Terms and Conditions of Access to the Sand Aire Limited (incorporating Sand Aire (Singapore) (Pte.) Limited and Lord North Street Limited; all three hereafter referred to as “The Group”) Website (the “Terms”).
By accessing any page on this website, you agree to be bound by the Terms below.
Legal and Regulatory Information
Sand Aire Limited is authorised and regulated by the Financial Conduct Authority, (FCA number 177030). The company is registered in England and Wales and has its registered office and place of business at 105 Wigmore Street, London, W1U 1QY (Company Number 3066958).
Lord North Street Limited is authorised and regulated by the Financial Conduct Authority, (FCA number 189174). The company is registered in England and Wales and has its registered office and place of business at 105 Wigmore Street, London, W1U 1QY (Company Number 3664551).
Sand Aire (Singapore) (Pte.) Ltd. holds a Capital Markets Services Licence issued by the Monetary Authority of Singapore for conducting the regulated activity of fund management in Singapore. Sand Aire (Singapore) (Pte.) Limited is incorporated in Singapore (Company Registration No.201134113G), with its registered office at 80 Robinson Road, #02-00, Singapore 068898 and its place of business at 77A Amoy Street, #02-00, Singapore 069896.
Please note that the information set out here does not exclude or restrict any duty or liability to customers of The Group under the UK financial system.
This website is subject to the jurisdiction of the Financial Conduct Authority in the UK. As a result the website is in accordance with the compliance requirements which apply to investors who are UK residents for tax and investment purposes. The information is not intended for distribution to, nor an offer or solicitation to deal in investments in a jurisdiction, including the United States or the European Union, where such distribution would be contrary to local law or regulation.
If we give you advice, it will normally be on investments from a restricted number of products and product providers that we have considered relevant to the risk appetite of our clients . We may also give you advice, in limited circumstances and only if you have asked about specific products and product providers which we have not yet considered as suitable for the relevant risk appetite. As a result, our advice will be classified as ‘restricted’ as defined in the FCA Rules and not classified as “independent” advice as also defined in the FCA Rules. Restricted advice is advice that is not based on an analysis of products or investments from the full range of products and providers.
The value of investments and the income from them may fall as well as rise and is not guaranteed. Consequently you may not receive back the amount originally invested. Past performance is not necessarily a guide to future returns. If performance is denominated in a currency other than that of the country in which you are resident, the return may increase or decrease as a result of the currency fluctuations.
Accuracy and Content of Information
Whilst every reasonable precaution has been taken to ensure the accuracy, security and confidentiality of information available on this website, no representation or warranty (including liability towards third parties), expressed or implied, is made as to its accuracy, reliability or completeness, and no liability is accepted for any errors or omissions.
Expressions and opinions on this website represent the views of The Group which may be subject to change without notice. These views are provided for information purposes only and should not be construed as constituting investment, legal, tax or other advice nor be relied upon in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.
The information and opinions on the website are provided without any warranty of any kind, either expressed or implied, to the fullest extent permissible pursuant to applicable law and are subject to change without notice. The Group further assumes no responsibility for, and makes no warranties that, functions contained on the website will be uninterrupted or error-free, that defects will be corrected, or that the website or the services that make it available will be free of viruses or other harmful components.
Copyright and Trademarks
Copyright trademarks, database rights, patents and all similar rights on this website are owned by The Group or related parties. You may download or print a hard copy of individual pages and/or selections of the website, provided that you do not remove copyright or other proprietary notices. Any downloading or other copying from the website will not transfer title of any software to you. You may not reproduce (in whole or part), transmit (by electronic means or otherwise), modify, link or use for any public or commercial purposes the website without the prior permission of Sand Aire Limited, Lord North Street Limited or Sand Aire (Singapore) (Pte.) Limited. Nothing on this website shall be construed as granting any license or right to use any image, trademark, service mark or logo. You shall indemnify us from and against all actions, claims, proceedings, costs and damages (including any damages or compensation paid by us on the advice of our legal advisors to compromise or settle any claims and all legal costs or expenses arising from any breach by you of these copyright and trademarks.
