New Capital Global Equity Conviction Fund

Marketing Communication

Executive Summary

Key events in market

Equities were higher in October, off their lows in September. The MSCI AC World was up +6.0% bringing it to -21.1% year to date. Growth stocks underperformed, +3.5%, while Value stocks rose +8.5%. Year to date Growth has underperformed Value by –17.6%. The narrative to the market’s upside move was driven by speculation of a slower pace of Fed tightening as the risk to the growth/inflation dynamic have become more two sided. Asia saw steep falls in the Hong Kong and mainland China indices. China’s President Xi Jinping secured a historic third term at the CCP Congress as widely expected. Market participants focused on the extent to which Xi strengthened his grip on power by stacking his leadership team with loyalists instead market-oriented reformers, risking a policy misstep from an absence of dissenting views.

Key performance & positioning updates

The portfolio underperformed the benchmark (MSCI AC World) in October. Our overweight exposure to China was a significant contributor as was our Growth Factor exposure given the rotation during the month. During the month we reduced the higher-than-average cash position of the Fund to benefit from the rising market. We modestly increased our exposure to Consumer Discretionary and Financials sector as well as to Asia ex Japan, moving closer to a neutral stance in these areas of the portfolio. Overall, we are maintaining a defensive stance, and will look to increase this further should inflation continue to surprise on the upside or if economic and earnings growth deteriorate more meaningfully.

Market Update

Equities were higher in October, off their lows in September. The MSCI AC World was up +6.0% bringing it to -21.1% year to date. Growth stocks underperformed, +3.5%, while Value stocks rose +8.5%. Year to date Growth has underperformed Value by –17.6%, primarily driven by a rapid change in inflation expectations and consequent accelerated monetary tightening. During the month Large-cap stocks underperformed, and were up 6.0%, with Mid-caps and Small-caps, up +6.3%, and +7.0%, respectively. From a sector perspective Energy led the benchmark followed by Industrials, and Healthcare. In contrast the laggards were Communication Services, Consumer Discretionary and Real Estate. The narrative to the market’s upside move was driven by speculation of a slower pace of Fed tightening as the risk to the growth/inflation dynamic have become more two sided. Though the September CPI report came in hotter than expected, Fed officials have begun to argue that inflation is likely to fall in the coming months as demand weakens, supply chain issues ease, and some lagging metrics (particularly shelter) have softened recently according to real-time metrics. In addition to an expected slowing in inflation, fears that the economy will be driven into recession if the tightening cycle continues have increased dampening expectations with respect to aggressive tightening. The other upside narrative this month continued to center on deeply depressed sentiment and positioning. This month's BofA (Bank of America) Global Fund Manager Survey showed cash levels of 6.3%, the highest since Apr-01, and investors three standard deviations underweight equities. This month saw the kickoff of Q3 earnings. with 52% of S&P 500 companies having reported through to the end of the month, the blended earnings growth rate of 2.2% was tracking short of the 2.8% expected at the end of the last quarter. However, there were some thoughts that the bar for earnings has been lowered in recent weeks, though that was also met with continued concerns for a more meaningful 2023 earnings reset. In the first few weeks of results, some of the other key themes included the large strong dollar headwind, mixed updates on supply chain pressures, still-elevated raw materials costs, weakening demand for semiconductor chips and PCs, digital advertising headwinds, and fears of a weakening macro backdrop. There were also some mixed signals around consumer spending, with some manufacturing and discretionary companies warning of some weakening trends, although credit card companies and banks highlighted spending resilience and strong household balance sheets.

