Skip to main content

FSSA Investment Managers

  • Home
  • About us

    Operating as an autonomous team within the First Sentier Investors Group, we are bottom-up investors, using fundamental research and analysis to construct high-conviction portfolios. 

    • Our philosophy
    • Our team
    • Careers
    FSSA-balloons-asia.png

    Download our core beliefs

    Read more

  • Our approach

    As responsible, long-term shareholders, we have integrated ESG analysis into our investment process and engage extensively on environmental, labour and governance issues. 

    • Climate change
    • Carbon footprint
    • Exclusion policy
    fssa-esg-report-2023.jpg

    View our latest ESG report

    Read more

  • Insights

    By region

    • Greater China
    • Asia Pacific
    • Indian Subcontinent
    • Global Emerging Markets

    Latest insights

    The biggest competitive advantage an investor can have is time

    In the 1960s, the average holding period for a stock was over eight years. Today, it’s less than six months. But with less time in the market, the narrow band of return dispersion means that many investors end up tracking the index, not beating it.
    • 30 June, 2025
    • Article
    • 6 mins

    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

    View latest articles

    2191032597

    The biggest competitive advantage an investor can have is time

    In the 1960s, the average holding period for a stock was over eight years. Today, it’s less than six months. But with less time in the market, the narrow band of return dispersion means that many investors end up tracking the index, not beating it.

  • Our funds

    lanterns.jpg

    Greater China

    Read more

    junk-sailing.jpg

    Asia Pacific

    Read more

    fabric.jpg

    Indian Subcontinent

    Read more

    silk.jpg

    Global Emerging Markets

    Read more

  • Performance and documents

    Latest fund price and performance, documents and factsheets for our range of actively managed funds

    • Price and performance
    • Documents and factsheets
    China-temple-teaser.png

    Price and performance

    Read more

  • First Sentier Investors
  • Contact us
  • Netherlands/Professional Investor

Important Note Click to maximise
Important Note I have read and agree, click to minimise

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.

FSSA-China-Growth.jpg
  1. Insights
  2. Greater China

China Equities: Back in the doldrums? 

After Chinese stocks rallied upon the abrupt end to pandemic lockdowns in late 2022, pessimism has taken hold of the markets again. This time, concerns include the uneven post-Covid recovery, uncertainty around stimulus and weak external demand. While we can see robust recoveries in service sectors such as catering, travel and hospitality, the manufacturing and property sectors need more time to revert to their pre-Covid strength. The same goes for consumer confidence, as urban households’ property and financial assets have declined in value while youth unemployment rose above 20%.1

Estimated change in Chinese urban households' assets

Note: High-risk financial assets include stocks, funds, and trusts; low-risk financial assets include wealth management, deposits, and insurance. Other assets include automobiles, and operating assets such as shops, factories, and equipment.

Source: CICC, FSSA Investment Manager as at Jun 2023.

Despite the sluggish recovery, we think the underlying fundamentals of our portfolio holdings remain strong. 

Additionally, valuations have become cheaper again, and we see the recent market weakness as a buying opportunity.

MSCI China Index’s price-to-earnings (trailing 12 months and 10-year average)

Source: Factset, FSSA Investment Managers. As of 5 July 2023.

Investing in China’s dynamic market comes with an evolving set of challenges and opportunities. Today, the key challenges include shifts in geopolitics, policy priorities and demographics. In the shorter term, weak consumer confidence and rising unemployment have been additional areas of concern. 

But we also see an attractive opportunity set in a unique market. We have been impressed by the improving quality of Chinese companies and management over the years. In the context of emerging markets, China has a stable government and political order, although its authoritarian nature draws controversy. And as the second largest stock market globally, it is highly regulated and deeply liquid.

Number of listed companies with over USD500m market cap

Note: Chinese ADRs are American depository receipts for Chinese companies. 

Source: CLSA, FSSA Investment Managers, as at 30 June 2023.

