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Sustainability-Related Disclosure for Financial Products That Promote Environmental or Social Characteristics

Sustainability-Related Disclosure for Financial Products That Promote Environmental or Social Characteristics

Dated 25 June 2024 

Harmony Energy Income Trust plc (the “Company”) is a financial product as defined in Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “Disclosure Regulation”). The Company is not within the scope of the Disclosure Regulation, because it is not marketed into the EU, however if it was within the scope of the Disclosure Regulation it would be categorised as a financial product which promotes environmental or social characteristics, within the meaning of Article 8 of the Disclosure Regulation. The Company has elected to prepare a report on a voluntary basis as if it were within the scope of the Disclosure Regulation.

(a) Summary;

The environmental characteristics promoted by the Company are the provision of support for the renewable energy transition and climate change mitigation, which it achieves through investment in grid-scale battery energy storage system (“BESS”) assets.  

This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment. 

The Company’s investment objective is to provide an attractive and sustainable level of income returns, with the potential for capital growth, by investing in commercial-scale BESS and renewable energy generation projects, with an initial focus on a diversified portfolio of BESS located in Great Britain.  

The following aspects of the investment strategy are binding on all investments held by the Company. 

  • Investment policy and restrictions: The Company’s investment focus is restricted to investments in energy storage and complementary renewable energy generation assets. Investments in all other areas are, by definition, excluded, and there is an express prohibition on investments in fossil fuels. 
  • Investment screening: Harmony Energy Advisors Limited (the “Investment Adviser”) and the Alternative Investment Fund Manager (“AIFM”) are responsible for assessing target acquisitions against the Company’s investment policy and investment restrictions for suitability. 

100% of the investments held by the Company are allocated to BESS, which meet the environmental characteristics promoted by the Company. Upon acquiring capital, the Company will hold the capital as cash and cash equivalents until it is allocated to investment projects aligned with the Company’s investment strategy. 

The following indicators are used to measure the attainment of each environmental characteristic:  

  • Storage capacity of operational BESS assets (MWh / MW): this indicator measures the total storage capacity of operational BESS assets.  
  • Storage capacity of BESS assets under construction (MWh / MW): this indicator measures the total storage capacity of BESS assets under construction. 
  • Total Renewable Energy Stored by the Company’s BESS assets (MWh): this indicator measures the renewable electricity stored by the Company’s assets. 
  • Estimated GHG emissions avoided by the Company’s BESS assets (tCO2e): this indicator measures greenhouse gas emissions avoided by the Company’s BESS assets during different modes of operation including wholesale trading actions, balancing mechanism actions and ancillary services actions. 

The Company has collaborated with a third-party sustainability consultancy to develop methodologies and identify suitable data sources for assessing the attainment of each environmental characteristic. These are summarised in the disclosure below. The data for these indicators are collected and processed by the Investment Adviser. 

The main limitation outlined in the disclosure is associated with the indicator on estimated GHG emissions avoided (tCO2e). Whilst the Company’s methodology aligns with both the EU and the Greenhouse Gas (“GHG”) Protocol for assessing avoided GHG emissions, further improvements can be made. For example, this methodology solely incorporates the overall carbon avoidance for the UK grid and does not capture the impact the storage systems have on the marginal carbon intensity from daily import and export services. 

The Company conducts sustainability-related due diligence on target assets as part of its approach to integrating sustainability risk into its investment process. 

Due to the nature of the Company’s portfolio, comprised of wholly owned SPV project companies, sustainability and Environment, Social, and Governance (“ESG”) matters are managed at the fund level.  Accordingly, the Company does not engage with “investee companies” (SPVs) on ESG matters as part of its ESG approach. 

The Investment Adviser and the Board of Directors are responsible for engagement with external stakeholders such as shareholders, suppliers and service providers in relation to the continued implementation of the Company’s ESG strategy throughout the asset lifecycle.  

To support the Company’s ESG Strategy and communicate the Company’s ESG objectives, the Company has adopted a suite of applicable policies including the Environmental Policy, Human Rights Policy, and Supplier Code of Conduct. The commitments made within these policies will be delivered by the Company’s key suppliers and service providers, who work together to monitor, manage, and report ESG performance across the asset lifecycle and any relevant supply chain activities. 

The Company has not designated an index as a reference benchmark.

(b) No sustainable investment objective;

This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.

(c) Environmental or social characteristics of the financial product;

The environmental characteristics promoted by Company are the provision of support for the renewable energy transition and climate change mitigation, which it achieves through investment in grid-scale BESS assets. 

The Company’s BESS assets support the renewable energy transition through their role in enabling the integration of more electricity from renewable sources into the electricity grid and reducing reliance on fossil fuel-based electricity generation. In doing so, the Company’s BESS assets contribute to climate change mitigation through the avoidance of GHG emissions from the electricity generation sector.  