Another highlight this month were disappointing FANMAG earnings. With nearly $1trn in market cap wiped off mega-cap technology stocks after results. Apple was the standout positive, with iPhone demand trends better than expected. Amazon offered weak Q4 guidance, as well as weaker cloud computing results. Microsoft also saw weaker cloud trends, citing customer efforts to optimize spending. Google cloud results were better than expected, though the company was hit by slower advertising trends and higher spending. Facebook was the worst of the group after investors hit the company for its growing Reality Labs spending slowing topline growth. In Europe, the ECB (European Central Bank) meeting during the month met market expectations. All three key rates were hiked by 75bps to take its key deposit rate to 1.5%. It maintained its data dependent approach and guided for further rate hikes. President Lagarde said substantial progress was made in withdrawing monetary policy accommodation and focused on recession risks and the need to weigh pros and cons when adjusting monetary policy from here. There was a sense that the ECB is coming close to a pivot itself as the bank's own forecasts continue to hint at further downside risks for the economy. While markets pared back bets of more aggressive ECB rate hikes next year, latest inflation prints out of major Eurozone economies left economists skeptical that inflation in the Eurozone has peaked, which may inspire a more hawkish stance from ECB in upcoming meetings. Asia saw steep falls in the Hong Kong and mainland China indices. China’s President Xi Jinping secured a historic third term at the CCP Congress as widely expected. However, market reaction was decidedly negative with foreign outflows hitting a record. Market participants focused on the extent to which Xi strengthened his grip on power by stacking his leadership team with loyalists instead market-oriented reformers, risking a policy misstep from an absence of dissenting views. The outcome of the Congress also drove concerns among offshore investors about more state encroachment on private industry, a continuation of China's growth-sapping zero-Covid strategy, a lack of policy support for the property sector, and Taiwan reunification vows that threaten to worsen geopolitical tensions in coming years. China’s Caixin September services PMI showed a sizable fall of 5.7 points to 49.3 due to the latest Omicron wave. Real GDP growth rebounded to 3.9% y/y in the third quarter, beating market expectations. The manufacturing sectors have led the recovery, although the service sectors are still suffering from lockdowns across the country. Headline inflation remains subdued at 2.8% y/y, creating room for the People’s Bank of China to pursue more accommodative monetary policy with new rate cuts expected in 2023.

Fund Performance & Positioning

The portfolio underperformed the benchmark (MSCI AC World) in October. Our overweight exposure to China was a significant contributor as was our Growth Factor exposure given the rotation during the month. Stocks that significantly contributed/detracted to relative performance were: + Netflix (+24%) – beat expectations by reverting back to growth in subscribers in the third quarter as it worked to introduce ad-supported content and crack down on password sharing aimed at bolstering its revenue and subscriber base. The company added 2.4 million new subscribers in the September quarter, after having forecast a net gain of 1 million customers. + Fair Isaac (+16%) – The Federal Housing Finance Agency announced that after a multi-year transition period, lenders will need to provide both a FICO credit score and a VantageScore credit score, where available, for Fannie Mae and Freddie Mac to evaluate mortgages. The development was positive for Fair Isaac given a FICO score continues to be mandated by regulation, eliminating the risks of market share loss and pricing power erosion. + Adobe (+16%) – Adobe's Analyst Day delivered reassuring guidance of double-digit revenue growth and further improvements in margins. In addition, the market reacted positively to the innovation and the direction that Adobe’s products are moving in. - Tencent (-23%) – No specific company news, but the stock price fell with the Hang Seng Index, after Chinese leader Xi Jinping cemented his control over the ruling Communist Party and the release of weak Chinese GDP data. - Hong Kong Exchanges and Clearing (-23%) – The company delivered slightly better than expected Q3 results, but the stock price fell with the Hang Seng Index, after Chinese leader Xi Jinping cemented his control over the ruling Communist Party and the release of weak Chinese GDP data. - Kweichow Moutai (-30%) – delivered slightly weaker than expected Q3 results, but the stock price fell with the Hang Seng Index, after Chinese leader Xi Jinping cemented his control over the ruling Communist Party and the release of weak Chinese GDP data. In addition, there were market rumours of a potential government crackdown on high end alcohol consumption that put further pressure on the stock.

Most of the portfolio’s capital remains deployed into what we believe to be quality growth compounders, these companies are best positioned, in our view, to deal with rising inflation given their pricing power. Additionally, they have historically tended to weather periods of slower economic growth well given their inherent lower cyclicality and higher structural growth. Overall, we are maintaining a defensive stance, and will look to increase this further should inflation continue to surprise on the upside or if economic and earnings growth deteriorate more meaningfully. This defensiveness is driven on a bottom-up basis as we continue to favour stocks with higher earnings visibility and lower cyclicality given the current risks to corporate earnings. From a top-down perspective the portfolio remains mostly exposed to active stock risk with what we believe to be very little sector and regional active risk. During the month we reduced the higher-than-average cash position of the Fund to benefit from the rising market. We modestly increased our exposure to Consumer Discretionary and Financials sector as well as to Asia ex Japan, moving closer to a neutral stance in these areas of the portfolio.

