IMPORTANT LEGAL INFORMATION:  Financial or funding services are NOT being offered in the United States or to U.S. persons, company, or any kind of entity whatsoever.  The Information may not satisfy the laws of any other country and some or all of the products and services described herein may not be available to residents of some countries. The information is current at the date of publication but may be subject to change without notice.  The information contained in this website ("the Website") is issued by Global Project Capital Ltd (UK) ("GPC").  Persons who access information on the website of GPC, "we" or "us"), agree to the following terms and conditions:

NO OFFER, NO OBLIGATION:   No information published on the GPC website constitutes a solicitation or offer, or recommendation, to engage in any investment activity, to effect any transactions, or to conclude any legal act of any kind whatsoever.  The information published and opinions expressed are provided by GPC for personal use and for information purposes only and are subject to change without notice. GPC makes no representation or warranties of any kind (either express or implied) that the information and opinions expressed on the GPC website are accurate, complete or up to date.  The distribution of the information contained in the Website in certain countries may be restricted by law and persons who access it are required to inform themselves of, and to comply with, any such restrictions. The information is not intended to be published or made available to any person in any jurisdiction where doing so would contravene any applicable laws or regulations.

By accessing this Website you confirm that you are aware of the laws in your own jurisdiction relating to the provision and sale of funds and related financial services products and you warrant and represent that you will not pass on or utilise the information contained in the Website in a manner that could constitute a breach of such laws by GPC or any other person. The Website does not constitute an offer or solicitation in any jurisdiction in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such an offer or solicitation.

The Website is provided for information purposes only and does not constitute investment, legal, tax or other advice or any recommendation to buy, or sell or otherwise transact any of the Funds or stocks mentioned. Prospective participants should take appropriate professional advice before making any participation decision.  Project funding is to be made solely on the terms of the relevant customised contract and may not be consistent with information contained in the Website.

GPC makes every effort to keep the content of the Website accurate and up to date and while the information contained in the Website has been taken from sources which GPC considers to be reliable, no warranty is given that such information is accurate or complete and it should not be relied upon as such. Any opinions expressed on the Website reflect GPC's judgment at the date of issue of the relevant report and are subject to change without notice. GPC will not be responsible for any liability for loss or damage of any kind which arises, directly or indirectly, from the use of the information contained in the Website.

The value of instruments and placements may go down as well as up and may be affected by change market forces and conditions.  The Website is protected by GPC copyright. The use of any trademarks and logos displayed on the Website without GPC's prior written consent is strictly prohibited. Information on the Website may not be published or redistributed without GPC's prior written consent. GPC accepts no responsibility for the content of any external websites linked to the Website nor any products or services offered through such external websites. The use of such external websites is at the user's own risk.

GPC collects certain personal information about you such as your name, address, telephone number, email address details and other information when it is voluntarily submitted to GPC on the Website. Such information is used by GPC to ensure prudence and compliance with prevailing regulations and for internal purposes. By submitting personal information you are consenting to such information being processed by GPC for such purposes and agree that GPC has the right to use and store such data on its internal systems for the purpose of providing services to you.

GPC neither provides investment advice to, nor receives and transmits orders from, investors in those products nor does it carry on any other activities with or for such clients that constitute “MiFID and / or equivalent third country business” for regulation purposes.

LIMITATION OF LIABILITY:   GPC disclaims, without limitation, all liability whatsoever for any direct, indirect, incidental, consequential or punitive damages, losses, liabilities, expenses or costs of whatever nature which might be incurred through the use of or access to the GPC website, or any links to third-party websites. 

Code of Business Conduct and Ethics

I. INTRODUCTION:  GPC and its subsidiaries and associated companies (collectively, “GPC” or the “Company”) have maintained a reputation for conducting their business activities in the highest ethical and professional manner. Indeed, GPC’s reputation for integrity is one of its most important assets and has been instrumental in its business success. Each GPC employee, officer and director —whatever his or her position — is responsible for continuing to uphold these high ethical and professional standards.

This Code of Business Conduct and Ethics (the "Code") covers a wide range of business activities, practices and procedures. It does not cover every issue that may arise in the course of GPC’s many business activities, but it sets out basic principles designed to guide employees, officers and directors of GPC. All of our employees, officers and directors must conduct themselves in accordance with this Code, and seek to avoid even the appearance of improper behaviour. This Code is a statement of policies for individual and business conduct and does not, in any way, constitute an employment contract or an assurance of continued employment.

Any employee who violates the requirements of this Code will be subject to disciplinary action, to the extent permitted by applicable law. If you are in or aware of a situation which you believe may violate or lead to a violation of this Code or other Company policies, you should follow the guidelines described in Section XV of this Code.

