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    China update: Domestic revival gaining traction despite external headwinds

    Investors started to turn more positive towards China after the government stepped up support for the economy last September. Domestic developments in artificial intelligence (AI) had also helped to boost market sentiment. But in recent weeks, global markets – including China equities – have been upended with chaotic announcements from the US about trade tariffs on goods imports from around the globe.
    • 13 May, 2025
    • Article
    • 8 mins

    Management quality: how we identify teams built to last

    At FSSA Investment Managers, we invest in businesses we expect to be part of our portfolio for decades to come. That’s why we put such a premium on the quality of management teams, choosing leaders who we believe have the skills to build strong franchises and deliver long-term growth.
    • 13 May, 2025
    • Article
    • 4 mins

    Focusing on quality: the key to our approach in global emerging markets

    Many fund managers see high trading volumes and rapid portfolio turnover as evidence of constant re-evaluation and attention to detail. But the FSSA Global Emerging Markets (GEM) strategy favours a more patient, long-term approach, only investing in companies where we have high conviction in their prospects.
    • 09 May, 2025
    • Article
    • 4 mins

    View latest articles

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    China update: Domestic revival gaining traction despite external headwinds

    Investors started to turn more positive towards China after the government stepped up support for the economy last September. Domestic developments in artificial intelligence (AI) had also helped to boost market sentiment. But in recent weeks, global markets – including China equities – have been upended with chaotic announcements from the US about trade tariffs on goods imports from around the globe.

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This is a financial promotion for The First Sentier China Strategy. This information is for professional clients only in the UK and EEA and elsewhere where lawful. Investing involves certain risks including:

  • The value of investments and any income from them may go down as well as up and are not guaranteed. Investors may get back significantly less than the original amount invested.
  • Currency risk: the Fund invests in assets which are denominated in other currencies; changes in exchange rates will affect the value of the Fund and could create losses. Currency control decisions made by governments could affect the value of the Fund's investments and could cause the Fund to defer or suspend redemptions of its shares.
  • Single country / specific region risk: investing in a single country or specific region may be riskier than investing in a number of different countries or regions. Investing in a larger number of countries or regions helps spread risk.
  • China market Risk: although China has seen rapid economic and structural development, investing there may still involve increased risks of political and governmental intervention, potentially limitations on the allocation of the Fund's capital, and legal, regulatory, economic and other risks including greater liquidity risk, restrictions on investment or transfer of assets, failed/delayed settlement and difficulties valuing securities..
  • Concentration risk: the Fund invests in a relatively small number of companies which may be riskier than a fund that invests in a large number of companies.
  • Smaller companies risk: Investments in smaller companies may be riskier and more difficult to buy and sell than investments in larger companies.

For details of the firms issuing this information and any funds referred to, please see Terms and Conditions and Important Information.  

For a full description of the terms of investment and the risks please see the Prospectus and Key Investor Information Document for each Fund. 

If you are in any doubt as to the suitability of our funds for your investment needs, please seek investment advice.

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China equities: Keeping a long-term view

In the final article of this three-part series, Martin Lau, managing partner and lead portfolio manager of the FSSA China Growth strategy, shares the key long-term investment themes in his portfolio as the strategy celebrates its 30th anniversary this year.

China’s Covid lockdowns have lasted longer than expected, taking a toll on the economy and investor confidence. Despite this, we continued to buy high conviction companies at more attractive valuations, as we viewed the near-term weakness as temporary. China’s structural drivers are still intact, even if we don’t return to the heady growth of 10 to 20 years ago. The companies we invest in should benefit from trends such as rising incomes and wealth, increasing demand for premium goods and services, and growing sophistication in technology and manufacturing.

The chart below shows how a long-term trend can endure. Since the 1990s economic reforms, China’s role in global trade continues to increase, beyond Japan’s peak in the mid-1980s. This bodes well for exports as well as consumption, which is partly a result of China becoming wealthier from selling to other countries. But as the availability of cheap labour fades, there is a growing need for Chinese companies to innovate and move up the value curve. 