Listed companies which doubled profit after tax (PAT) in last 5 years

Source: CLSA, FSSA Investment Managers, as at 30 June 2023. 

Finding growth in a more mature market

We have heard concerns around China’s slowing economy, including the potential to miss the 5% GDP growth target for 2023. We expect China to deliver steady albeit lower growth than before, given it is a more mature market. In this context, we can still find industry leaders who benefit from gaining market share over weaker rivals, or companies improving their returns and expanding their customer markets. 

If we look at some of the most successful companies across the world, like Procter & Gamble, Estee Lauder and Nestle, their profits do not grow 20-30% every year. Rather, they generate steady profits and reward shareholders with value over the long term. Similarly, we look for companies in China which can generate 10-15% annual growth on a sustainable basis, and have returns on equity (ROE) in the mid-teens or higher.

China’s GDP growth, YoY %

Source: National Bureau of Statistics, Bloomberg as at June 2023.

China’s falling birth rate and ageing population are also top-of-mind for the market. But while the Chinese people may be getting older, they are also getting richer. According to Boston Consulting Group, China’s middle class and affluent populations will grow by over 80 million during 2022-30, to account for 40% of the country’s total. The May 2023 study also found Chinese consumers are willing to trade up across many product categories, including fresh & organic foods, health care, personal & home care, electronics, sports gear and beauty products. 

In a separate study from 2021, McKinsey forecasted consumers in the upper-middle brackets (those with annual household incomes from RMB160,000 to RMB345,000) will drive 60% of China’s urban consumption by 2030, while the “affluent” segment above them will drive another 20%. 

Urban consumption % by income group (Annual household income in RMB, 2020 real)

Source: McKinsey & Company, as at November 2021. 

Our China equity strategies are invested in many areas likely to benefit from this structural trend — dominant consumer franchises, such as Anta Sports and Midea Group, amid a growing preference for domestic brands; drugs and medical services companies like CSPC Pharmaceutical and Shenzhen Mindray, which may benefit from rising spend on healthcare; well-managed and conservative banks like China Merchants Bank and Bank of Ningbo which are tapping into the growth in wealth management; and technology champions in niche markets, such as Shenzhen Inovance and Advantech, which may benefit from increasing industrial automation and localised production.

To highlight an example, China Merchants Bank (CMB) was the first joint-stock commercial bank to focus on retail and high-net-worth customers in the early 1990s. Its retail banking business has grown to 184 million customers, with assets under management of more than RMB12 trillion — predominantly from its Sunflower (mass affluent) and private banking customers. 

The company plans to continue building its wealth management business and focus on value creation for shareholders and other stakeholders. Despite being controlled by a central state-owned parent, China Merchants Group, it is seen as the most market-oriented bank in China. It also has the highest return on assets (1.4%) and return on equity (18%) in the industry, thanks to its low funding cost, lean business model and strong fee income franchise.

CMB also has a prudent risk management mind-set and the highest coverage ratio in China. Its loan growth has been in line with China’s industry average, but its deposit growth is the highest among all the major banks. Unlike its peers, CMB’s deposits are growing faster than its loans, which means it controlled its loan growth to focus on the quality of lending.

Retail CASA ratio² and funding cost

Note: CASA ratio is the ratio of deposits in current and savings accounts to total deposits.

Source: Company reports, FSSA Investment Managers, as at May 2023

Private bank assets under management (AUM) per customer, RMB millions

Note: AUM stands for assets under management.

Source: Company reports, FSSA Investment Managers, as at May 2023

On the negative side, there are concerns that China’s “common prosperity” drive may slow down the growth of the wealthier population, although we think this is likely priced in. There is also intensifying competition for retail customers, at a time with weak loan demand. Even after China’s reopening, Chinese banks’ net interest margins reached a historical trough in the first quarter, amid the low (and falling) interest rate environment. 

