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Privacy policy

INTRODUCTION

Welcome to Harmony Energy Income Trust plc’s privacy policy.

Harmony Energy Income Trust plc (the “Company“) and its direct and indirect subsidiaries from time to time (together “we“, “us“, “our“) are committed to protecting your personal data and are required, by Data Protection Legislation (defined below), to provide individuals with certain information about how we use your personal information.

This privacy policy (“Privacy Policy“) explains what personal information we collect from you or you provide to us, how we use it and with whom we share that information. This Privacy Policy also sets out your rights and who you can contact for more information.

This Data Protection Policy applies to all our directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us (“you“, “your“). You must read, understand and comply with this Privacy Policy on our behalf and attend training on its requirements.

In this Privacy Policy:

  • your personal information is sometimes also referred to as “personal data”;
  • we may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data; and
  • the term “Data Protection Legislation” means the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

For the purposes of Data Protection Legislation the data controller is the Company. This is because we are the organisation which (either acting alone or jointly with others) determines why and how your personal information is processed. 

To use your personal data, we rely on third parties to develop our business under our directions. For this reason your personal data will normally be processed by companies like JTC Global AIFM Solutions Limited, who is our Alternative Investment Fund Manager (“AIFM”), JTC (UK) Limited, who is our Administrator and Company Secretary, Harmony Energy Advisors Limited (“HEAL”), who is our Investment Adviser, Computershare Investor Services PLC, who is our Registrar and Receiving Agent, and we will not access or otherwise process your data unless it is strictly necessary. When they collect your personal data, or any personal data you provide to them, they will inform you about the processing of this data for their own purposes or on our behalf if appropriate. 

1. WHAT INFORMATION WE COLLECT ABOUT YOU

The Company, or our processors, may collect, record and use information that personally identifies you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Policy.

The personal data we collect and process may include:

(A) Information that you provide to us

This is information that personally identifies you that you provide to us. Such information may typically include:

  • information obtained from identification documentation (including your name, email address, telephone number, address (including city, postcode and country), nationality and national identity numbers (where applicable));
  • your professional title and occupation;
  • your age, date of birth and marital status;
  • financial information, tax status, bank account details and evidence of ownership of financial assets;
  • personal identifiers such as your social security number, national insurance number, tax file number, internet protocol (IP) address or your internal electronic identifiers;
  • information which we need to conduct ‘know your client’ checks such as details relating to your passport and credit history; and
  • other information you provide in the course of your dealings with us or which we require you to provide so that we can provide you with products and services.

(B) Information that we collect or generate about you

This may include:

  • files that we may produce as a record of our relationship with you, including contact history and correspondence records; and
  • any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements.

(C) Information we obtain from other sources

This may include information from publicly available sources, including third party agencies such as credit reference agencies, public databases, registers and records such as Companies House, the Financial Conduct Authority register and information obtained from sanction checking and background screening providers.

In certain circumstances, we also collect and process what are known as ‘special categories’ of personal data (as defined by Data Protection Legislation). Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in the Company obtaining information about actual or alleged criminal convictions and offences.

You are not obliged to provide us with your personal data where it is requested but we may be unable to provide certain products and services or proceed with your business relationship with the Company if you do not do so.

2. HOW WE COLLECT YOUR INFORMATION

The personal information we collect comes from:

  • application forms or other materials you or your authorised representative submits to us during the course of your relationship with the Company;
  • your or your authorised representative’s interactions with the Company, transactions and use of our products and services (including the use of our website);
  • your or your authorised representative’s business dealings with the Company, including via email, telephone or as stated in contracts with you;
  • third parties (including for credit and money laundering checks, among other things); and
  • recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).

3. HOW WE USE YOUR INFORMATION

Our primary purpose in collecting your personal information is to facilitate and record your holding of shares in the Company, the management and administration of your holdings in the Company and any related administration on an on-going basis.