China has become a bigger part of global trade while Japan has faded

Source: WDI, CICC, FSSA Investment Managers, December 2022. 

To give us an idea of the growth runway for Chinese companies, we compared the revenue of a few of our holdings with their global peers. For example, Nike is a global company and considered to be the best sportswear company in the world. In China, we believe ANTA Sports is the best sportswear company domestically. A side-by-side comparison implies that there is plenty of room for ANTA to grow.

Global winners - revenue comparison (2021, USD billions)

Source: Bloomberg, FSSA Investment Managers, December 2022. 

Likewise, we believe that the best pharmaceutical company in China is Jiangsu Hengrui; the best automation company in China is Shenzhen Inovance; and the best medical equipment company in China is Shenzhen Mindray. We like these companies for fundamental reasons. It has nothing to do with government policies, property measures, interest rates, the state of the economy, or GDP growth. Rather, it’s based on their ability to gain market share, earn higher margins, create more valuable brands, and having strong management and alignment.

Below we discuss these companies in more detail, and why they are likely to remain as our long-term holdings. 

 

Industrial automation aims to offset shrinking workforce

China’s automation market enjoys strong secular tailwinds, given labour shortages and the government’s goal to become self-sufficient in “hard technologies”. China’s working age population is declining due to the earlier one-child policy. From 2022 to 2050, China’s workforce – people aged between 15 and 64 – will contract by 22% or 217m people, according to United Nations (UN) projections.  There is increasing demand for robotic equipment as well as components that can improve efficiencies or improve the production process. With this in mind, we have been closely following companies in industrial automation and general automation for a number of years.

Annual installations of industrial robots in China (1,000 units)

Source: International Federation of Robotics, FSSA Investment Managers, December 2022. 

We own Shenzhen Inovance, an industrial automation company with leading positions in inverters, servo motors and new energy vehicle (NEV) controllers. The ownership and alignment are strong, with a dedicated founder team that has grown Inovance from a small inverter maker into China’s most successful automation company.

Inovance has repeatedly proven its capability in developing new products and entering new markets, where it can compete with multi-national peers. The company has generated 28% per annum shareholder returns since its IPO in 2010, with 40% compound annual growth rate (CAGR) in sales and 35% net profit CAGR. Despite its size, we think Inovance can continue to generate attractive growth over the next 5-10 years, as it gains market share and continues to innovate.

Another example is Airtac, the second-largest pneumatic components supplier in China with around 25% market share. Demand for pneumatic components is also driven by industrial automation. Airtac is a rare type of Taiwanese company, one which has built its own channels and brands to compete with global companies like SMC, rather than focus on manufacturing for third-party companies. The chairman seems to be clear in his goals, treats employees well and positions for long-term growth by identifying attractive markets. Airtac is also moving into linear guides, which he believes are a stepping stone to larger, high-end pneumatic customers, as there is a big customer overlap between the two businesses. Over the longer term, we expect 10-15% growth per year. 

 

Leading healthcare companies stand to gain market share

Healthcare spending in China is much lower than in developed countries, and should continue to grow with the ageing population. The 65-plus population will increase from 14% of the total in 2022 to 30% in 2050, according to UN estimates. In the healthcare sector, we own pharmacy businesses, independent contract laboratory (ICL) companies, and medical device manufacturers.

The pharmacy sector is highly fragmented, but we think consolidation is likely and the industry leaders would benefit. There are 1,200 pharmaceutical companies in China and the largest two, Jiangsu Hengrui and Sino Biopharm, have 3.1% market share each, followed by 2.7% share for CSPC (we own all three companies). By comparison, the global pharmaceutical sector is also fragmented, but leaders tend to hold 5-6% market share.

We also hold Shenzhen Mindray, China’s largest domestic medical devices company and a market leader in patient monitors and life support systems. The company has been gaining market share from global leaders as it expands its presence overseas, with more than 40% of its sales through exports. Meanwhile, the penetration level of medical devices in China is still low and there is a growing preference for import substitutions.