The stock has been under pressure for the past year, and we have added to our holdings. Despite the concerns, its wealth management strategy is on track and asset quality remains benign. We believe its strong capital adequacy rate, non-performing loans (NPL) coverage and stable retail business should protect the book value over the next few years.

Mitigating the pitfalls of investing in China

Given the many challenges and pitfalls of investing in China, we think an active, bottom-up approach makes sense. While some investors have been disappointed with the flattish performance of the MSCI China over the past decade, our strategies have provided attractive returns over this period. We think this is due to our focus on quality companies with sustainable and predictable growth, which helps us mitigate two key reasons for the disappointing market performance — a lack of supply discipline and poor quality among many companies.

Lack of supply discipline

For many decades, as China transitioned away from being a centrally planned economy, it experienced frequent overcapacity in sectors such as steel, cement, chemicals, shipbuilding, and solar panels. The causes included excess investments in infrastructure projects, easy access to loans and misaligned incentives, which all led to lower returns for companies and investors.  

We typically avoid buying companies in such commoditised sectors. In contrast, the Chinese beer market is highly consolidated, with the top three companies sharing 75% of the market. As a result, competition in this industry appears rational and measured. China is different from global markets as domestic beer volumes have been in decline since 2014. As the economy and middle class have grown, so has the demand for premium products. Meanwhile, despite tepid sales, margins and profitability have improved as the leading beer companies consolidated their breweries and modernised their operations. 

We hold China Resources Beer (CRB), the largest beer company in China with around 30% market share. CRB’s share of premium sales has grown to just under 20% of turnover, with help from a 2019 merger with Heineken China. Although the company is a State-Owned Enterprise (SOE), China Resources businesses have typically been well run, with returns comparable to private enterprises. The most recent annual report suggests that the company is focused on quality growth and profitability.

Average selling price (ASP) has grown consistently

Note: ASP is the average selling price.

Source: Company filings, FSSA Investment Managers. As at 30 Jun 2023.

Operations are being optimised

Note: EBITDAM is the earnings before interest, taxes, depreciation, and amortization.

Source: Company filings, FSSA Investment Managers. As at 30 Jun 2023.

Poor quality among many companies

When we say a company is poor quality, we are often referring to unattractive economics like persistently low returns and lack of competitive moats like pricing power or strong brands. We also look closely at the leadership’s alignment, culture and track record. 

The companies which underperformed often had management who made wrong-footed or sub-optimal investments. Historically China’s SOEs have largely generated subpar returns. One example is Aluminum Corporation of China (CHALCO). When we looked at the company’s capex in the past and the returns on those investments, it was hard to make sense of it.

In contrast, portfolio holdings such as China Resources Land and China Merchants Bank are more market-driven despite being SOEs. For example, CMB differs from China’s big policy banks in a few ways: firstly, it did not inherit legacy staff and was able to build its own staff and culture from scratch, making it more of a meritocracy. Secondly, the bank is not directly owned by the state and doesn’t have one dominant shareholder, resulting in a governance system that is much closer to privately-owned banks in other markets. This explains why CMB has largely managed to avoid national service. Finally, the bank’s culture is very market-oriented. At every level of the organisation, they try to ensure every division is profitable on its own and can generate capital, which is why they have not raised capital in the past decade. 

Total returns from January 2007 through June 2023

Source: Bloomberg, FSSA Investment Managers, as at 30 June 2023. 

We only invest in companies that have good management, competitive advantages and attractive returns. This is especially important going forward, as China’s heady growth days are mostly over. Hence, companies are shifting their focus to enhancing returns and winning market share with better brands, products and strategies.

However, we realise that no company is perfect. Despite our strict requirements around quality, sometimes our portfolio companies can make mistakes or miss their targets. A key performance detractor in our portfolio this year has been China Mengniu Dairy, which weakened on concerns about its underlying profitability as its acquisitions of Yashili and Bellamy have not been very successful. Mengniu has booked asset impairments for both acquisitions. Bad timing, misjudgement of sector development and unstable teams in the acquired companies all contributed to this poor outcome. 