Additionally, on an ongoing basis during your relationship with us, we may use your information for the following specific purposes:

  • to process transactions and to improve the quality of the service that we provide to you;
  • to disclose information to other third parties such as service providers of the Company, auditors, regulatory authorities and technology providers for the purposes outlined in this Privacy Policy (as set out in more detail below);
  • to communicate with you as necessary in connection with the proper running of the Company;
  • to update and maintain records;
  • to monitor and record calls and electronic communications;
  • in connection with the Company’s internal management and reporting;
  • to report regulatory and tax related information to regulatory and tax authorities in order to comply with a legal obligation, including any obligation arising under legislation implementing the U.S. Foreign Account Tax Compliance Act of 2010, as amended, and the Organisation for Economic Co-operation and Development’s Common Reporting Standard; 
  • to permit, administer and record  your investment in the Company;
  • verifying the identity of the prospective investor to comply with statutory and regulatory requirements in relation to anti-money laundering procedures;
  • in order to carry out anti-money laundering checks and related actions which are necessary to comply with legal obligations, in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis;
  • for prudential and risk management purposes;
  • to provide you with any products and services that you request from us; and
  • other reasons compatible with the primary purpose.

We will only use your personal information for the purposes for which it was collected unless we reasonably consider that it is necessary to use it for another reason and that reason is compatible with the original purpose. 

4.  LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION

Data Protection Legislation permits us to process your personal data in the way that we do because such processing is:

  • necessary for the purposes of the legitimate interests that we pursue, which are to run and administer the Company, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services; or
  • necessary for the performance of a contract with you;
  • necessary in order to comply with a legal obligation to which we are subject; or
  • otherwise with your express consent.  

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

5. PROVIDING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of recipients who may receive it and process it for the purposes outlined in this Privacy Policy:

  • representatives, agents, custodians, intermediaries and/or other third party product providers appointed by you;
  • our AIFM, Administrator and Company Secretary, HEAL, Registrar and Receiving Agent, who will directly collect and process your personal data as our processors. When they collect your personal data, or any personal data you provide to them, they will inform you about the processing of this data for their own purposes or on our behalf if appropriate; 
  • third party agents and contractors for the purposes of them providing services both to us and to you (for example, professional advisers and, information technology (IT) and communications providers). These third parties will be subject to appropriate data protection obligations and may act as separate controllers of your personal data where, although they are our agents or contractors, they decide why and how to use your data when providing services for us. More information concerning these recipients is available under request;
  • any depositary, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your personal information is reasonably required for the purpose of effecting, managing or reporting transactions on your behalf or establishing a relationship with a view to such transactions;
  • any regulatory, supervisory or governmental authorities to the extent we are required by law or regulation to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud) or to establish, exercise or defend our legal rights; and
  • tax authorities.

The Company does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.

6. TRANSFERRING DATA OUTSIDE OF THE UK

Where we transfer your personal data out of the UK, we will ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.

This can be done in a number of different ways, for instance:

  • the country to which we send the personal information may be approved according to the UK law parameters;
  • by having in place a contract based on “model contractual clauses” approved by the European Commission; or
  • where the law permits us to otherwise transfer your personal information to another country.

If you would like further information about the safeguards we have in place to protect your personal information, please refer to paragraph 13 below.

7. AUTOMATED PROCESSING

We do not carry out automated decision-making or profiling based on your personal data.

8. YOUR RIGHTS

In the circumstances where we collect, use or store your personal information, as outlined in this Privacy Policy, you may have the following rights and, in most cases, you can exercise them free of charge:  

  • to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
  • to request access to or a copy of any personal data which we hold about you;
  • to rectification of your personal data, if you consider that it is inaccurate or incomplete;
  • to ask us to delete your personal data, if you consider that we do not have the right to hold it (please note that there may be circumstances where you ask us to erase your personal information but we are required or entitled to retain it);
  • to withdraw your consent to our processing of your personal data (please note that we may still be entitled to process your personal data if we have another legitimate reason for doing so, for example we may need to retain your personal data to comply with legal or regulatory obligations or to satisfy our internal audit requirements);
  • to restrict processing of your personal data;
  • where applicable, to data portability (moving some of your personal data elsewhere) in certain circumstances;
  • to object to your personal data being processed in certain circumstances;
  • not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data; and
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information of which we are made aware and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change. Failure to provide accurate information or to update changed information may have a detrimental impact on your investment in the Company, including the processing of any subscription or redemption instructions or the suspension of your account.

