter-parties. If you have any questions concerning this website please contact your independent financial adviser for advice. If you are a professional client or eligible counterparty, you may also contact Arundel Group Limited for advice. The Group does not hold client money or assets. The Group may pay part of any fees received to third party agents on terms agreed from time to time.

The SEC, FINRA and FCA have not approved or endorsed the contents of this website or any member of the Group.

No regulated services are provided in Switzerland. All services provided which are regulated in the US are provided by Arundel (Securities) Inc. All services provided which are regulated in the UK are provided by Arundel Group Limited. The FCA only regulates business undertaken by Arundel Group Limited.

Arundel (Securities) Inc. and Arundel Group Limited are wholly owned subsidiaries of Arundel Inc., a subsidiary of Arundel AG. Arundel (Mauritius) Limited is a wholly owned subsidiary of Arundel Group Limited.

All communication with clients is undertaken in English and by way of post, fax, email and telephone.

The Group does not hold client money or client assets.

Arundel Group Limited ensures that its board of directors defines, oversees and is accountable for the implementation of governance arrangements that ensure effective and prudent management of the company, including the segregation of duties in the organisation and the prevention of conflicts of interest. Its board of directors has overall responsibility for the company, approves and oversees the implementation of the company’s strategic objectives, risk strategy and internal governance, ensures the integrity of the company’s financial and accounting reporting systems, including financial and operational controls and compliance with the regulatory system, oversees the process of disclosure and communications, oversees senior management and monitors and periodically assesses the effectiveness of the company’s governance arrangements and takes appropriate steps to address any deficiencies.

Owing to the nature of Arundel Group Limited’s business, it does not have a separate chairman. There is a separate chief executive officer and chief operating officer.

Arundel Group Limited’s directors are of sufficiently good repute, possess sufficient knowledge, skills and experience to perform their duties, possess adequate, collective knowledge, skills and experience to understand the company’s activities and risks, reflect an adequate broad range of experience, commit sufficient time to perform their functions and act with honesty, integrity and independence of mind effectively to assess and challenge the decisions of senior management when necessary and effectively to oversee and monitor management decision making.

Arundel Group Limited devotes adequate human and financial resources to the induction and training of its directors. It ensures that its directors do not hold more directorships than is appropriate taking into account individual circumstances and the nature, scale and complexity of Arundel Group Limited’s activities. Arundel Group Limited does not have a nomination committee, but looks for a broad set of qualities and competences when recruiting its directors and seeks to promote diversity.

Details of the Group’s Privacy Policy are available on written request by email to rborg@arundel-ag.com

BUSINESS CONTINUITY PLAN SUMMARY STATEMENT FOR ARUNDEL (SECURITIES) INC.

BUSINESS CONTINUITY PLAN SUMMARY

Arundel (Securities), Inc. has developed a Business Continuity Plan to respond to events that significantly disrupt its business. Since the timing and impact of disasters and disruptions is unpredictable, it has to be flexible in responding to actual events as they occur. With that in mind, it is providing this information on its business continuity plan.

Contacting Arundel — If after a significant business disruption you cannot contact Arundel as you usually do at phone number (212) 332-7801 or by e-mail at: rborg@arundel-ag.com , or our alternative number (212) 332-7802, you may also access Arundel through its web site at www.arundel-ag.com If you cannot access it through these means, you should contact the Group at (011-44-20-7766-7000) for instructions on how you may be assisted.

Business Continuity Plan — The Group plans quickly to recover and resume business operations after a significant business disruption and respond by safeguarding its employees and property, making a financial and operational assessment, protecting the Group’s books and records, and allowing customers to transact business. In short, its business continuity plan is designed to permit the Group to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

The Group’s business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring customers prompt access to their funds and securities if the Group is unable to continue its business.

The Group backs up important records in a geographically separate area.

Varying Disruptions — Significant business disruptions can vary in their scope, such as only one company, a single building housing one company, the business district where one company is located, the city where one company is located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only one company or a building housing one company, the Group will transfer its operations to a local site when needed and expect to recover and resume business within eight hours of the business disruption. In a disruption affecting a business district, city, or region, the Group will transfer its operations to a site outside of the affected area, and recover and resume business within twenty-four hours. In either situation, the Group plans to continue in business, transfer operations to an executing firm if necessary, and notify you through its customer emergency number, (212) 332-7801 or 011-44-020-7766-7000, explaining how to contact the Group. If the significant business disruption is so severe that it prevents the Group from remaining in business, it will assure its customers prompt access to their funds and securities.

For more information — If you have questions about the Group’s business continuity planning, you can contact it at (212) 332-7801 or by e-mail at: rborg@arundel-ag.com

CONFLICTS OF INTEREST POLICY SUMMARY

The Group is required to manage conflicts of interest fairly and is required to disclose clearly any areas of conflict that may impact its investment activities and services.

The Group maintains a policy for managing conflicts of interest, details of which are made available to its clients on request.

This policy sets out the systems, controls and procedures that the Group has in place to manage potential conflicts of interest.

As a result of the range of investment activities carried out within the Group, there are a number of instances which may give rise to potential conflicts of interest within the organisation. Any potential conflicts of interest, and the methods by which such conflicts will be mitigated, are outlined in the engagement letters the Group executes with its clients on request.

The Group restricts personal account dealing by staff in line with regulatory requirements. Typically, staff will not be able to deal in securities issued by past or present clients without the prior written approval of the compliance officer. All staff dealing is monitored for adherence to this policy.

The Group prevents all staff from accepting gifts or entertainments worth more than US$200 without prior approval from both the compliance officer/general counsel and the chief executive officer.

Further details on these policies are available on written request by email at rborg@arundel-ag.com

Stewardship Code

In July 2010, the Financial Reporting Council published a Stewardship Code (the “Code”) which sets out indicative good practice for fund management entities when dealing with companies in which they have invested. The Code was revised in September 2012. To the extent that the Group acts as a fund manager, it is its policy to comply with the Code, save where such compliance is irrelevant or not appropriate bearing in mind the size and nature of the business undertaken by the Group.

The Group will monitor on an on-going basis investee companies in which its clients are invested. The extent of monitoring will be dependent on the size and nature of the investment. The Group will ensure that an active dialogue is undertaken when necessary to protect its clients’ investments and will intervene on the instructions of its clients where it believes such action to be necessary. The Group is willing to collaborate with any other investors where appropriate. If its clients approve, the Group is willing to be made an insider. It will seek to exercise all proxy votes following discussions with the clients as to their preference on voting. It will not automatically support the board.

Discussions are held with clients concerning the Group’s discharge of responsibilities under all investment mandates. There is no prescribed format to, and no independent audit of, the Group’s compliance with the Code. Owing to the size and nature of its business, the Group does not obtain an independent opinion on its engagement and voting processes.

Remuneration Code

Under FCA Rules, Arundel Group Limited is required to apply a remuneration code to ensure that it has risk-focused remuneration policies, processes and internal controls which are consistent with and promote effective risk management and do not expose Arundel Group Limited to excessive risk. Arundel Group Limited has a policy in place which complies with the FCA remuneration code requirements.