 

Domestic brands may benefit from premium consumption

China’s easing of Covid restrictions is gathering momentum. This should enable a return to structural growth in consumption and tourism. Amid the weak consumer demand over the past two years, we have focused on buying the higher quality franchises and market leaders. This means companies with above-average margins and returns, and the ability to premiumise and raise selling prices.

For example, China’s beer market is different from most, as beer volumes have been in decline since 2014. On the other hand, as the economy and middle class have grown, so has the opportunity in premiumising and improving unit economics. China Resources Beer (CRB) is the largest beer company in China, with around 30% market share. The Chinese beer market is highly consolidated, with the top three companies (CRB, Tsingtao and Anheuser-Busch Inbev) sharing 75% of the market. As a result, competition is rational and measured.

Despite tepid sales, margins and profitability have improved as beer companies consolidated their breweries. CRB’s share of premium sales has grown with help from a 2019 merger with Heineken China, resulting in higher average selling prices (ASP). Although the company is a State-Owned Enterprise (SOE), China Resources businesses have typically been well run, with returns comparable to private enterprises. 

ASP has grown consistently

Source: Company filings, FSSA Investment Managers, as at 30 June 2022. 

As China’s reopening gathers momentum, we expect people to return to a more active and sporty lifestyle. This should benefit Anta, China’s most successful sportswear company, and one of the few Chinese companies that has proven its ability to build and run multiple strong consumer brands. In the longer term, sportswear consumption in China has the potential to increase as incomes rise, judging from the per capita spending on this segment in Japan and South Korea. 

Sportswear consumption per capita in 2021 (USD)

Source: Euromonitor, J.P. Morgan, FSSA Investment Managers, as at 30 June 2022. 

Few companies know Chinese consumers better than Anta, as its direct retail sales and data- and survey-driven consumer analytics bring the company much closer to its customers. We believe the “Anta System” that enabled FILA’s success can be replicated across its other brands as well. As long as Anta can attract new customers (with Kids, Fusion and its performance sportswear range, as well as more efforts to target the underrepresented female customer segment), we believe it can prolong its brand life-cycle and continue to grow sales.

 

As always, the key for us is quality

While much about China has changed over the last 30 years, our investment process remains the same. The key for us has always been the quality of the business and management, backed by structural growth drivers.

So what will the next 30 years look like for China? Drawing upon the parallels in Japan, Olympus, Komatsu, and Sony have become world-class companies; we would expect some of China’s domestic champions to reach similar levels of competence and acclaim. Meanwhile, the median age in Japan is now 49 years, compared with 38 in China, and Japan’s average life expectancy is 85 years, compared with 78 years in China. As China’s economy matures and its people grow older, it could heed a few other lessons from Japan’s experience – like how to age gracefully, with growing wealth, wisdom and happiness.

 

Source: Company data retrieved from company annual reports or other such investor reports. Financial metrics and valuations are from FactSet and Bloomberg. As at February 2023 or otherwise noted.

 

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Martin Lau

Managing Partner

01 March, 2023

  • Greater China

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Meeting companies amid China’s post-Covid rebound

Following on the FSSA China Growth strategy’s 30th anniversary, we sat down with our China portfolio managers Martin Lau, Winston Ke and Helen Chen to respond to recent questions from investors. In this Q&A, they discuss market valuations, inflation, geopolitics and recent company visits.
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In the second article of this three-part series, Martin Lau, managing partner and lead portfolio manager of the FSSA China Growth strategy, discusses the importance of keeping a long-term mindset and valuation discipline as the strategy celebrates its 30th anniversary this year.
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References to specific securities should not be construed as investment advice or a recommendation to buy or sell the same.

Source: Company data retrieved from company annual reports or other such investor reports. Financial metrics and valuations are from FactSet and Bloomberg. As at February 2023 or otherwise noted.