9. HOW LONG WE KEEP YOUR INFORMATION

We will only keep the information we collect about you for as long as required for the purposes set out in this Privacy Policy or as long as required for us to comply with any legal obligations to which we are subject being the longest of the following periods:

  • as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with the Company;
  • the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
  • any retention period that is required by law; or
  • the end of the period in which litigation or investigations might arise in respect of an investment in the Company.

This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

10. HOW WE PROTECT YOUR INFORMATION

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal information from unauthorised access. The Company has controls and mechanisms in place designed to detect, respond and recover in case of any adverse events that may arise.

11. CHANGES TO PRIVACY POLICY

This Privacy Policy may be amended from time to time without notice, in which case the date of this Privacy Policy will be revised.

If our Privacy Policy changes in any way, we will place an updated version on the Company’s website. Regularly reviewing the Privacy Policy on the Company’s website ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

12. OTHER

This Privacy Policy is for your information and should not be used as the basis for any decision to purchase or sell investments in the Company. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.

13. COMPLAINTS

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our Company Secretary, JTC (UK) Limited at The Scalpel, 18th Floor, 52 Lime Street, London, EC3M 7AF.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, (ICO) (www.ico.org.uk), the UK regulator for data protection issues, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113. 

The Nomination and Remuneration Committee will review this Policy, at least annually, to ensure its effectiveness, discuss any revisions that may be required and recommend any such revisions to the Board for consideration and approval. 

This Policy was approved by the Board on 14 March 2024.

Disclaimer

IMPORTANT NOTICE

Please note that access to this information and documents on this portion of the website may be restricted for regulatory reasons. We request that you provide certain information in order to access this information. This personal data will not be retained by us and will be requested of you each time you seek to access this restricted information. The information given by you must be true and accurate.

Please select the country in which you reside:

Disclaimer

The information contained in this section of the Company’s website is restricted and is not for release, publication or distribution, directly or indirectly, in whole or in part in, into or from the United States (including its territories and possessions, any state of the United States and the District of Columbia, collectively the “United States”), Australia, Canada, the Republic of South Africa, Japan any member state of the European Economic Area (the “EEA“) or any jurisdiction where to do so would constitute a violation of the relevant laws of such jurisdiction.”

The information to which this gatepost gives access is exclusively intended for persons who are not residents of, and who are not physically present in, the United States, Australia, Canada, the Republic of South Africa, Japan or any member state of the EEA. This information does not constitute or form a part of an offer to sell or issue, or the solicitation of an offer to buy, acquire or subscribe for any securities of Harmony Energy Income Trust plc (the “Company”) in the United States, Australia, Canada, the Republic of South Africa, Japan, any member state of the EEA or in any other jurisdiction in which such offer or invitation is restricted or not authorised or to any person to whom it is unlawful to make such offer or solicitation (each a “Restricted Jurisdiction“). Potential users of this information are requested to inform themselves about and to observe any such restrictions. Any failure to comply with these restrictions may constitute a violation of the securities laws of such jurisdictions. The information to which this gatepost gives access does not in any way constitute investment, tax, legal or other advice.

No securities of the Company have been or will be registered under the US Securities Act of 1933, as amended (the “Securities Act“) or under the securities laws of any state or other jurisdiction of the United States and may not be offered, sold or delivered, directly or indirectly, in or into the United States, or to or for the account or benefit of any US person (within the meaning of Regulation S under the Securities Act) except pursuant to an exemption from, or in a transaction not subject to, the registration requirements of the Securities Act and in compliance with any applicable securities laws of any state or other jurisdiction in the United States. In addition, the Company has not been, and will not be, registered under the United States Investment Company Act of 1940, as amended. There will be no public offer of securities in the United States, Australia, Canada, Japan, the Republic of South Africa or any member state of the EEA or any jurisdiction in which such an offer would constitute violation of the relevant laws or regulations of such jurisdiction.