New Capital Global Equity Conviction Fund MSCI AC World Net USD Difference
1 Month +2.4% +6.49% -4.09%
3 Month -11.99% -7.25% -4.74%
6 Month -11.81% -9.03% -2.78%
YTD -31.18% -20.79% -10.39%
1Yr -31.83% -19.61% -12.22%
3Yr Annualized +7.03% +5% +2.03%
5Yr Annualized +7.17% +5.33% +1.84%
Since inception annualized +7.22% +5.95% +1.27%
Since inception 08.05.2015 +68.37% +54.05% +14.32%

Past performance is not necessarily a guide to the future. The value of your investments and the income from them may fall as well as rise as a result of market as well as currency fluctuations and you may not get back the full amount invested. Fund performance is net of fees and representative of the USD I Acc Share Class and shows a maximum of five previous calendar years and current year to date (computed on a NAV to NAV basis). Where share class inception begins prior to the five previous years the chart has been rebased to 100. Where the Fund has fewer than five full years of performance, returns are shown from the inception date. Source: EFG Asset Management, Bloomberg. As at 31 October 2022.

Outlook

Inflation remains well above Central Bank targets. US Core CPI +6.7% in September up from +6.3% in August and US Core PCE was +5.2% in September up from +4.9% in August, after peaking at 5.4% in February. Inflation has been driven by strong end demand, tight labour markets, previous COVID supply disruption, COVID lockdowns in China and the impact of the Russia/Ukraine war on commodity prices. Central Banks are firmly on a tightening path to slow inflation and this along with falls in commodity prices should be supportive of lower inflation going forward. However, there is a high degree of uncertainty with respect to how fast inflation falls and what level it eventually will settle at. Demand and or supply tightness could fade more rapidly than expected or remain stubborn. Rising interest rates in response to high inflation continue to put pressure on equity multiples especially long duration growth stocks. Economic growth is significantly decelerating, and labour markets remain stubbornly strong so far - but headwinds are building. Forward looking economic indicators have rolled over pointing to contractionary conditions with PMI’s moving below 50. Demand is being supported by tight labour markets and high wage growth, and this is being partly offset by tightening financial + fiscal conditions and high inflation. Supply remains somewhat constrained due to supply chain disruptions, but this is easing. The risks to growth are rising given the financial tightening underway and high levels of inflation impacting spending and investment. The US bond market is already pricing a significant slowdown with most segments of the yield curve inverted. The degree of the slowdown is highly dependent on the degree to which inflation stays sticky and the consequent degree of financial tightening required to lower it down to Central Bank targets. Given the recent rally and decline in forward earnings the, the MSCI AC World trades on a forward P/E of 14.3x compared to its fifteen-year average of 14.1x. The implied global equity risk premium has fallen to 4.9%, which is below its fifteen-year average of 5.7%. These valuation metrics do not paint a picture of an equity market that has fully priced current risks to earnings. Key to market performance over the next few months will be the degree to which inflation moderates after recent demand and supply shocks. Should inflation moderate sufficiently policy tightening will likely slow, providing a reprieve for equites. Should inflation continue to remain persistently high we would expect further financial tightening, impacting growth and asset multiples, and would expect equities to remain under pressure - and particularly growth and cyclical equities.

The Fund’s core focus remains to outperform the benchmark over rolling three-year periods by investing in what we believe to be the highest quality global businesses at attractive prices. We believe these businesses have the following characteristics – 1) robust to competition with the potential to generate sustainable returns on capital. (2) Significant attractive long-term growth prospects underpinned by multiple trends, and (3) Managed by excellent stewards of corporate capital, who can maintain both returns and growth through time. We continue to be focused on the long-term investment cases of the companies we own remaining intact, and that we own the right amount of each of them at any given point, depending on their current price relative to our assessment of their long-term intrinsic value. We also continue to look for companies that are even better than the ones we own in order to ensure the Fund continues to own what we believe are the best businesses in the world.

Disclaimer

For professional clients, qualified investors and accredited investors only. The value of investments and the income derived from them can fall as well as rise, your capital is at risk. Note: Past performance is not a guide to the future. Returns may increase or decrease as a result of currency fluctuations.

Performance contribution is gross of fees, all other performance shown is net of fees and expenses. Please refer to the Prospectus for further information on this Fund and prior to any subscription. All data sourced New Capital, EFGAM, Bloomberg, as at title date, unless otherwise stated.