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This document has been prepared for informational purposes only and is only intended to provide a summary of the subject matter covered and does not purport to be comprehensive. The views expressed are the views of the writer at the time of issue and may change over time. It does not constitute investment advice and/or a recommendation and should not be used as the basis of any investment decision. This document is not an offer document and does not constitute an offer or invitation or investment recommendation to distribute or purchase securities, shares, units or other interests or to enter into an investment agreement. No person should rely on the content and/or act on the basis of any material contained in this document.

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10. Liability: No warranty is given that the contents of this Website are compatible with all computer systems or browsers or that this Website shall be available on an uninterrupted basis. First Sentier Investors does not accept any liability for any damages or losses arising from changes or alterations made to this Website by unauthorised third parties.

The internet is not a completely reliable transmission medium and neither First Sentier Investors nor any of its affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from First Sentier Investors or any of its affiliates. Any such transmission of information is entirely at your own risk and any material downloaded from this Website is downloaded at your own risk.

The information on this Website is provided “as is”. To the extent permitted by law, First Sentier Investors, its affiliates and its and their directors, officers, employees and agents expressly exclude all conditions, warranties, representations and other terms which might otherwise be implied by statute, common law or the law of equity. First Sentier Investors and its affiliates will only be liable to you in respect of any direct losses arising from your use of, or inability to use, this Website in the event of First Sentier Investors’ gross negligence, wilful default or fraud. In no event will First Sentier Investors or any of its affiliates be liable to any person for any indirect, special or consequential damages arising out of any use of, or inability to use, this Website or the information contained on it or on any other hyper-linked site including, without limitation, any lost profits, business interruption, loss of programs or data on your equipment or otherwise, even if First Sentier Investors is expressly advised of the possibility or likelihood of such damages. This does not affect First Sentier Investors’ liability for any loss or damage which cannot be excluded or limited under applicable law.

Nothing in these Terms is intended to exclude or restrict any duty or liability that First Sentier Investors has to its clients under applicable local regulatory rules or which may not be excluded or restricted as a matter of applicable law. 

11. Access: First Sentier Investors reserves the right to suspend or withdraw access to any page(s) included on this Website without notice at any time and accepts no liability if, for any reason, these pages are unavailable at any time or for any period. 

12. Compliance with Law and Regulation: When using this Website you must comply with all applicable local, national and international laws including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on this Website in certain countries and First Sentier Investors, its affiliates and its and their directors, officers, employees and agents disclaim all responsibility if you download any information from this Website in breach of any law or regulation of the country in which you reside. 

13. Intellectual Property: 

(a) Unless otherwise specified, First Sentier Investors is the owner or the licensee of all intellectual property rights in and to this Website, its content and the information, imagery and data published on it including but not limited to copyright and trade mark rights (whether registered or unregistered). Those works are protected by copyright laws and treaties around the world. All such rights, save as expressly granted, are reserved. 
(b) Notwithstanding paragraph (a) above, no warranty or indemnity is given that the use of the Website, or any information or material taken or downloaded from the Website will not infringe the intellectual property rights of any third party. 
(c) Reproduction in any form of any part of the content, information, imagery or data from, or underlying, this Website, save for in strict compliance with these Terms, is prohibited without the prior written consent of First Sentier Investors. All such intellectual property rights shall continue to be held by First Sentier Investors or its licensors and no rights of any kind in such rights shall pass to you. 
(d) The information held on this Website is for your own personal use only. You may print off or download copies of, or extracts from, pages from this Website for your personal reference but you must not modify those copies or extracts in any way. First Sentier Investors (and any identified contributors), as the authors of material on this Website, must always be acknowledged. 
(e) Notwithstanding paragraph (d) above, to the extent that you are a financial advisor, you may use the information available on this Website and provide copies of documents available on the Website to make recommendations to your clients, however such information is not intended for direct use by members of the public. 
(f) Any unauthorised downloading, re-transmission or other copying or modification of any of the contents of the Website may be in breach of statutory or common law rights which could be the subject of legal action. First Sentier Investors disclaims all liability which may result from any unauthorised reproduction or use of the information on the Website. 
(g) All trade marks, service marks, company names or logos are the property of their respective holders. The display of any trade names or trade marks on the Website does not imply that any licence has been granted to any third party in respect of the same. Any use by you of these marks, names and/or logos may constitute an infringement of the holders’ rights. 