While the company made some mistakes, our meetings with the management team indicate they are learning and evolving. Recent comments from the CEO suggest that Mengniu will prioritise profitability and cash flow going forward. We believe Mengniu’s fundamentals are in decent shape, though it will need to strengthen its brands, develop more innovative products, and improve its digitalisation platforms to achieve its profitability targets. We still expect Mengniu to benefit from the rising dairy consumption in China, currently growing at a mid-single-digit rate, as it improves in areas such as ice cream and milk powder, and develops newer products such as fresh milk and cheese.

Mengniu’s margin improvements have recently stalled

Source: Factset, Bloomberg and FSSA Investment Managers. As at 30 June 2023.

Portfolio update

In what has been a challenging environment, our strategies have declined year-to-date. We mentioned some of the key detractors, China Merchants Bank and Mengniu Dairy, earlier in this note.

In addition, JD.com’s performance has been weak due to sluggish consumer demand and concern around more promotional activities taking place, which will stall its retail margin expansion. However we think it makes strategic sense to build consumer mindshare on the platform’s value-for-money offering. The company is dominant in standardised categories such as electronics, fast-moving consumer goods (FMCG) and large home appliances, and has also built a significant presence in other categories.

Anta Sports also declined on doubts about China’s recovery and consumer demand. We see rising competition from foreign firms like Nike, which has been aggressive in China’s online market. We remain positive on Anta for its multi-brand portfolio which can appeal to different consumer demands. For example, we see bright prospects for its Amer brand which can cater to mid-to-high income groups, and is building awareness among consumers. 

On the positive side, key contributors to performance include semiconductor-related companies such as Taiwan Semiconductor Manufacturing (TSMC), Realtek and Mediatek (the first two are held in our Greater China strategies). This was largely driven by optimism over developments in artificial intelligence (AI), such as the latest ChatGPT software and the projected demand for more powerful chips. Another reason, in our view, is that chip prices had already dropped last year on concerns about the inventory build-up, and so did the share prices. In late 2022, we added to the companies as we believed the valuations had factored in much of the cycle weakness. 

The stocks have performed well since that period. TSMC reported an optimistic outlook with a recovery expected in the second half of this year. The management noted signs of stabilisation in demand and expects the inventory correction to bottom out in the coming quarters. Similarly, Realtek and Mediatek guided for sales to recover this year as the cycle turns more positive.

TSMC remains a high-conviction holding in our Greater China strategies, given its strong global franchise as the largest foundry with the most advanced technologies. Although its growth will eventually taper off due to the law of large numbers, for now it should continue to gain market share and outpace the overall industry’s growth. It has demonstrated pricing power amid strong customer demand, which can in turn drive more investments in a virtuous cycle. 

We have consolidated our semiconductor holdings after the recent strength, and reduced our position in Realtek, a Taiwanese integrated circuits (IC) designer focused on connectivity chips. It has benefited from the previous two years’ cyclical strength. Its margin profile is not as attractive as its IC designer peers, as the business includes many long-tail consumer connectivity products. Therefore, we think the business model lacks operating leverage and its profits may be more volatile. 

As for Mediatek, another IC design company, we have mostly held on to our position. About half of its business comes from smartphones, a maturing end market, with the other half coming from areas like autos, industrials and application-specific integrated circuits (ASICS). Given the company’s size, we don’t expect very fast growth, but the diversification of its business should be a key driver. We also think the valuations are very reasonable, at 15x price-to-earnings and a 10% dividend yield. 

Over the longer term, we expect many beneficiaries from the AI trend, but in the near term the optimism may be a bit overdone. TSMC has been anticipating the AI wave for many years, and high-performance computing has recently become TSMC’s largest revenue source, surpassing smartphones. 