Issued in the UK by EFG Asset Management (UK) Limited which is authorised and regulated by the Financial Conduct Authority (FCA Registration No. 536771). Registered No: 7389746. Registered address: Park House, 116 Park Street, London W1K 6AP. Telephone: +44 (0)20 7491 9111.

This document is a marketing communication and does not constitute an offer to sell, solicit or buy any investment product or service, and is not intended to be a final representation of the terms and conditions of any product or service. The investments mentioned in this document may not be suitable for all recipients and you should seek professional advice if you are in doubt. Clients should obtain legal/taxation advice suitable to their particular circumstances. This document may not be reproduced or disclosed (in whole or in part) to any other person without our prior written permission. Although information in this document has been obtained from sources believed to be reliable, EFGAM does not represent or warrant its accuracy, and such information may be incomplete or condensed. All estimates and opinions in this document constitute our judgment as of the date of the document and may be subject to change without notice.

EFGAM will not be responsible for the consequences of reliance upon any opinion or statement contained herein, and expressly disclaims any liability, including incidental or consequential damages, arising from any errors or omissions. Performance results shown are net of applicable fees and expenses.

Any information quoted relating to the New Capital UCITS Fund plc is merely a brief summary of key aspects of the Fund.  More complete information on the fund can be found in the prospectus, the simplified prospectus or key investor information document, and the most recent audited annual report and the most recent semi-annual report.

These documents constitute the sole binding basis for the purchase of fund units. Copies of these documents are available free of charge in the United Kingdom at EFG Asset Management (UK) Limited (“EFGAM”), Park House, 116 Park Street, London W1K 6AP, United Kingdom. Copies of these documents are available free of charge in Germany at the offices of the German information agent, HSBC Trinkaus & Burkhardt AG, Königsallee 21/23, 40212 Düsseldorf, Germany. Copies of these documents are available free of charge in France from the French centralizing agent, Societe Generale, 29, boulevard Haussmann – 75009 Paris, France. Copies of these documents are available free of charge from the Swiss Representative: CACEIS (Switzerland) SA, Route de Signy 35, CH-1260 Nyon, Switzerland. Paying Agent: EFG Bank SA. 24 Quai du Seujet, CH-1211, Geneva 2, Switzerland.

Copies of these documents are available free of charge in Luxembourg at the offices of the Luxembourg paying agent, HSBC Securities Services (Luxembourg) S.A., 16 boulevard d’Avranches, L-1160 Luxembourg, R.C.S. Luxembourg, B28531. Copies of these documents are available in the local languages as per the above and from www.newcapitalfunds.com. A summary of investor rights is available at: https://www.efgam.com/newcapitalfunds/Summary-Investor-Rights.html.

Country of origin of the collective investment scheme: Ireland

Investment products may be subject to investment risks, involving but not limited to, currency exchange and market risks, fluctuations in value, liquidity risk and, where applicable, possible loss of principal invested.

In the European Union, this Document is issued by KBA Investments Limited (“KBA”). KBA Investments Limited is licensed in terms of the Investment Services Act (Cap 370) as an Investment Firm and is regulated by the Malta Financial Services Authority (Authorisation ID KIL2-IF-16174). In the European Union, this Document is available to Professional Investors only (as defined under Annex II to Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU).

KBA Investments Limited
Licensed in terms of the Investment Services Act (Cap 370) as an Investment Firm and is regulated by the Malta Financial Services Authority (Authorisation ID KIL2-IF-16174). KBA Investments Limited is a sub-distributor in certain countries in the European Union for EFG Asset Management (UK) Limited. For the full list of EU countries, please visit the https://www.mfsa.mt/financial-services-register/ . Registered Office: Trident Park, Notabile Gardens, No 2 - Level 3, Zone 2, Central Business District, Birkirkara, Malta. Registered in Malta No. C97015

Prospectus/Key Investor Information
A copy of the English version of the prospectus of the Fund and the key investor information document relating to the Fund is available on www.newcapital.com and may also be obtained from EFG Asset Management (UK) Limited. Where required under national rules, the key investor information document/the key information document will also be available in the local language of the relevant EEA Member State.

Hyperlink to Summary of Investor Rights
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Termination of marketing arrangements
A decision may be taken at any time to terminate the arrangements made for the marketing of the Fund in any EEA Member State in which it is currently marketed. In such circumstances, Shareholders in the affected EEA Member State will be notified of this decision and will be provided with the opportunity to redeem their shareholding in the Fund free of any charges or deductions for at least 30 working days from the date of such notification.
Issued in the United Kingdom by EFGAM which is authorised and regulated by the Financial Conduct Authority. Registered number: 7389736. Registered address: EFG Asset Management (UK) Limited, Park House, 116 Park Street, London W1K 6AP, United Kingdom.