14. The Internet: Please note that there is no guarantee that any e-mail sent by you will be received by us, or that the contents of any such e-mail will remain private during internet transmission. Any information is sent at your own personal risk. 

15. Data Protection: Please see our Privacy Notice for information relating to how First Sentier Investors and other companies associated with it protect your personal data. In agreeing to these Terms you agree to the terms of our Privacy Notice. 

16. Cookies: Cookies are small data files that are sent to and stored on your computer, smartphone or other device used to access the internet, whenever you visit a website. We use cookies to enable and improve certain functions on our website and gain feedback on how our website is used. If you choose to switch certain cookies off, it will affect how our website works.

Cookies are useful because they allow a website to recognise the device you are using. As the First Sentier Investors group are based in various jurisdictions and operate different websites for each regional business, we use your IP address to identify your location, and use cookies to store general information such as the region where you are based, the language the site is being viewed in (for example English, Chinese) and the type of client you are. This helps us to tailor our website to better suit your requirements. The Cookies we use here are ‘session’ cookies and will be removed every time you leave our website.

When you browse this website, you do so on the basis of these Terms and Conditions, a Cookie may set if you have accepted them. This can mean that you don’t have to re-accept them on every visit. This type of cookie is ‘persistent’ as they remember your preferences. Every time we amend our Terms and Conditions, or on an annual basis, a new Cookie will be set and you will be asked to re-accept our Terms and Conditions.

We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. These Cookies are ‘session’ cookies.

The browsers of most computers, smartphones and other web–enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences. 
However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work.

More information about cookies can be found on allaboutcookies.org

17. Amendment: First Sentier Investors may delete or make changes to these Terms and to the information contained on this Website at any time. Where we make any changes to these Terms, you will be required to accept such changes in order to continue to use the Website. If you do not accept such revised Terms, you may no longer be able to access this Website.

If any provision of these Terms is found by any court or authority of competent jurisdiction to be illegal, void or invalid under the laws of any jurisdiction, the legality, validity or enforceability of the remainder of these Terms in that jurisdiction shall not be affected and the legality, validity and enforceability of the whole of these Terms in any other jurisdiction shall not be affected. 

18. Third Parties: First Sentier Investors’ affiliates shall have the benefit of the rights conferred on them by these Terms but otherwise no person who is not a party to these Terms may enforce its terms. 

19. Applicable Law: These Terms and any non-contractual obligations arising from or connected with them shall be governed by, and these Terms shall be construed in accordance with, the laws of Ireland. 

20. Jurisdiction: You agree that the Irish courts shall have exclusive jurisdiction in relation to any legal action or proceedings arising out of or in connection with these Terms (whether arising out of or in connection with contractual or non-contractual obligations) (“Proceedings”) and waive any objection to Proceedings in such courts on the grounds of venue or on the grounds that Proceedings have been brought in an inappropriate forum. You further agree that this paragraph operates for the benefit of First Sentier Investors and accordingly First Sentier Investors shall be entitled to take Proceedings in any other court or courts having jurisdiction. 

21. Contact Us: If you have any enquiries in relation to this Website or the information on it, please contact First Sentier Investors at enquiries@firstsentier.com  

By clicking “I Agree” you: 

(1) represent, warrant and undertake to us that you are resident in the country selected when entering this Website; 
(2) confirm that you have read and understood the Terms and agree to abide by them on every occasion that you access this Website;  
(3) confirm that you are accessing this Website in compliance with the laws and regulations of your jurisdiction; and
(4) confirm you have read and understood our Privacy Notice.

Please click the "I have read and agree to the above information" button below if you have read and understood this page and agree to abide by its contents, otherwise click "Cancel" to leave the website.