If you are not permitted to view this website or are in any doubt as to whether you are permitted to view this website, please exit this website immediately by clicking on the “I do not agree” button below. The information to which this gatepost gives access must not be released or otherwise forwarded, distributed or sent, directly or indirectly, in whole or in part, to any Restricted Jurisdiction, or any other jurisdiction where the distribution of such materials would or may breach any applicable law or regulation or would require any registration or licensing within such jurisdiction. Persons receiving the information to which this gatepost gives access (including, without limitation, custodians, nominees and trustees) should observe these restrictions and must not, directly or indirectly, in whole or in part, forward, distribute or send them in, into or from any jurisdiction outside the United Kingdom. None of the Company, JTC Global AIFM Solutions (“AIFM”) or Harmony Energy Advisors Limited (“Investment Adviser”) nor their respective advisers accept any responsibility for any violation by any person of any of these restrictions.

In addition, the securities referred to herein and on the pages that follow may only be offered: (i) in the United Kingdom (“UK“), to the extent that the securities are permitted to be marketed in the UK pursuant to the Alternative Investment Fund Managers Directive (Directive 2011/ (61/EU) (“AIFMD“) as implemented in the UK by UK statutory instruments and by virtue of the European Union (Withdrawal) Act 2018, and in any EEA jurisdiction to the extent that such securities are permitted to be marketed into the relevant EEA jurisdiction pursuant to the AIFMD (and/or any applicable local implementing measures); or (ii) can otherwise be lawfully offered or sold (including on the basis of an unsolicited request from a ‘professional investor’ (as that term is used in the AIFMD)).

Any person accessing the information to which this gatepost gives access in any jurisdiction should inform themselves about and observe any applicable legal requirements in their jurisdiction. Access to this website is for information purposes only. Any person seeking access to this website represents and warrants to the Company, to the AIFM and to the Investment Adviser that they are doing so for information purposes only. Making this website available does not constitute an offer to issue or sell, or the solicitation of an offer to subscribe for or buy, securities in the Company. Further, it does not constitute a recommendation by the Company, the AIFM or the Investment Adviser or any associated company or any other person to subscribe for or buy securities in the Company.

Any person accessing the information to which this gatepost gives access should carefully review the Terms and Conditions of the website. By using the information to which this gatepost gives access, you indicate that you accept the Terms and Conditions and that you agree to abide by them. The Company may change the Terms and Conditions. Such changes will be posted on the website. Your access to the website is governed by the version of the Terms and Conditions then in force. If you do not agree to the Terms and Conditions, please refrain from using this website.

None of the Company, the AIFM or the Investment Adviser or any other person has, or accepts: (i) any responsibility or duty to update any information, document or announcement contained on this website and the Company reserves the right to add to, remove or amend any information available on this website at any time; or (ii) any responsibility in respect of any information contained on any other website which may be linked to or from this website.

Joh. Berenberg, Gossler & Co. KG, acting through its London Branch (“Berenberg“), is authorised by the German Federal Financial Supervisory Authority (BaFin) and in the United Kingdom is deemed authorised under the Temporary Permissions Regime and subject to limited regulation by the FCA. Berenberg is acting solely for the Company and will not be responsible to anyone other than the Company for providing the protections afforded to clients nor for providing advice in relation to the contents of the documents or other information contained on these pages.

Apart from the responsibilities and liabilities which may be imposed on Berenberg by the Financial Services and Markets Act 2000, as amended, or by the regulatory regime established under it, neither Berenberg nor its affiliates accepts any responsibility whatsoever for the contents of the documents or other information contained on these pages or for any other statement made or purported to be made by or on behalf of Berenberg or any of its affiliates in connection with the Company, the Securities or the Offering. Berenberg and its affiliates accordingly disclaim all and any liability whether arising in tort, contract or otherwise (save as referred to above) in respect of any documents, statements or other information contained on these pages and no representation or warranty, express or implied, is made by Berenberg or any of its affiliates as to the accuracy, completeness or sufficiency of the documents or other information contained on these pages.

The release, publication or distribution of the documents or other information contained on these pages may be restricted by law in certain jurisdictions. Persons into whose possession any of the documents or other information contained on these pages come should inform themselves about and observe any such restrictions. Any failure to comply with any such restrictions may constitute a violation of the securities laws or regulations of such jurisdiction.

The documents or other information contained on these pages may not be forwarded or distributed to any other person and may not be reproduced in any manner whatsoever. Any forwarding, reproduction, distribution or disclosure of this information in whole or in part is unauthorised and may result in a violation of the Securities Acts or the applicable laws of other jurisdictions.