France
Investors should note that, relative to the expectations of the Autorité des Marchés Financiers, this UCITS presents disproportionate communication on the consideration of non-financial criteria in its investment policy.

Information for investors in Australia
This document has been prepared and issued by EFG Asset Management (UK) Limited, a private limited company with registered number 7389746 and with its registered office address at Park House, 116 Park Street, London W1K 6AP (telephone number +44 (0)20 7491 9111). EFG Asset Management (UK) Limited is regulated and authorized by the Financial Conduct Authority No.536771.
EFG Asset Management (UK) Limited is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to wholesale clients in Australia and is authorised and regulated by the Financial Conduct Authority of the United Kingdom (FCA Registration No. 536771) under the laws of the United Kingdom which differ from Australian laws.
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ASIC Class Order CO 03/1099
EFG Asset Management (UK) Limited notifies you that it is relying on the Australian Securities & Investments Commission (ASIC) Class Order CO 03/1099 (Class Order) exemption (as extended in operation by ASIC Corporations (Repeal and Transitional Instrument 2016/396) for UK Financial Conduct Authority (FCA) regulated firms which exempts it from the requirement to hold an Australian financial services licence (AFSL) under the Corporations Act 2001 (Cth) (Corporations Act) in respect of the financial services we provide to you.

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The financial services that we provide to you are regulated by the FCA under the laws and regulatory requirements of the United Kingdom which are different to Australia. Consequently any offer or other documentation that you receive from us in the course of us providing financial services to you will be prepared in accordance with those laws and regulatory requirements. The UK regulatory requirements refer to legislation, rules enacted pursuant to the legislation and any other relevant policies or documents issued by the FCA.

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Offering Documents
Neither this document nor any document under which Interests in the New Capital UCITS Fund plc (the “Fund”) are offered is a prospectus, product disclosure statement or other formal disclosure document under the Corporations Act. Interests in the Fund may not be offered, issued, sold or distributed in Australia other than by way of or pursuant to an offer or invitation that does not need disclosure to investors either under Part 7.9 or Part 6D.2 of the Corporations Act, whether by reason of the investor being a wholesale client (as defined in section 761G of the Corporations Act and applicable regulations) or otherwise. Nothing in this document nor any document under which interests in the Fund are offered constitutes an offer of interests in a financial product or financial product advice to a 'retail client' (as defined in section 761G of the Corporations Act and applicable regulations).
The issuer of the interests in the Fund relies on exemptions available under Australian law from the need to hold an AFSL for the provision of financial services to Australian wholesale clients.Note that as all investors must be wholesale clients, no cooling off rights are available in relation to an investment in the Fund.

Americas
The Company is an open-ended umbrella type investment company with variable capital authorised by the Central Bank of Ireland pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 as amended. EFGAM and the Company are affiliated with EFG Capital International Corp., an SEC registered and FINRA/SIPC member broker-dealer.

Notice to Residents of the United States: Shares of the Fund may not be offered or sold, directly or indirectly, within the United States or to U.S. Persons (as defined in the Fund’s Prospectus).

Notice to Residents of Argentina: These shares may not be offered or sold to the public in Argentina. Accordingly, the offering of the shares has not been submitted to the Comisión Nacional de Valores (CNV) for approval. Documents relating to this offering (as well as information contained herein) may not be supplied to the general public for purposes of a public offering in Argentina or be used in connection with any offer or subscription for sale to the public in Argentina.

Notice to Residents of Bermuda: The securities being offered hereby are being offered on a private placement basis to investors who satisfy the criteria outlined in the prospectus. The prospectus is not subject to and has not received approval from either the Bermuda Monetary Authority or the Registrar of Companies in Bermuda and no statement to the contrary, explicit or implicit, is authorised to be made in this regard. The securities being offered may be offered or sold in Bermuda only in compliance with the provisions of the Investment Business Act 2003 of Bermuda. Additionally, non-Bermudian persons may not carry on or engage in any trade or business in Bermuda unless such persons are authorized to do so under applicable Bermuda legislation. Engage in the activity of offering or marketing the securities being offered in Bermuda to persons in Bermuda may be deemed to be carrying on business in Bermuda.