 

2. PRIVACY NOTICE

First Sentier Investors

Background

This Notice gives information on how the First Sentier Investors group of companies collect, use and protect the personal data held about investors, clients, intermediaries and other business contacts.

This Notice describes how we will fulfil our obligations under applicable data protection laws.

 

Information about us

References in this Notice to First Sentier Investors will include the following companies as well as the EU and UK based group company investment funds that they manage (as applicable):

First Sentier Investors (UK) Funds Limited* 
First Sentier Investors (UK) IM Limited* 
First Sentier Investors (UK) Services Limited
First Sentier Investors UK Holdings Limited
First Sentier Investors International IM Limited
*
First Sentier Investors (Ireland) Limited**

(together “we”, “us” or “our”)

*Authorised and regulated by the Financial Conduct Authority of the United Kingdom

**Authorised by the Central Bank of Ireland

 

Information we may collect

First Sentier Investors collects from time to time, personal data on investors, clients, intermediaries and other business contacts from a number of sources, including from: investor application forms; other First Sentier Investors forms (including website forms); client investment management agreements; correspondence, conversations with clients, advisers, intermediaries; business cards; third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents); client advisers; other third parties; and from public sources.  This information may be collected directly from investors, clients, intermediaries and business contacts, or indirectly from third parties, as follows:

From you

We may collect from you and process the following personal data, depending on the nature of our business relationship with you:

  • Your name; address (including proof of name and address); photo identification; contact details both personal and work (for example, your email and phone numbers); hobbies and interests; job title and company; nationality; citizenship; tax residency; date of birth; passport details; national insurance number and other tax details; adviser details; investment details; banking details; signed contracts with you; business cards, contact sheets and biographies; financial dealings; family connections; details of your company’s directors, secretaries, authorised signatories and identification documents; details of any complaints made; data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); responses to surveys and competitions; fraud enquiries (for example, information from police reports); images captured by CCTV cameras on our premises; recordings of telephone conversations and electronic communications with our staff.
  • By the use of cookies on this site in accordance with our Cookies Policy set out below.

From third parties

We may collect personal data about you from third parties, depending on the nature of our business relationship with you, in particular:

  • Third party service providers to our funds (for example, transfer agents, registrars, administrators, distributors, custodians and paying agents) – information received includes personal details of investors obtained from fund application forms such as: name; address; contact details; nationality; national insurance number; date of birth; tax residency; adviser details; investment details; bank account details. 
  • Your advisers (including independent financial advisers) – information received may include your name, address, gender, date of birth; bank details.
  • Our vendors such as Experian and World-Check – information received includes the results of “Know Your Client”, anti-money laundering, politically exposed persons and sanctions checks.
  • Publically available sources such as MandateWire and LinkedIn – information available includes contact details of institutional investors (MandateWire) and details of job title, company, former employers and roles, and connections (LinkedIn).

 

How we will use the information we collect

The information we collect and use will depend on the nature of our business relationship with you, as follows:

  • In relation to prospective investors and clients, we may process personal data for identification purposes (prior to becoming an investor in our funds or a client of ours under an investment management agreement), for the purposes of anti-money laundering, counter terrorist financing, suitability and appropriateness assessments, “Know Your Client” and credit-worthiness checks, and for any other applicable legal or regulatory reasons.  Failure to provide relevant information will mean that we will not be able to on-board a potential investor or client.
  • In relation to investors in our funds, we may process information collected for the purpose of account administration and other general business purposes (for example, for processing subscriptions and investments; maintaining the share register of investors, carrying out investor instructions; handling any complaints and enquiries; sending investor communications, including financial reports, valuations, corporate actions).  In addition, in order to comply with regulatory obligations, we may collect and disclose certain information about our investors and certain related persons and their investments to HM Revenue & Customs and/or other relevant tax authorities overseas. 
  • In relation to our investment management clients, we may process personal data for the purpose of managing and administering clients’ accounts, including providing valuations and periodic reports and informing clients of relevant information as required by the investment management agreement.
  • We may from time to time process personal data of investors and clients to comply with legal and regulatory requirements impacting our business.  In particular, we may need in the context of our business: to obtain legal advice on legal and regulatory requirements; to report to relevant regulators; to comply with market opening and registration requirements in the conduct of our business.
  • In relation to intermediaries who introduce investors into our funds (such as distributors, platforms and independent financial advisers), we may process personal data to conduct market research, gauge product sales or product performance or assess the creditworthiness of intermediaries.  In addition, we may process the personal data of investors introduced to our funds, as outlined above.
  • In relation to our general business contacts (including consultants and intermediaries who act for our mutual clients), we may process personal data for general business purposes such as: for public relations and corporate communications purposes; providing thought leadership articles; networking/relationship building; conducting market research and gathering industry statistics; evaluating products and services; and assisting with any queries.
  • Monitoring purposes: we may process personal data to analyse the performance of IT systems, monitor usage of resources and systems and to improve products, services and usability of our technology platform, including telephone calls and electronic communications with our staff which may be recorded for the purposes of retaining a record of communications, in the interests of security, for training and compliance monitoring purposes and/or to comply with legal or regulatory obligations.
  • Where you have provided your consent, we may process your personal data for the purposes of informing you (for example, by telephone, mail and email) about other products and services available from the First Sentier Investors group of companies and of marketing campaigns and event invitations.

We are entitled to use your personal data in these ways because:

  1. We have legal and regulatory obligations that we have to discharge;
  2. We may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  3. The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates);
  4. The use of your personal data is necessary for the performance of a contract with you;
  5. You have provided your consent to us processing your personal data (other than for marketing purposes); or
  6. You have provided your consent to us processing your personal data for the purposes of informing you (for example, by telephone, mail or email) about other products and services available from the First Sentier Investors group of companies and of marketing campaigns and event invitations.

 

Disclosure of your information

  • We may disclose your personal data to any member of the First Sentier Investors group, which means our affiliates, for internal business and administrative purposes (including to administer our products and services and for prudential and risk management purposes) and, where you have given your consent, to provide you with information on related products and services.  We may also disclose personal data relating to our clients to members of our group to whom we sub-delegate our services (for example, trade order execution and portfolio management). 
  • We may disclose your personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us.  The following is a list of the types of third parties who process your personal data on our behalf:
  1. third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents and researchers). These third party service providers may also disclose and transfer your personal data to their affiliates or other third party contractors;
  2. credit reference agencies, debt collection agencies and other companies for use in credit decisions, for fraud prevention, to pursue debtors and for the verification of identity;
  3. document execution vendors in relation to the execution of contracts with our clients;
  4. insurance brokers;
  5. professional advisers (for example, accountants/tax advisors and legal advisors).
  • If you use a financial adviser (as indicated on your investor application form), then details of your investments and valuations may also be provided to such financial adviser.
  • We may disclose to relevant tax authorities, regulators, government departments or competent authorities of the UK or of other countries, any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) in order to comply with a court order or to meet legal and regulatory requirements arising in the conduct of our business.  Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf. 

 

Transfers outside the EEA

We may transfer your personal data to our overseas affiliates (including outside the EEA) and/or allow the information to be accessed by our affiliates and their employees outside the EEA as well as within in.  It may also be processed by personnel operating outside the EEA who work for us or for one of our third party service providers. 

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA or that the transfer is otherwise compliant with data protection laws.  This can be done in a number of ways, for example:

  • the country that we send the data to might be approved by the European Commission;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
  • where data protection laws permit us to transfer your personal data outside the EEA.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a sample copy of the model contractual clauses) by contacting infoUK@firstsentier.com

 

How long will we store your data?