TSMC’s revenue by platform, 1Q 2023

Source: Company presentation, as at 20 April, 2023

The industry still needs to clear through excess inventories in the coming months, especially in consumer products which have faced weak demand. Another risk is the added complexity from geopolitics and de-globalisation. For example, TSMC’s expansion into the US is turning out to be harder than expected, due to issues around recruitment and training. 

Besides the chipmakers, Netease also rose after the management reiterated its positive outlook for the business. Future revenue growth is expected to be supported by innovative new content and a diversified games portfolio, while existing games should remain steady. It also has plans to expand its overseas presence, launching games outside of China. With a long track record and impressive returns over the past 20 years, we like the company’s strong alignment and mind-set for returning value to shareholders.

Key transactions

Amid the recent headwinds, we have added to many of our key holdings as their valuations became more attractive. In no particular order, these include Tsingtao Brewery, Anta Sports, H World, Yifeng Pharmacy, Wuxi Apptec, Hongfa Technology, JD.com, Mengniu, Sino Biopharmaceutical, Autobio Diagnostics and Midea.

We added more broadly to Haier Smart Home, a leading global home appliances maker with sales evenly split between China and overseas. It is a decent franchise with the top position in refrigerators and washing machines, and the only domestic player with a strong presence in the high-end segment. It is also ahead of peers in terms of overseas expansion, with most of its overseas sales coming from its own brands.

While the company has struggled with low efficiency, suboptimal alignment and weaker margins than peers, recently the home appliance/white goods assets were all combined into one identity with corresponding incentive schemes. We believe this should improve alignment and profitability. A recovery in air conditioners domestically and increasing competitiveness in North America should lift margins in the next five years.

We also bought Kanzhun, the leader in China’s online recruitment industry. It has disrupted the industry with a recommendation-based direct chat model, and has demonstrated superior user engagement and recruitment effectiveness over its peers. We see further potential to gain market share as it taps into underpenetrated areas like small and medium-sized enterprises (SMEs) and blue collar workers. There is also scope to increase the monetisation rate on job postings and candidates. 

Finally, we bought a toehold in Bafang Electric, a leading supplier of electric motor systems for pedal assist electric bikes (pedelecs) and electric scooters. We like the focused and aligned management team (who altogether hold around 65% stake in the company), as well as its long-term growth potential. While near-term the industry is in a down-cycle after having peaked during Covid, we believe Bafang will benefit from rising penetration of e-bikes in the US and China (from below 10% and 5% respectively), and market share gains in Europe. Based on Japan’s 40% penetration rate, we think Bafang could also benefit from China’s ageing population.

Conclusion

In response to the recent pessimism in the market, we revisited China’s long-term investment case and how we think about the key opportunities. The demographic tailwinds may be less robust than before, but we still see room for industry leaders to deliver attractive returns in a more mature economy with a growing middle class. 

Considering the broader China market’s mediocre returns over the past decade, we believe our active management approach with bottom-up stock selection makes sense. We continue to seek absolute returns by investing in portfolios that are concentrated and benchmark agnostic, while our focus on quality and the long term sets us apart from our peers. Finally, we stand by our belief that the best time to buy is when things appear gloomy and valuations are undemanding.

We welcome any feedback. As always, thank you for your support.

 

1 Source: National Bureau of Statistics, Bloomberg, as at 15 June 2023. 

2 CASA ratio stands for current and savings account ratio, it is the ratio of deposits in current, and saving accounts to total deposits.

3 EBITDA is the earnings before interest, taxes, depreciation, and amortization.

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

14 July, 2023

  • Greater China

Download PDF

Share

  • Share via Email
  • Post on LinkedIn

Important Information

This document has been prepared for informational purposes only and is only intended to provide a summary of the subject matter covered. It does not purport to be comprehensive or to give advice. The views expressed are the views of the writer at the time of issue and may change over time. This is not an offer document and does not constitute an offer, 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.