The Company’s BESS assets provide grid stability services and help to balance supply and demand of electricity, storing electricity as it is generated and exporting it to the grid during times of peak demand. By storing excess electricity from renewable sources, the Company’s BESS assets prevent curtailment (i.e. renewable energy assets being paid to stop generating) and allow energy from renewable sources to contribute a greater proportion of the energy mix. Grid stability and balancing services have traditionally been provided by fossil fuel-based generation assets, which emit GHG emissions.  Therefore, the use of BESS for these services reduces the need for fossil fuel-based electricity generation and avoids GHG emissions associated with the combustion of fossil fuels.

(d) Investment objective and strategy;

The Company’s investment objective is to provide an attractive and sustainable level of income returns, with the potential for capital growth, by investing in commercial-scale BESS and renewable energy generation projects, with an initial focus on a diversified portfolio of BESS located in Great Britain.  

The following elements of the investment strategy are binding on all investments selected by the Company. 

Investment policy and restrictions: The Company’s investment focus is restricted to investments in energy storage and complementary renewable energy generation assets. Investments in all other areas are, by definition, excluded, and there is an express prohibition on investments in fossil fuels.     

Investment screening: the Investment Adviser and the AIFM are responsible for assessing target acquisitions against the Company’s investment policy and investment restrictions for suitability.  

Good governance practices are also assessed and monitored as detailed in Annex II on the Company’s website.

(e) Proportion of investments; 

100% of the investments held by the Company are allocated to BESS (as per the asset table below), which meet the environmental characteristics promoted by the Company. 

Upon acquiring capital, the Company will hold the capital as cash and cash equivalents until it is allocated to investment projects aligned with the Company’s investment strategy. The fund’s cash balance as of 31 October 2023 was £18m, representing 6.9% of the fund.

Project Capacity Status 
Pillswood 196 MWh / 98 MW Operational 
Broadditch 22 MWh / 11 MW Operational 
Farnham 40 MWh / 20 MW Operational 
Rusholme 70 MWh / 35 MW Under Construction Target COD: H2 2024. 
Bumpers 198 MWh / 99 MW Operational 
Little Raith 99 MWh / 49.5 MW Operational 
Wormald Green 66 MWh / 33 MW Under Construction Target COD: H2 2024. 
Hawthorn Pit 99.8 MWh / 49.9 MW Under Construction Target COD: H2 2024. 

COD: Commercial operations date.  

Derivatives are used by the Company (via its subsidiary, HEIT Holdings Ltd) for interest rate hedging purposes to manage its exposure to interest rate risk. The Company does not make derivative transactions for speculative purposes. Derivatives are not used to attain the environmental characteristics promoted by the Company. 

(f) Monitoring of environmental or social characteristics;  

The following indicators are used to measure the attainment of the environmental characteristics:  

  • Storage capacity of operational BESS assets (MWh / MW): this indicator measures the total storage capacity of operational BESS assets.  
  • Storage capacity of BESS assets under construction (MWh / MW): this indicator measures the total storage capacity of BESS assets under construction. 
  • Total renewable energy stored by BESS assets (MWh): this indicator measures the renewable electricity stored by the Company’s assets. 
  • Estimated GHG emissions avoided by BESS assets (tCO2e): this indicator measures greenhouse gas emissions avoided by the Company’s BESS assets during different modes of operation including wholesale trading actions, balancing mechanism actions and ancillary services actions.  

The above indicators and other sustainability indicators, including the 14 mandatory SFDR Principal Adverse Impact (“PAI”) indicators, are collected and monitored by throughout the investment cycle by the Investment Adviser.

(g) Methodologies;

The Company has collaborated with a third-party sustainability consultancy to develop methodologies and identify suitable data sources for assessing the attainment of each environmental characteristic, which are outlined as follows: 

  1. Storage capacity of operational BESS assets (MWh / MW): this indicator is calculated by totalling the storage capacity of the operational assets invested in by the Company during the reference period.  
  1. Storage capacity of BESS assets under construction (MWh / MW): this indicator is calculated by totalling the storage capacity of the assets under construction invested in by the Company during the reference period. 
  1. Total renewable energy stored by the Company’s BESS assets (MWh): this indicator is calculated using half-hourly asset-specific energy data combined with energy generation mix data from the National Grid.  
  1. Estimated GHG emissions avoided by the Company’s BESS assets (tCO2e): this indicator calculates the GHG emissions avoidance of BESS in each mode of operation:
    • The GHG emissions avoidance of a BESS project during wholesale trading and balancing mechanism actions is calculated as the difference in the emissions between the actual scenario where the BESS is in use and a hypothetical, ‘business as usual’ scenario when the BESS is not in use. In the first scenario, the supply of electricity to the grid is provided by the BESS assets; in the second, business as usual scenario, it is provided by a gas-peaker plant. Emissions associated with system efficiency losses are incorporated into the calculations. 