II. COMPLIANCE WITH LAWS AND REGULATIONS:  GPC’s business activities are subject to extensive governmental regulation and oversight. In particular, as an investment adviser and sponsor of investment companies and other investment products, GPC is subject to regulation under numerous international regulation and securities laws in jurisdictions in which we operate. In addition, GPC is subject to regulation and oversight, as a private company and. Further, GPC provides services to a wide variety of high profile clients and foreign governments and corporations, so it may be subject to increased scrutiny.

It is, of course, essential that GPC comply with the laws and regulations applicable to its business activities. Although you are not expected to know the details of these laws and regulations, it is important to know enough about them to determine when to seek advice from supervisors and GPC’s Legal and Compliance Department (“Legal and Compliance”). You must abide by applicable law in the country where you are located. In some instances, there may be a conflict between the applicable laws of two or more countries, states, or provinces. If you encounter such a conflict, or if a local law conflicts with a policy set forth in this Code, you should consult with your supervisor or the Legal and Compliance to determine the appropriate course of action.

It is GPC’s policy to make full, fair, accurate, timely and understandable disclosure in compliance with applicable rules and regulations in all periodic reports required to be filed by the Company.

III. CONFLICTS OF INTEREST:  Your obligation to conduct the Company's business in an honest and ethical manner includes the ethical handling of actual, apparent and potential conflicts of interest between personal and business relationships. A “conflict of interest” may arise under various circumstances. A conflict of interest arises when a person’s private interest interferes, or even appears to interfere, in some way with the interests of the Company. A conflict situation can arise when an employee, officer or director takes actions or has interests that may make it difficult to perform his or her Company work objectively and effectively. Conflicts of interest arise when an employee, officer or director, or members of his or her family, receives improper personal benefits as a result of his or her position in the Company. Loans to, or guarantees of obligations of, employees, directors or their family members may create conflicts of interest.

Conflicts of interest also arise when a GPC employee, officer or director works in some manner for a competitor, client or vendor. Thus, you are not allowed to work for a competitor as a consultant or board member or in any other capacity, except as approved in writing by GPC’s General Counsel. In addition, potential conflicts of interests may arise between the interests of GPC on the one hand and the interests of one or more of its clients on the other hand. As an investment adviser and fiduciary, GPC has a duty to act solely in the best interests of its clients and to make full and fair disclosure to its clients.

Conflicts of interest may not always be clear-cut and it is not possible to describe every situation in which a conflict of interest may arise. Therefore, if you have a question, you should consult your supervisor, the Company’s General Counsel or another member of the Legal and Compliance. Any employee, officer or director who becomes aware of a conflict or potential conflict should bring it to the attention of a supervisor, manager or a member of the Legal and Compliance.

IV. CORPORATE OPPORTUNITIES:  Employees, officers and directors are prohibited from taking for themselves personal opportunities that are discovered through the use of corporate property, information or position without the consent of the Board of Directors or, in some cases, the General Counsel. No employee, officer or director may use corporate property, information, or position for improper personal gain, and no employee, officer or director may compete with the Company directly or indirectly. Employees, officers and directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

V. COMPETITION AND FAIR DEALING:  We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance, never through unethical or illegal business practices. Misappropriating proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other companies is prohibited. We should each endeavour to respect the rights of and deal fairly with the Company’s clients, vendors and competitors. No one in the course of conducting GPC’s business should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.

VI. RECORDKEEPING:  The Company requires honest and accurate recording and reporting of information in order to conduct its business and to make responsible business decisions. In addition, since GPC is engaged in a variety of financial services activities and is a private company, it is subject to extensive regulations regarding maintenance and retention of books and records. GPC’s Record Retention Policy is available on the Company’s internal website.

Generally, all of GPC’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect the Company’s transactions and must conform both to applicable legal requirements and to GPC’s system of internal controls.

Business records and communications often become public, and employees should avoid exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that can be misunderstood. This applies equally to e-mail, internal memos, and formal reports. Records should always be retained or destroyed according to the Company’s record retention policies. Finally, in the event of litigation or governmental investigations, please consult Legal and Compliance regarding any specific record-keeping requirements or obligations.