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Notice to Residents of Chile: Fecha de inicio de la oferta: [11.10.2013]
(i) La presente oferta se acoge a la Norma de Carácter General N° 336 de la Superintendencia de Valores y Seguros de Chile.
(ii) La presente oferta versa sobre valores no inscritos en el Registro de Valores o en el Registro de Valores Extranjeros que lleva la Superintendencia de Valores y Seguros, por lo que los valores sobre los cuales ésta versa, no están sujetos a su fi scalización;
(iii) Que por tratarse de valores no inscritos, no existe la obligación por parte del emisor de entregar en Chile información pública respecto de estos valores; y
(iv) Estos valores no podrán ser objeto de oferta pública mientras no sean inscritos en el Registro de Valores correspondiente.
(i) The commencement date of the offer and the fact that the relevant offer is made pursuant to this SVS Rule 336;
(ii) That the offer deals with securities that are not registered in the Securities Registry (Registro de Valores) or in the Foreign Securities Registry (Registro de Valores Extranjeros) kept by the SVS, which are, therefore, not subject to the supervision of the SVS. It is not sufficient to include disclaimers stating that the securities are registered in a specific jurisdiction other than Chile and supervised by the correspondent regulator; the SVS requires including in the communications and material used to offer the securities to potential investors the disclaimer provided by the NCG 336 and in Spanish;
(iii) That, given that the securities are not registered, there is no obligation for the issuer to disclose in Chile public information about said securities; and
(iv) That the securities may not be publicly off ered as long as they are not registered in the corresponding Securities Registry.

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Notice to Residents of El Salvador: The recipient of this documentation hereby acknowledges that the same has been provided by EFG Capital International Corp. upon the recipient’s express request and instructions, and on a private placement basis.

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Notice to Residents of Mexico: The shares have not been, and will not be, registered under the Mexican Securities Market Law (Ley del Mercado de Valores) and may not be offered or sold in the United Mexican States. The Prospectus relating to the Securities Offering may not be distributed publicly in Mexico and the shares may not be traded in Mexico.

Notice to Residents of Panama: Neither these securities, nor their offer, sale or transfer, have been registered with the Superintendence of the Securities Market (before named National Securities Commission). The exemption from registration is based on numeral 3 of Article 129 of Decree Law 1 of July 8, 1999 (Institutional Investors), as amended. In consequence, the tax treatment established in Articles 334 to 336 of Decree Law 1 of July 8, 1999, as amended, does not apply to them. These securities are not under the supervision of the Superintendence of the Securities Market (before named National Securities Commission).

Notice to Residents of Uruguay: Shares of the Fund are not available publicly in Uruguay and are offered only on a basis which constitutes a private placement in Uruguay. As such, the Shares are not required to be, and will not be, registered with the Central Bank of Uruguay. The Shares correspond to an investment fund that is not an investment fund regulated by Uruguayan law 16,774 dated September 27, 1996, as amended.

Hong Kong
The contents of this document have not been reviewed nor endorsed by any regulatory authority in Hong Kong. Hong Kong residents are advised to exercise caution in relation to this offer. An investment in the Fund may not be suitable for everyone. If you are in any doubt about the contents of this document, you should consult your stockbroker, bank manager, solicitor, accountant or other financial adviser for independent professional advice.
The Fund is not authorised by the Securities and Futures Commission (“SFC”) in Hong Kong pursuant to Section 104 of the Securities and Futures Ordinance (Cap 571, Laws of Hong Kong) (“SFO”). This document has not been approved by the SFC in Hong Kong, nor has a copy of it been registered with the Registrar of Companies in Hong Kong and, must not, therefore, be issued, or possessed for the purpose of issue, to persons in Hong Kong other than (1) professional investors within the meaning of the SFO (including professional investors as defined by the Securities and Futures (Professional Investors) Rules); or (2) in circumstances which do not constitute an offer to the public for the purposes of the Companies Ordinance (Cap 32, Laws of Hong Kong) or the SFO. This document is distributed on a confidential basis and may not be reproduced in any form or transmitted to any person other than the person to whom it is addressed. No interest in the Fund will be issued to any person other than the person to whom this document has been addressed and no person other than such addressee may treat the same as constituting an invitation for him to invest.