The Group does not take any responsibility for the content of off-site pages or any other websites linked or linking to the website.
Within the Data Protection Act 2018 (UK) Sand Aire Limited and Lord North Street Limited, will act as data controller. Within the Personal Data Protection Act 2012 (Singapore), Sand Aire (Singapore) (Pte.) Limited will act as processor. The Group takes the privacy of their customers very seriously and are concerned to protect personal data. The Group will not use confidential information for any purpose other than that for which it was given. Nor will The Group reveal that information to other organisations except in the proper performance of its duties or where required to do so under compulsion of law or where requested by a regulatory agency.
A ‘Cookie’ is a small file, containing a line of code that an internet site sends to a website visitor’s computer. In some cases it is stored on the visitor’s hard drive and is erased after a fixed period of time. Cookies can save the pages viewed, but none of your personal data is sought, obtained or stored by The Group in this process.
The terms are governed and shall be construed in accordance with the laws of England. You agree that any disputes arising out of the Terms or otherwise between us shall be subject to the exclusive jurisdiction of the English courts.
Affiliates, directors, officers and/or employees of The Group may have holdings in investment companies of which Sand Aire Limited acts as ACD and Manager and of which Sand Aire Limited or Lord North Street Limited act as investment manager.
We reserve the right to change or modify the Terms at any time. If you continue to use the website you consent to the changes in the Terms.
Complaints relating to Sand Aire Limited and Lord North Street should be addressed to the Compliance Officer of the respective company at the following address: 105 Wigmore Street, London, W1U 1QY. If you are unhappy with our response, which we must have provided to you within eight weeks, you can contact the Financial Ombudsman at The Financial Ombudsman Service, Exchange Tower, London E14 9SR. For more information please review http://www.financial-ombudsman.org.uk.
Complaints relating to Sand Aire (Singapore) (Pte.) Limited should be addressed to the Compliance Officer at Sand Aire (Singapore) (Pte.) Limited at the address shown above. In addition, complaints may be addressed directly to the Financial Industry Disputes Resolution Centre Limited, 112 Robinson Road, #08-01, Singapore, 068902.
Remuneration Policy Disclosure
Under the Undertakings for Collective Investment in Transferable Securities directive 2014/91/EU (UCITS V)
FCA Regulation SYSC 19E requires any firm that is a UK UCITS management company to explain how it complies with the UCITS V remuneration requirements (the Remuneration Code).
The board of directors of Sand Aire Limited’s (Sandaire) parent company Applerigg Limited (Applerigg) is responsible for approving the Group Remuneration Policy summarised below. The Applerigg Remuneration Committee comprising the Non-Executive Directors of Applerigg has general responsibility for the oversight of the implementation of the Remuneration Policy. The Sandaire Remuneration Committee comprising the Non-Executive Directors of Sandaire will be responsible for setting the remuneration of all staff (excluding the salary of the Chief Executive Officer which will be set by the Applerigg Remuneration Committee) with support from the Chief Executive Officer.
The Applerigg Remuneration Committee consists of M Fuller, S Hill, M Houghton-Berry and C Scott none of whom has an executive function in Applerigg. The Sandaire Remuneration Committee consists of M Houghton-Berry and C Scott neither of whom has an executive function in Sandaire.
Sandaire rewards its staff fairly and appropriately for their contribution to the growth and success of the business and the provision of a high level of service to clients. The remuneration policy is designed to be consistent with, and promote, sound and effective risk management.
The remuneration of staff is reviewed annually, taking into account individual performance and market rates for the role being undertaken. Any bonus arrangement is also reviewed annually to ensure alignment with Sandaire’s aims for the growth and success of the business and the provision of a high level of service to clients. There is no direct link to investment performance and bonuses do not encourage excessive risk taking.