Web Site Terms and Conditions of Use

1. Terms

By accessing this web site, you are agreeing to be bound by these web site Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trade mark law.

2. Use License

1. Permission is granted to temporarily download one copy of the materials (information or software) on GRS Capital Partners Limited web site for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:
2. modify or copy the materials;
3. use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
4. attempt to decompile or reverse engineer any software contained on GRS Capital Partners Limited web site;
5. remove any copyright or other proprietary notations from the materials; or
6. transfer the materials to another person or “mirror” the materials on any other server.
7. This license shall automatically terminate if you violate any of these restrictions and may be terminated by GRS Capital Partners Limited at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

1. The materials on GRS Capital Partners Limited web site are provided “as is”. GRS Capital Partners Limited makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, GRS Capital Partners Limited does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet web site or otherwise relating to such materials or on any sites linked to this site.

4. Limitations

In no event shall GRS Capital Partners Limited or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption,) arising out of the use or inability to use the materials on GRS Capital Partners Limited internet site, even if GRS Capital Partners Limited or a GRS Capital Partners Limited authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Revisions and Errata

The materials appearing on GRS Capital Partners Limited web site could include technical, typographical, or photographic errors. GRS Capital Partners Limited does not warrant that any of the materials on its web site are accurate, complete, or current. GRS Capital Partners Limited may make changes to the materials contained on its web site at any time without notice. GRS Capital Partners Limited does not, however, make any commitment to update the materials.

6. Links

GRS Capital Partners Limited has not reviewed all of the sites linked to its Internet web site and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by GRS Capital Partners Limited of the site. Use of any such linked web site is at the user’s own risk.

7. Site Terms of Use Modifications

GRS Capital Partners Limited may revise these terms of use for its web site at any time without notice. By using this web site you are agreeing to be bound by the then current version of these Terms and Conditions of Use.

8. Governing Law

Any claim relating to GRS Capital Partners Limited web site shall be governed by the laws of the State of England and Wales without regard to its conflict of law provisions.

General Terms and Conditions applicable to Use of a Web Site.

Privacy Policy

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

• Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
• We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
• We will only retain personal information as long as necessary for the fulfilment of those purposes.
• We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
• Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
• We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
• We will make readily available to customers information about our policies and practices relating to the management of personal information.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

Sustainability-related Disclosures

Stewardship Code 2026

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, GRS Capital Partners Limited (“GRS” or the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy.  The Code sets out a number of principles relating to engagement by asset managers or asset owners across all asset classes including, for example, listed equity, fixed income, private equity, infrastructure investment and in investments outside the UK.

The six principles of the Code for Asset owners and Asset Managers (in our case, Asset Managers) are as follows:

Purpose and Governance:	1. Purpose, strategy and culture
	2. Conflicts of Interest & Duty to Clients/Beneficiaries
	3. Systemic Risk & Market Stewardship
	4. Governance, Oversight & Effectiveness
	5. Stewardship in Investment & Integration
	6. Engagement, Escalation & Rights

Whilst the Firm fully supports the general objectives that underlie the Code and observes high standards of corporate governance and due diligence in respect of its investments, upon consideration, it believes that the Principles are not currently applicable to its investment activities and therefore has chosen not to commit to the code at this time. The Firm will review this position annually and update this disclosure accordingly if the provisions of the Code become relevant.

The Shareholder Rights Directive II (“SRDII”)

The Directive took effect in June 2019 and falls under COBS 2.2B in the UK.  It applies, broadly, to Portfolio Managers, UCITS Management Companies and Full Scope AIFMs.  SRD requires Firms that invest in shares that trade on an UK/EU regulated market, in addition to ‘comparable’ markets outside the UK/EU, to develop and publicly disclose an engagement policy or publicly disclose a clear and reasoned explanation of why it has chosen not to comply with this requirement.

Given the similarity with the UK Stewardship Code, which is at present not deemed relevant to the type of activity undertaken by the Firm, it has been decided not to comply with SRD at the current time.  The Firm will review this position annually, in conjunction with the Stewardship Code, and any change to the current strategy of the Firm will be taken into account.

Sustainability Risk Disclosure

The EU Sustainable Finance Disclosure Regulation (“SFDR”) took effect on 10^th March 2021.  Currently, this regulation has not been onshored in the UK.  However, certain UK Firms may fall within scope as a result of their activities or Group structure or may choose to opt-in to SFDR to demonstrate a commitment to green finance and sustainability.  This requires them, under Art 3 of SFDR, to publish information on their websites about their sustainability risk policies.

At present, we have decided not to opt-in to SFDR and do not consider the adverse impacts of investment decisions on sustainability factors.  Whilst we recognise the fundamental importance of transitioning to a low-carbon, more-sustainable resource-efficient economy, we do not currently offer products which promote environmental or social characteristics, nor do we offer products promoting sustainable investments.  Our business is of a nature, scale and level of complexity that indicates that a comprehensive review of sustainability risks would not be proportionate or aligned to the types of products that we currently offer.  We will review this position on an annual basis as we are mindful that Financial Services Industry has a part to play in “making finance flows consistent with a pathway towards low greenhouse gas emissions and climate‐resilient development.

EU Sustainable Finance Disclosure Regulation (SFDR)

Unless otherwise detailed in the Prospectus of the relevant fund, the below disclosures apply with respect to EU domiciled funds managed or distributed by GRS Capital Partners Limited.

Sustainable Finance Disclosure Regulation- Integration of Sustainability Risks and Assessment of the Impact on Likely Returns

The impact of sustainability risks on the returns of the financial products have been assessed by GRS Capital Partners Limited and having considered the composition of the assets of the portfolios and the objective and policies of the financial products, it has been determined the impact of sustainability risks are not materially relevant to the returns of the financial products. For that reason, sustainability risks are not integrated into investment decisions for the financial products.

No Consideration of Principal Adverse Impacts

GRS Capital Partners Limited does not currently consider the principal adverse impacts of its investment decisions on sustainability factors in accordance with the Taxonomy Regulation. The rationale for not considering such adverse impacts is on the basis that the regulatory technical standards which will set out the content, methodology and information required in the principle adverse impact statement remain in draft form and the level two regulatory technical standards (the ”RTS”), which supplements the Sustainable Finance Disclosure Regulation, has not yet come into effect. GRS Capital Partners Limited intends to make a decision on whether it will consider the principal adverse impacts of investment decisions on sustainability factors once the RTS come into effect.

For further information on the Firm’s approach please contact the Firm’s Compliance Officer, Paul Phelan, at: pphelan@grscapitalpartners.com.