This document is confidential and must not be copied, reproduced, circulated or transmitted, in whole or in part, and in any form or by any means without our prior written consent. The information contained within this document has been obtained from sources that we believe to be reliable and accurate at the time of issue but no representation or warranty, express or implied, is made as to the fairness, accuracy, or completeness of the information. We do not accept any liability whatsoever for any loss arising directly or indirectly from any use of this document.

References to “we” or “us” are references to First Sentier Investors a member of MUFG, a global financial group. First Sentier Investors includes a number of entities in different jurisdictions. MUFG and its subsidiaries do not guarantee the performance of any investment or entity referred to in this document or the repayment of capital. Any investments referred to are not deposits or other liabilities of MUFG or its subsidiaries, and are subject to investment risk including loss of income and capital invested.

If this document relates to an investment strategy which is available for investment via a UK UCITS but not an EU UCITS fund then that strategy will only be available to EU/EEA investors via a segregated mandate account.

In the United Kingdom, issued by First Sentier Investors (UK) Funds Limited which is authorised and regulated in the UK by the Financial Conduct Authority (registration number 143359). Registered office Finsbury Circus House, 15 Finsbury Circus, London, EC2M 7EB number 2294743. In the EEA, issued by First Sentier Investors (Ireland) Limited which is authorised and regulated in Ireland by the Central Bank of Ireland (registered number C182306) in connection with the activity of receiving and transmitting orders. Registered office: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland number 629188. Outside the UK and the EEA, issued by First Sentier Investors International IM Limited which is authorised and regulated in the UK by the Financial Conduct Authority (registered number 122512). Registered office: 23 St. Andrew Square, Edinburgh, EH2 1BB number SCO79063.

Copyright © (2023) First Sentier Investors

All rights reserved.

Keep up to date with our latest research and developments on social media

  • LinkedIn
  • Contact us
  • Home
  • Who we are
  • About us
  • Our philosophy
  • Our team
  • Careers
  • Responsible investment
  • Our approach
  • Climate change
  • Carbon footprint
  • Exclusion policy
  • Insights
  • Our funds
  • Asia Pacific
  • Greater China
  • Indian Subcontinent
  • Global Emerging Markets
  • Performance and documents
  • Price and performance
  • Documents and factsheets
  • Contact us
  • Media releases

Part of the First Sentier Investors Group

Working together with Manan Trust

© 2025 FSSA Investment Managers

  • Important Information
  • Privacy Notice
  • Cookies policy
  • Whistleblower
  • Sitemap
  • Policies
FSSA Investment Managers 首域盈信 Signatory of: Principles for Responsible Investment Certified B Corporation Working in partnership with Manan Trust

Get the right experience for you

Your location : Netherlands

Australia & NZ

  • Australia
  • New Zealand

Asia

  • Hong Kong (English)
  • 香港 (繁體中文)
  • Singapore
  • Japan

Europe

  • Austria
  • Switzerland
  • Germany
  • Denmark
  • Spain
  • Finland
  • France
  • Ireland
  • Italy
  • Luxembourg
  • Netherlands
  • Norway
  • Sweden
  • United Kingdom

Americas

  • United States

About you

Tell us a little about yourself to personalise the site to your needs.

What type of investor are you?

What type of investor are you? Please select an option from the section above.

Before you access the First Sentier Investors website, we would like you to read & understand some important information about the site, what data we collect and how we use it. This information is set out in the terms and conditions below:

  1. Important Information
  2. Privacy Notice
  3. Cookie Policy

Scroll down to view the relevant policy.

1. Important Information

If you are not a Professional Client or an Eligible Counterparty and are based in the UK please return to www.fssaim.com and select Private Investor.

It is important that you read this page. The use of www.fssaim.com (this “Website”) is subject to the following terms and conditions (the “Terms”). After you have read and understood these Terms, you may click “I Agree” to confirm that you agree to the Terms which create a binding legal agreement between us. If you do not agree to these Terms, please refrain from using this Website.