Documents or other information contained on these pages, including those related to the Offering and admission of the Company’s securities to trading, include statements that are, or may be deemed to be, “forward-looking statements”. These forward-looking statements, which may use words such as “aim”, “anticipates”, “believe”, “intend”, “estimate”, “expect” and words of similar meaning, include all matters that are not historical facts. These forward-looking statements involve risks and uncertainties that could cause the actual results of operations, financial condition, liquidity, dividend policy and the development of the industries in which the Company’s businesses operate to differ materially from the impression created by the forward-looking statements. These forward-looking statements speak only as at the date of the document or other information concerned. In light of these risks, uncertainties and assumptions, the events described in the forward-looking statements may not occur.

By proceeding to view the materials to which this gatepost gives access, you warrant that you have read and understand the statements above, are located in the United Kingdom, are not located in or accessing this website from the United States, Australia, Canada, the Republic of South Africa or Japan or any other Restricted Jurisdiction, are not a U.S. Person (as defined in Regulation S under the Securities Act) or otherwise resident in the United States or any other Restricted Jurisdiction, you are not investing or otherwise acting for the account or benefit of a US Person or a resident of the United States or any other Restricted Jurisdiction, you are accessing this website for information purposes only and agree that you will not transmit or otherwise send any information contained in this website to any person outside the United Kingdom, including in the United States, Australia, Canada, the Republic of South Africa, Japan any member state of the EEA or any other Restricted Jurisdiction, to any US Person or to publications with a general circulation in the United States.

Disclaimer

The information contained in this section of the Company’s website is restricted and is not for release, publication or distribution, directly or indirectly, in whole or in part in, into or from the United States (including its territories and possessions, any state of the United States and the District of Columbia, collectively the “United States”), Australia, Canada, the Republic of South Africa, Japan any member state of the European Economic Area (the “EEA“) or any jurisdiction where to do so would constitute a violation of the relevant laws of such jurisdiction.”

The information to which this gatepost gives access is exclusively intended for persons who are not residents of, and who are not physically present in, the United States, Australia, Canada, the Republic of South Africa, Japan or any member state of the EEA. This information does not constitute or form a part of an offer to sell or issue, or the solicitation of an offer to buy, acquire or subscribe for any securities of Harmony Energy Income Trust plc (the “Company”) in the United States, Australia, Canada, the Republic of South Africa, Japan, any member state of the EEA or in any other jurisdiction in which such offer or invitation is restricted or not authorised or to any person to whom it is unlawful to make such offer or solicitation (each a “Restricted Jurisdiction“). Potential users of this information are requested to inform themselves about and to observe any such restrictions. Any failure to comply with these restrictions may constitute a violation of the securities laws of such jurisdictions. The information to which this gatepost gives access does not in any way constitute investment, tax, legal or other advice.

No securities of the Company have been or will be registered under the US Securities Act of 1933, as amended (the “Securities Act“) or under the securities laws of any state or other jurisdiction of the United States and may not be offered, sold or delivered, directly or indirectly, in or into the United States, or to or for the account or benefit of any US person (within the meaning of Regulation S under the Securities Act) except pursuant to an exemption from, or in a transaction not subject to, the registration requirements of the Securities Act and in compliance with any applicable securities laws of any state or other jurisdiction in the United States. In addition, the Company has not been, and will not be, registered under the United States Investment Company Act of 1940, as amended. There will be no public offer of securities in the United States, Australia, Canada, Japan, the Republic of South Africa or any member state of the EEA or any jurisdiction in which such an offer would constitute violation of the relevant laws or regulations of such jurisdiction.

If you are not permitted to view this website or are in any doubt as to whether you are permitted to view this website, please exit this website immediately by clicking on the “I do not agree” button below. The information to which this gatepost gives access must not be released or otherwise forwarded, distributed or sent, directly or indirectly, in whole or in part, to any Restricted Jurisdiction, or any other jurisdiction where the distribution of such materials would or may breach any applicable law or regulation or would require any registration or licensing within such jurisdiction. Persons receiving the information to which this gatepost gives access (including, without limitation, custodians, nominees and trustees) should observe these restrictions and must not, directly or indirectly, in whole or in part, forward, distribute or send them in, into or from any jurisdiction outside the United Kingdom. None of the Company, JTC Global AIFM Solutions (“AIFM”) or Harmony Energy Advisors Limited (“Investment Adviser”) nor their respective advisers accept any responsibility for any violation by any person of any of these restrictions.