Personal data held by us will be kept confidential.  How long we hold your personal data for will vary and will be determined by various criteria, including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

 

Your rights in relation to your data

If you wish to contact us for any of the reasons below, please e-mail us at infoUK@firstsentier.com

  • You have a right to access the information which we hold about you.  If you wish to make an application to access or obtain this information, please contact us.  In some circumstances, you have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible.  Please note that this right only applies to personal data which you have provided to us.
  • We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date. Please contact us if any of the details you have provided change.  Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.
  • If you wish us to erase or restrict using your data, please contact us.  We may need to discuss with you the basis of your request as there may be circumstances where we are legally entitled to continue processing your personal data/refuse your request.
  • If you have previously provided your consent to our use of your data (other than for marketing purposes) and you wish to withdraw such consent, please contact us.  We may need to discuss with you whether our use of your data needs to continue for lawful purposes (i.e. because we have another legitimate reason (other than your consent) for doing so).
  • If you have previously consented to being sent information about other products and services available from the First Sentier Investors group of companies, you may withdraw such consent by contacting us.
  • If you have any complaints in relation to the way we have used your information, please contact us in the first instance.  If you are based in the UK you also have the right to lodge a complaint with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel: 0303 123 1113) or, if you are based in the EU or EEA, the Irish Data Protection Commission at 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (Tel: +353 578 684 800) if you think that any of your rights have been infringed by us.

Other Products and Services

If you would like to receive further information from us about other products or services offered by First Sentier Investors group, please ensure you tick the relevant box on the appropriate application form or contact us by e-mailing us at infoUK@firstsentier.com

 

Links to other web sites

Our web site may contain links to non-First Sentier Investors web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.

Recording of telephone conversations and electronic communications

Please note that we are required to record telephone conversations (we will do so without a warning) and to keep copies of electronic communications.  We are required to keep copies of these recordings and electronic communications for a period of five years (or up to seven years at the request of a regulator).  Copies may be provided to you upon request by contacting infoUK@firstsentier.com  

Changes to our Privacy Notice

This Notice was updated in September 2021.  We reserve the right to change this Notice at any time. We will ensure that any changes to this Notice are added to the Notice available on our website on their effective date. 

 

3. Cookies Policy

Cookies are small data files that are sent to and stored on your computer, smartphone or other device used to access the internet, whenever you visit a website. We use cookies to enable and improve certain functions on our website and gain feedback on how our website is used. If you choose to switch certain cookies off, it will affect how our website works.

Cookies are useful because they allow a website to recognise the device you are using. As the First Sentier Investors group are based in various jurisdictions and operate different websites for each regional business, we use your IP address to identify your location, and use cookies to store general information such as the region where you are based, the language the site is being viewed in (for example English, Chinese) and the type of client you are. This helps us to tailor our website to better suit your requirements. The Cookies we use here are ‘session’ cookies and will be removed every time you leave our website.

When you browse this website, you do so on the basis of these Terms and Conditions, a Cookie may set if you have accepted them. This can mean that you don’t have to re-accept them on every visit. This type of cookie is ‘persistent’ as they remember your preferences. Every time we amend our Terms and Conditions, or on an annual basis, a new Cookie will be set and you will be asked to re-accept our Terms and Conditions. 

We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. These Cookies are ‘session’ cookies.

We use marketing automation cookies placed by Pardot and Salesforce. Pardot tracks visitor and prospect activities on our website and landing pages by setting cookies on your browsers. Cookies are set to remember preferences (like form field values) when you return to our site following a previous visit. Pardot also sets a cookie for logged-in users to maintain the session and remember table filters.

Pardot sets first-party cookies for tracking purposes, to allow us to improve our content, and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the marketing automation industry. Pardot cookies don’t store personally identifying information, only a unique identifier. Pardot sets first-party cookies on tracker subdomains and Pardot domains. 

We use remarketing cookies to allow us to match external advertising messages with the pages that you have visited on our website, with the intention of providing you follow-up information. You can opt-out of this service by visiting the Network Advertising Initiative opt-out page.

The browsers of most computers, smartphones and other web-enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the "Help" menu of your browser to learn about how to change your cookie preferences.

However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work. More information about cookies can be found on allaboutcookies.org

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