IMPORTANT INFORMATION ABOUT ACCESS TO THIS WEBSITE

This Website and the information on it is communicated by First Sentier Investors (Ireland) Limited (“First Sentier Investors”), which is authorised and regulated by the Central Bank of Ireland. It is not directed at or made available to Retail Clients. This Website uses cookies as described in paragraph 16 of these Terms and by agreeing to these Terms you consent to the use of cookies as described in that paragraph.

This Website (and the information on it) is directed only at persons who are Professional Clients or Eligible Counterparties for the purposes of the Markets in Financial Instruments Directive (“MiFID”) or as otherwise defined under applicable local regulations and at whom this Website (and any information on it) may lawfully be directed in any relevant jurisdiction. Access to this Website is not open to persons resident in, or citizens of any territory where, to allow such access would require any registration, filing, application for any licence or approval or other steps to be taken by First Sentier Investors in order to comply with local laws or other regulatory requirements in such overseas territory. Please contact First Sentier Investors if you require any further information on your status.

Following a UK departure from the European Union, First Sentier Investors ICVC (“OEIC”) has ceased to qualify as a UCITS scheme and is instead an Alternative Investment Fund (“AIF”) for European Union purposes under the terms of the Alternative Investment Fund Managers Directive (2011/61/EU). Accordingly, no marketing activities relating to the OEIC are being carried-out by First Sentier Investors in the European Union (or the additional EEA states) and the OEIC is not available for distribution in those jurisdictions. This website does not constitute an offer or invitation or investment recommendation to distribute or purchase shares in the OEIC in the European Union (or the additional EEA states).

1. About this Website: This Website is owned, maintained, operated and communicated by First Sentier Investors (Ireland) Limited which is authorised and regulated by the Central Bank of Ireland (the “CBI”). First Sentier Investor’s registered office is at 70 Sir John Rogerson’s Quay, Dublin 2, Ireland number 629188 (CBI registration number C182306).. The information on this Website constitutes a financial promotion and an invitation or inducement to engage in investment activity and/or a marketing communication.

This Website contains information about investment funds which are offered by First Sentier Investors (the “Funds”) and which are registered, or have otherwise been notified, for public distribution and marketing in certain jurisdictions in the European Union / EEA. Please note that the fact of such registration does not mean that any regulator has determined that such Funds are suitable for all or any investors. The Funds referred to on this Website may not be suitable investments for you and you should therefore seek professional investment advice before making a decision to invest in any of the Funds.

A prospectus and Key Investor Information Document (“KIID”) for each of the Funds is available on this Website. Contact details of the facilities where such documents are available are also set out on the web-page for the relevant Fund. 

2. Selling Restrictions: The distribution of the information on this Website may be restricted by law in certain countries. You have selected Spain as your country of residence. This Website, and the information on it, are not addressed to any person resident in the territory of any country or jurisdiction where such distribution would be contrary to local law or regulation. By choosing to view or make use of this Website you do so on the basis that you have informed yourself of any regulatory or other consequences of your doing so.

First Sentier Investors and its affiliates disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation in the country of which you are a citizen or in which you are residing or domiciled. If your country of residence or domicile changes, you must access this Website selecting your new country of residence. Please note, however, that this may impact your ability to access information about certain Funds.

3. No Advice: The information on this Website is provided for information only and does not constitute, and should not be construed as, investment advice or a recommendation to buy, sell or otherwise transact in any investment including the Funds. The information on this Website is provided solely on the basis that you will make your own investment decisions and First Sentier Investors has not taken any account of your particular investment objectives or financial situation in preparing the information on this Website. In addition, nothing in this Website shall, or is intended to, constitute financial, legal, accounting or tax advice. We strongly recommend that you seek professional investment advice before making any investment decision.

First Sentier Investors neither provides investment advice to, nor receives and transmits orders from, investors in the Funds. 

4. Price and Performance Information: All prices provided on this Website are indicative only. Such prices or values may not reflect actual prices or values that would be available in the market at the time provided or at the time you may decide to purchase or sell an interest in a particular Fund. First Sentier Investors accepts no responsibility for updating such price information.