Singapore
The Fund and the offer of the Shares / Units which are the subjects of this document do not relate to a collective investment scheme which is authorised by the Monetary Authority of Singapore (“MAS”) under section 286 of the Securities and Futures Act (Cap. 289) (the "SFA") or recognised by the MAS under section 287 of the SFA, and Shares / Units of the Fund are not allowed to be offered to the retail public.

This document (as well as any other document issued in connection with the offer or sale of Shares / Units is not a prospectus as defined in the SFA, nor will it be lodged or registered as a prospectus with the MAS and, accordingly, statutory liability under the SFA in relation to the content of prospectuses does not apply, and potential investors should carefully consider whether an investment in the Shares / Units is suitable for them. The MAS assumes no responsibility for the contents of this document (nor any other document issued in connection with the offer or sale of the Shares / Units.

No offer of the Shares / Units for subscription or purchase, or invitation to subscribe for or purchase the Shares / Units, may be made, nor any document or other material (including but not limited to this document relating to the Shares / Units may be circulated or distributed, either directly or indirectly, to any person in Singapore other than: (i) to an institutional investor (as defined in section 4A of the SFA) pursuant to section 304 of the SFA; (ii) to a relevant person (as defined in section 305(5) of the SFA) pursuant to section 305(1) of the SFA; (iii) on terms that the minimum consideration is the equivalent of Singapore dollars 200,000 in accordance with section 305(2) of the SFA; or (iv) otherwise pursuant to, and in accordance with the conditions of, any other exemption under the SFA.

Pursuant to section 305 of the SFA, read in conjunction with regulation 32 of and the Sixth Schedule to the Securities and Futures (Offers of Investments) (Collective Investment Schemes) Regulations 2005, the Fund has been entered into the list of restricted schemes maintained by the MAS for the purposes of offering Shares / Units in the Fund to relevant persons (as defined in section 305(5) of the SFA), or, for the purposes of offering Shares / Units in the Fund in accordance with the conditions of section 305(2) of the SFA.

Where an offer is made to institutional investors pursuant to section 304 of the SFA, the following restrictions (under section 304A) apply to Shares / Units acquired pursuant to such an offer. Where such Shares / Units are first sold to any person other than an institutional investor, the requirements of Subdivisions (2) and (3) of Division 2 to Part XIII of the SFA will apply to the offer resulting in such sale, save where the Shares / Units acquired are of the same class as, or can be converted into Shares / Units of the same class as, the other Shares / Units:
i. which are listed for quotation on an approved exchange (as defined in the SFA); and
ii. in respect of which any offer information statement, introductory document, unitholders’ circular for a reverse take-over, document issued for the purposes of a trust scheme, or any other similar document approved by an approved exchange (as defined in the SFA), was issued in connection with an offer of those Shares / Units, or the listing for quotation of those Shares / Units.

Where an offer is made to relevant persons pursuant to section 305 of the SFA, the following restrictions (under section 305A) apply to Shares / Units acquired pursuant to such an offer. Where such Shares / Units are first sold to any person other than (i) an institutional investor; (ii) a relevant person; or (iii) on terms in accordance with section 305(2) of the SFA, the requirements of Subdivisions (2) and (3) of Division 2 to Part XIII of the SFA will apply to the offer resulting in such sale, save where the Shares / Units acquired are of the same class as other Shares / Units:
i. which are listed for quotation on an approved exchange (as defined in the SFA); and
ii. in respect of which any offer information statement, introductory document, unitholders’ circular for a reverse take-over, document issued for the purposes of a trust scheme, or any other similar document approved by an approved exchange (as defined in the SFA), was issued in connection with an offer of those Shares or Units, or the listing for quotation of those Shares / Units.

Further, where the Shares / Units are acquired pursuant to an offer made in reliance on section 305 of the SFA and the acquirer is:
a. a corporation which is not an accredited investor (as defined in the SFA), whose sole business is to hold investments and the entire share capital of which is owned by individuals each of whom is an accredited investor); or
b. a trust of which the trustee is not an accredited investor and whose sole purpose is to hold investments for the benefit of beneficiaries each of whom is an accredited investor,
then no securities of such a corporation and no rights and interests of the beneficiaries in such a trust (as the case may be) shall be transferred for a period of 6 months from the time the corporation or trust (as the case may be) acquired the Shares / Units, unless such transfers are in accordance with the conditions specifically provided in sections 305A(2) and 305A(3) of the SFA (as the case may be).