In addition, the securities referred to herein and on the pages that follow may only be offered: (i) in the United Kingdom (“UK“), to the extent that the securities are permitted to be marketed in the UK pursuant to the Alternative Investment Fund Managers Directive (Directive 2011/ (61/EU) (“AIFMD“) as implemented in the UK by UK statutory instruments and by virtue of the European Union (Withdrawal) Act 2018, and in any EEA jurisdiction to the extent that such securities are permitted to be marketed into the relevant EEA jurisdiction pursuant to the AIFMD (and/or any applicable local implementing measures); or (ii) can otherwise be lawfully offered or sold (including on the basis of an unsolicited request from a ‘professional investor’ (as that term is used in the AIFMD)).

Any person accessing the information to which this gatepost gives access in any jurisdiction should inform themselves about and observe any applicable legal requirements in their jurisdiction. Access to this website is for information purposes only. Any person seeking access to this website represents and warrants to the Company, to the AIFM and to the Investment Adviser that they are doing so for information purposes only. Making this website available does not constitute an offer to issue or sell, or the solicitation of an offer to subscribe for or buy, securities in the Company. Further, it does not constitute a recommendation by the Company, the AIFM or the Investment Adviser or any associated company or any other person to subscribe for or buy securities in the Company.

Any person accessing the information to which this gatepost gives access should carefully review the Terms and Conditions of the website. By using the information to which this gatepost gives access, you indicate that you accept the Terms and Conditions and that you agree to abide by them. The Company may change the Terms and Conditions. Such changes will be posted on the website. Your access to the website is governed by the version of the Terms and Conditions then in force. If you do not agree to the Terms and Conditions, please refrain from using this website.

None of the Company, the AIFM or the Investment Adviser or any other person has, or accepts: (i) any responsibility or duty to update any information, document or announcement contained on this website and the Company reserves the right to add to, remove or amend any information available on this website at any time; or (ii) any responsibility in respect of any information contained on any other website which may be linked to or from this website.

Joh. Berenberg, Gossler & Co. KG, acting through its London Branch (“Berenberg“), is authorised by the German Federal Financial Supervisory Authority (BaFin) and in the United Kingdom is deemed authorised under the Temporary Permissions Regime and subject to limited regulation by the FCA. Berenberg is acting solely for the Company and will not be responsible to anyone other than the Company for providing the protections afforded to clients nor for providing advice in relation to the contents of the documents or other information contained on these pages.

Apart from the responsibilities and liabilities which may be imposed on Berenberg by the Financial Services and Markets Act 2000, as amended, or by the regulatory regime established under it, neither Berenberg nor its affiliates accepts any responsibility whatsoever for the contents of the documents or other information contained on these pages or for any other statement made or purported to be made by or on behalf of Berenberg or any of its affiliates in connection with the Company, the Securities or the Offering. Berenberg and its affiliates accordingly disclaim all and any liability whether arising in tort, contract or otherwise (save as referred to above) in respect of any documents, statements or other information contained on these pages and no representation or warranty, express or implied, is made by Berenberg or any of its affiliates as to the accuracy, completeness or sufficiency of the documents or other information contained on these pages.

The release, publication or distribution of the documents or other information contained on these pages may be restricted by law in certain jurisdictions. Persons into whose possession any of the documents or other information contained on these pages come should inform themselves about and observe any such restrictions. Any failure to comply with any such restrictions may constitute a violation of the securities laws or regulations of such jurisdiction.

The documents or other information contained on these pages may not be forwarded or distributed to any other person and may not be reproduced in any manner whatsoever. Any forwarding, reproduction, distribution or disclosure of this information in whole or in part is unauthorised and may result in a violation of the Securities Acts or the applicable laws of other jurisdictions.