VII. DISCRIMINATION AND HARASSMENT:  The diversity of GPC’s employees is a tremendous asset. GPC is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. In particular, it is GPC’s policy to comply with the law by affording equal opportunity to all qualified applicants and existing employees without regard to race, religion, colour, national origin, sex, sexual orientation, age, disability, protected veteran status or any other basis that would be in violation of any applicable ordinance or law. All personnel actions, including but not limited to recruitment, selection, hiring, training, transfer, promotion, termination, compensation, and benefits conform to this policy. In addition, GPC will not tolerate harassment, bias or other inappropriate conduct on the basis of race, colour, religion, national origin, sex, disability, age, status as a Vietnam-era veteran or any other basis by a manager, supervisor, employee, customer, vendor or visitor that would be in violation of any applicable ordinance or law. GPC’s Equal Opportunity Policy and other employment policies are available on the Company’s internal website.

VIII. PROTECTION AND PROPER USE OF GPC ASSETS:  You should endeavour to protect GPC’s assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on the Company’s profitability. Any suspected incident of fraud or theft should be immediately reported to your supervisor or a member of the Legal and Compliance for investigation. Company technology, equipment or other resources should not be used for non-Company business, though incidental personal use may be permitted.

Your obligation to protect the Company’s assets includes its proprietary information. Proprietary information includes intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, systems, software programs, designs, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information would violate Company policy, and it could also be illegal and result in civil and/or criminal penalties. GPC’s Intellectual Property Policy details each employee’s obligation to protect GPC’s intellectual property.

IX. CONFIDENTIALITY:  Generally, GPC employees, officers and directors must maintain the confidentiality of confidential information entrusted to them by the Company or its clients, except when disclosure is authorized by the Legal and Compliance or required by laws or regulations. Confidential information includes all non-public information that might be of use to competitors, or harmful to the Company or its clients, if disclosed. It also includes information that clients and other parties have entrusted to us. The obligation to preserve confidential information continues even after employment ends. All employees of GPC have signed a Confidentiality and Employment Policy or similar policy which sets forth specific obligations regarding confidential information. Any questions regarding such Policy or other issues relating to confidential information should be directed to a member of the Legal and Compliance.

X. PAYMENTS TO GOVERNMENT PERSONNEL:  Most western oriented countries prohibits the offering or giving anything of value, directly or indirectly, to officials of foreign governments, foreign political candidates or foreign political parties in order to influence official acts or decisions, obtain or retain business or ensure an improper advantage. It is strictly prohibited to make illegal payments to government officials of any country or secure any improper advantage.

XI. WAIVERS OF THE CODE OF BUSINESS CONDUCT AND ETHICS:  The Company will waive application of the policies set forth in this Code only where circumstances warrant granting a waiver. Any waiver of this Code for executive officers or directors may be made only by GPC’s Board of Directors or a committee of the Board and will be promptly disclosed as required by law or stock exchange regulation.

XII. REPORTING ANY ILLEGAL OR UNETHICAL BEHAVIOR:  You should talk to supervisors, managers or members of Legal and Compliance about observed illegal or unethical behaviour and when in doubt about the best course of action in a particular situation. Employees in the European Union may report a concern anonymously if such concern relates to finance, financial crimes, accounting, auditing, falsification of business records, bribery and anti-corruption (or in accordance with restrictions applicable to a particular EU country).

Reports will be treated confidentially to the extent reasonably possible. Due to certain requirements under data protection laws in Europe, the Company may be obligated to inform the subject of a reported violation in Europe that the report was filed and how he or she may exercise his or her right to access and correct the information regarding the allegation. However, this right to access information does not automatically entitle the subject of the allegation to information identifying the person who reported the allegation.

GPC will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment because of a report of misconduct by others made in good faith. Employees are expected to cooperate in internal investigations of misconduct.

The General Counsel of GPC will report material violations of this Code or the policies and procedures referenced herein to the Board of Directors of GPC (or a committee thereof) and to GPC’s Office of the Chairman.

XIII. COMPLIANCE PROCEDURES:  We must all work to ensure prompt and consistent action against violations of this Code. However, in some situations it is difficult to know right from wrong. Since we cannot anticipate every situation that will arise, it is important that we have a way to approach a new question or problem. These are the steps to keep in mind:

•     Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible.

•     Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, seek guidance before acting.

      Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem.

•     Discuss the issue with your supervisor. This is the basic guidance for all situations. In many cases, your supervisor will be more knowledgeable about the question, and will appreciate being brought into the decision-making process. Remember that it is your supervisor’s responsibility to help solve problems.

•     Seek help from Company resources. In the rare case where it may not be appropriate to discuss an issue with your supervisor, or where you do not feel comfortable approaching your supervisor with your question, discuss it locally with your office manager, your Human Resources manager or a member of Legal and Compliance . If you prefer to write, address your concerns to your Human Resources manager or the General Counsel of GPC, as appropriate.

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