Regulatory Disclosure



PineBridge Global Disclosure

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GDPR

MiFID

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PineBridge Global Disclosure

PineBridge Investments is a group of international companies that provides investment advice and markets asset management products and services to clients around the world. PineBridge Investments is a registered trademark proprietary to PineBridge Investments IP Holding Company Limited.

For purposes of complying with the Global Investment Performance Standards (GIPS®), the firm is defined as PineBridge Investments Global. Under the firm definition for the purposes of GIPS, PineBridge Investments Global excludes some alternative asset groups and regional legal entities that may be represented in this presentation, such as the assets of PineBridge Investments.

Readership: This document is intended solely for the addressee(s) and may not be redistributed without the prior permission of PineBridge Investments. Its content may be confidential, proprietary, and/or trade secret information. PineBridge Investments and its subsidiaries are not responsible for any unlawful distribution of this document to any third parties, in whole or in part.

Opinions: Any opinions expressed in this document represent the views of the manager, are valid only as of the date indicated, and are subject to change without notice. There can be no guarantee that any of the opinions expressed in this document or any underlying position will be maintained at the time of this presentation or thereafter. We are not soliciting or recommending any action based on this material.

Risk Warning: All investments involve risk, including possible loss of principal. Past performance is not indicative of future results. If applicable, the offering document should be read for further details including the risk factors. Our investment management services relate to a variety of investments, each of which can fluctuate in value. The investment risks vary between different types of instruments. For example, for investments involving exposure to a currency other than that in which the portfolio is denominated, changes in the rate of exchange may cause the value of investments, and consequently the value of the portfolio, to go up or down. In the case of a higher volatility portfolio, the loss on realization or cancellation may be very high (including total loss of investment), as the value of such an investment may fall suddenly and substantially. In making an investment decision, prospective investors must rely on their own examination of the merits and risks involved.

Performance Notes: Past performance is not indicative of future results. There can be no assurance that any investment objective will be met. PineBridge Investments often uses benchmarks for the purpose of comparison of results. Benchmarks are used for illustrative purposes only, and any such references should not be understood to mean there would necessarily be a correlation between investment returns of any investment and any benchmark. Any referenced benchmark does not reflect fees and expenses associated with the active management of an investment. PineBridge Investments may, from time to time, show the efficacy of its strategies or communicate general industry views via modeling. Such methods are intended to show only an expected range of possible investment outcomes, and should not be viewed as a guide to future performance. There is no assurance that any returns can be achieved, that the strategy will be successful or profitable for any investor, or that any industry views will come to pass. Actual investors may experience different results.

Information is unaudited unless otherwise indicated, and any information from third-party sources is believed to be reliable, but PineBridge Investments cannot guarantee its accuracy or completeness.

PineBridge Investments Europe Limited is authorised and regulated by the Financial Conduct Authority (FCA). In the UK this communication is a financial promotion solely intended for professional clients as defined in the FCA Handbook and has been approved by PineBridge Investments Europe Limited. Should you like to request a different classification, please contact your PineBridge representative.

Approved by PineBridge Investments Ireland Limited. This entity is authorised and regulated by the Central Bank of Ireland.

In Australia, PineBridge Investments LLC is exempt from the requirement to hold an Australian financial services license under the Corporations Act 2001 (Cth) in respect of the financial services it provides to wholesale clients, and is not licensed to provide financial services to individual investors or retail clients. Nothing herein constitutes an offer or solicitation to anyone in or outside Australia where such offer or solicitation is not authorised or to whom it is unlawful. This website is not directed to any person to whom the publication or availability of this website is restricted.

In Hong Kong, the issuer of this document is PineBridge Investments Asia Limited, licensed and regulated by the Securities and Futures Commission (SFC). This document has not been reviewed by the SFC.

In Dubai, PineBridge Investments Europe Limited is regulated by the Dubai Financial Services Authority as a Representative Office.

PineBridge Investments Singapore Limited is licensed and regulated by the Monetary Authority of Singapore (MAS). In Singapore, this material may not be suitable to a retail investor and is not reviewed or endorsed by the MAS.

As of 6 March 2017


GDPR

PRIVACY NOTICE

This Privacy Notice explains how PineBridge (“the Company”) collects, uses and discloses your personal data, and your rights in relation to the personal data it holds.

In this Privacy Notice, “us”, “we” and “our” refers to the Company.

If you are an individual, this will affect you directly. If you are an institution that provides us with personal data on individuals connected to you for any reason, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

YOUR RIGHTS

Under the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and if you are a European data subject you have the following rights including:

  • To obtain access to, and copies of, the personal data that we hold about you;
  • To require that we cease processing your personal data if the processing is causing you damage or distress;
  • To require us to erase your personal data;
  • To require us to restrict our data processing activities;
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Data Privacy Coordinator via email: privacyofficer@pinebridge.com.

HOW WE COLLECT YOUR DATA

We may collect your personal data in a number of ways, for example:

  • From information you provide to us when you meet with one of our employees or when we communicate with you by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When we complete due diligence on you;
  • When we enter into a contract and during the provision of services;
  • From third parties.

THE CATEGORIES OF THE DATA WE COLLECT

We may collect the following categories of data about you:

  • Personal Data (including but not limited to name and contact information); and
  • Sensitive Personal Data (where you volunteer to provide such information to us)

THE BASIS FOR PROCESSING YOUR DATA, HOW WE USE THAT DATA AND WHOM WE SHARE IT WITH

1. We may process your personal data because it is necessary for our legitimate interests.

  • This may include sharing your personal data with the following:
    • other companies in our Group; and
    • third party service providers as may be necessary.
  • This may also include carrying out marketing activities, which are in our or our affiliates’ legitimate business interest.

2. We may also process your data for our compliance with a legal obligation which we are under.

3. To perform our contractual obligations to you. This may also entail sharing your personal data with companies, which assist us in performing our contractual obligations.

4. We may use your personal data to meet our regulatory obligations, with regard to conducting due diligence. In this respect, we may share your personal data with the following:

  • Our auditors where it is necessary as part of their auditing functions;
  • With relevant regulators where we are required to do so; and
  • third party service providers as may be necessary.

In sharing your personal data for the reasons set out elsewhere in this Privacy Notice, we may need to transfer it to other Group companies located in the European Economic Area as well as Switzerland, which are countries, which provide the same or a similarly adequate level of protection for your personal data as is provided within the jurisdiction in which the Company is incorporated. We may also share your personal data with Group companies located in locations including the United States of America, Hong Kong, and Japan, which do not have laws which provide the same level of protection to your personal data as are provided within the jurisdiction in which the Company is incorporated. However, these companies are subject to our Group-wide data sharing arrangements which offer a common level of protection across the Group.

RETENTION OF YOUR DATA

We may retain your personal data only for so long as is necessary for the purposes for which the personal data in collected and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy.


MiFID

Annual Best Execution disclosure - 2017