Past performance is not a reliable indicator of future performance. The value of investments and the income from them can go down as well as up and investors may not get back the amount originally invested and may lose all of their investment. Exchange rate changes may cause the value of overseas investments to rise or fall. To the extent that any information on this Website refers to a particular tax treatment, such treatment depends on the individual circumstances of the investor and may be subject to change in the future.

5. Risk Warnings: Any investment involves substantial risks. Further information about the types of risks associated with investment in the Funds referred to on this Website can be found here. The offering documents for each Fund also contain risk warnings which are specific to the relevant Fund and which you should consider carefully before taking any decision to invest. 

6. Offering Documents: The terms of any investment in a Fund are governed by the documents establishing such terms. In the event of any inconsistency between the information on this Website and the terms specified in, or established pursuant to, the documents establishing the terms of issue or contract, the terms so specified or determined shall prevail. An application for interests in any of the Funds should only be made having fully and carefully read the relevant prospectus, the latest financial reports and other offering documents for the relevant Fund which are available on this Website and upon request from the fund representative in your jurisdiction. 

7. Information on this Website: First Sentier Investors has taken reasonable care to ensure that the information contained on this Website is accurate, current, complete, fit for its intended purpose and compliant with relevant legislation and regulations and, where applicable, the laws of the country of your residence as at the date of issue. However, errors or omissions may occur due to circumstances beyond First Sentier Investors’ control and no warranty is given, or representation made, regarding the accuracy, validity or completeness of the information on this Website and no liability is accepted by such persons for the accuracy or completeness of such information. You must conduct your own due diligence and investigations rather than relying on any of the information in this Website. Any person who acts upon, or changes his or her investment position in reliance on, the information contained on this Website does so entirely at his or her own risk.

Information posted on this Website is current only as at the date it is first posted and may no longer be true or complete when viewed by you. First Sentier Investors cannot guarantee that content will be accurate, complete and current at all times. To the extent that any information on this Website relates to a third party, such information has been provided by that third party and is the sole responsibility of such third party and First Sentier Investors accepts no liability for such information. All content on the Website is subject to modification from time to time without notice. Please contact First Sentier Investors for further information regarding the validity of any information contained on this Website.

To the extent that this Website contains any expression of opinion or forecast, such opinion or forecast is based on sources believed by First Sentier Investors to be reliable, but is not guaranteed or warranted as to its current validity, accuracy or completeness. Opinions expressed represent the opinions of First Sentier Investors at the date of publication only, reflecting prevailing market conditions and certain assumptions (which may not prove to be valid), are subject to change and should not be relied on by users of the Website.

Certain content (the “Restricted Content”) on this Website including, but not limited to, webcasts shall be made available only on the granting of permission by First Sentier Investors or a third party appointed by First Sentier Investors. First Sentier Investors reserves the right, in its absolute discretion, not to grant access to such Restricted Content. Where you are granted access to such Restricted Content, such access is granted for your personal use only. You must treat this Restricted Content as confidential and you must not disclose it to any third party or allow any third party to access such Restricted Content. First Sentier Investors may revoke access to the Restricted Content in its absolute discretion at any time without notice. 

8. Material Interests: First Sentier Investors, its affiliates and its or their directors, officers, employees or agents may have holdings in the Funds and/or underlying investments of the Funds and may otherwise be interested in transactions in those Funds. Further details about the policies that First Sentier Investors has adopted in order to avoid or to manage such conflicts in a way that ensures fair treatment for First Sentier Investors’ clients are available from First Sentier Investors on request. 

9. Linked Websites: Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them. First Sentier Investors accepts no responsibility for information contained on any other sites which can be accessed by hypertext link from this Website or for these sites not being available at all times. First Sentier Investors has not reviewed, and will not review or update, such websites or information and any use that you make of such websites and information is at your own risk. Please note that when you click on any external site hypertext link you will leave this Website. 

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

Global site