Documents or other information contained on these pages, including those related to the Offering and admission of the Company’s securities to trading, include statements that are, or may be deemed to be, “forward-looking statements”. These forward-looking statements, which may use words such as “aim”, “anticipates”, “believe”, “intend”, “estimate”, “expect” and words of similar meaning, include all matters that are not historical facts. These forward-looking statements involve risks and uncertainties that could cause the actual results of operations, financial condition, liquidity, dividend policy and the development of the industries in which the Company’s businesses operate to differ materially from the impression created by the forward-looking statements. These forward-looking statements speak only as at the date of the document or other information concerned. In light of these risks, uncertainties and assumptions, the events described in the forward-looking statements may not occur.

By proceeding to view the materials to which this gatepost gives access, you warrant that you have read and understand the statements above, are located in the United Kingdom, are not located in or accessing this website from the United States, Australia, Canada, the Republic of South Africa or Japan or any other Restricted Jurisdiction, are not a U.S. Person (as defined in Regulation S under the Securities Act) or otherwise resident in the United States or any other Restricted Jurisdiction, you are not investing or otherwise acting for the account or benefit of a US Person or a resident of the United States or any other Restricted Jurisdiction, you are accessing this website for information purposes only and agree that you will not transmit or otherwise send any information contained in this website to any person outside the United Kingdom, including in the United States, Australia, Canada, the Republic of South Africa, Japan any member state of the EEA or any other Restricted Jurisdiction, to any US Person or to publications with a general circulation in the United States.

Disclaimer

This communication is an advertisement and does not constitute a prospectus and investors must subscribe for or purchase any shares referred to in this communication only on the basis of information contained in the prospectus published by Harmony Energy Income Trust plc on 15 October 2021 (the “Prospectus“) and not in reliance on this video. A copy of the Prospectus is, subject to certain access restrictions, available for inspection on the Company’s website: www.heitp.co.uk and at the registered office of the Company. This communication does not constitute, and may not be construed as, an offer to sell or an invitation to purchase, investments of any description, or a recommendation regarding the issue or the provision of investment advice by any party.

This communication is only addressed to, and directed at, persons in the United Kingdom who are “qualified investors” within the meaning of Article 2(e) of the Prospectus Regulation (“Qualified Investors“).  For the purposes of this paragraph, the expression “Prospectus Regulation” means the UK version of Regulation (EU) 2017/1129 of the European Parliament and of the Council of 14 June 2017 on the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market, and repealing Directive 2003/71/EC, which is part of UK law by virtue of the European Union (Withdrawal) Act 2018, as amended by The Prospectus (Amendment, etc) (EU Exit) Regulations 2019.

In addition, in the United Kingdom, this communication is being distributed only to, and is directed only at, Qualified Investors (i) who have professional experience in matters relating to investments who fall within the definition of “investment professional” in Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, as amended (the “Order“), or (ii) who are high net worth companies, unincorporated associations and partnerships and trustees of high value trusts as described in Article 49(2) of the Order, or (iii) other persons to whom it may otherwise lawfully be communicated (all such persons together being referred to as “relevant persons“).  Any investment or investment activity to which this communication relates is available only to and will only be engaged in with relevant persons.  This communication must not be acted on ora relied on in the United Kingdom, by persons who are not relevant persons.

By proceeding to view the materials to which this gatepost gives access, you warrant that you have read and understand the statements above, are located in the United Kingdom, are a relevant person for the purposes of the Order, are not located in or accessing this website from the United States, Australia, Canada, the Republic of South Africa or Japan or in any other jurisdiction in which such offer or invitation is restricted or not authorised or to any person to whom it is unlawful to make such offer or solicitation, are not a U.S. Person (as defined in Regulation S under the U.S. Securities Act of 1933) (each a “Restricted Jurisdiction“) or otherwise resident in the United States or any other Restricted Jurisdiction, you are not investing or otherwise acting for the account or benefit of a U.S. Person or a resident of the United States or any other Restricted Jurisdiction, you are accessing this website for information purposes only and agree that you will not transmit or otherwise send any information contained in this website to any person outside the United Kingdom, including in the United States, Australia, Canada, the Republic of South Africa, Japan or any other Restricted Jurisdiction, to any U.S. Person or to publications with a general circulation in the United States.