      GHG avoidance = (emissions of the hypothetical gas-peaker plant scenario) – (emissions of the BESS (wholesale trading and balancing mechanism) scenario) 
    • The GHG emissions avoidance of a BESS project during ancillary service use is calculated as the difference in the emissions between the actual scenario where the BESS is in use and a hypothetical, ’business as usual’ scenario where ancillary services are provided by running a combined cycle gas turbine (CCGT) plant. It is assumed the CCGT would be running at a reduced efficiency of 45% as the usual case in this scenario. 

      GHG avoidance = (emissions of the hypothetical CCGT scenario) – (emissions of the BESS (ancillary services) scenario) 

The Company has published a PAI report on its website and reported on the methodology used to calculate all the mandatory PAI indicators.

(h) Data sources and processing; 
  1. Storage capacity of operational BESS assets (MWh / MW): the data for this indicator is collected and processed by the Investment Adviser. 
  1. Storage capacity of BESS assets under construction (MWh / MW): the data for this indicator is collected and processed by the Investment Adviser. 
  1. Renewable energy stored by the Company’s BESS assets (MWh): renewable energy for this metric includes wind, solar, biomass, geothermal, and hydroelectric generation, and excludes coal, gas, nuclear, imported or ‘other’ energy sources categorised by the National Grid’s API. For the reference period, a total of 30,938 MWh imported by the operational portfolio was derived from renewable sources, constituting 36% of the total electricity imported. The data for this indicator is collected by the Investment Adviser.  
  1. Estimated GHG emissions avoided by the Company’s BESS assets (tCO2e): the asset-specific total energy data is sourced from the battery manufacturer’s data platform (e.g., Tesla’s Powerhub API) and weekly revenue reports. The generation mix is sourced from the National Grid’s API. The emissions factor for a gas-fired plant and a CCGT plant in the UK is sourced from the Department of Energy Security and Net Zero’s annual fuel mix disclosure table under ‘Natural Gas’. The data for this indicator is collected by the Investment Adviser, with no estimation necessary. 
(i) Limitations to methodologies and data;
  1. Storage capacity of operational BESS assets (MWh / MW):  no limitations noted. 
  1. Storage capacity of BESS assets under construction (MWh / MW): no limitations noted. 
  1. Total renewable energy stored by the Company’s BESS assets (MWh): electricity comes from a wide range of sources across the UK, and some sources of generation may be more local to a given area instead of even distribution nationally through the National Grid’s high-voltage transmission network. Therefore, the electricity generation mix provided by some electricity suppliers differs from National Grid’s stated national average.  
  1. Estimated GHG emissions avoided by the Company’s BESS assets (tCO2e): whilst the Company’s methodology aligns with both the EU and the GHG Protocol for assessing avoided GHG emissions, further improvements can be made. For example, this methodology solely incorporates the overall carbon avoidance for the UK grid and does not capture the impact the storage systems have on the marginal carbon intensity from daily import and export services. Future developments in this regard will be closely monitored to ensure the methodology is aligned with current best practice guidance to provide the most accurate assessment of the carbon avoidance potential of BESS. 

The Company has published a PAI report on its website and reported on the limitations to methodologies and data used to calculate all the mandatory PAI indicators. 

(j) Due diligence;

The Company conducts sustainability-related due diligence on target assets as part of its approach to integrating sustainability risk into its investment process, as described below. The Company’s Responsible Investment Policy provides a full overview of the process.   

Prior to recommending any asset for acquisition, the Investment Adviser performs detailed due diligence on potential investments. The due diligence includes an assessment of the ESG characteristics and performance of target assets. A list of transaction-specific ESG issues forms the basis of this assessment and includes consideration of climate- and nature-related risks in line with the Taskforce on Climate-Related Financial Disclosures and Taskforce on Nature-related Financial Disclosures guidance. PAIs of investment decisions will be considered for future acquisitions as part of the due diligence process. 

The Investment Adviser produces a detailed due diligence report covering any potential investments that meet the initial screening criteria. This report details ESG risks and opportunities identified during the due diligence process. The Investment Adviser considers any ESG due diligence analysis conducted by third-party specialists and may include findings in the due diligence report. 

Following pre-investment due diligence, the Investment Adviser provides the due diligence report, covering ESG risks and opportunities, to the AIFM and to the Company’s Board. The AIFM assesses whether the proposed investment is appropriate for the Company in accordance with the Company’s investment policy, Responsible Investment Policy and ESG Policy before making a formal recommendation to the Company’s Board. The Company’s Board must approve all investment recommendations prior to any investment proceeding. ESG is an important consideration in the Board’s decision making. 

Pre-acquisition ESG due diligence on suppliers is also performed, and key suppliers are required to adhere to the Company’s Supplier Code of Conduct, which aligns with international standards and best practices.  

Good governance practices are also assessed and monitored as detailed in Annex II on the Company’s website.

(k) Engagement policies;

Due to the nature of the Company’s portfolio, comprised of wholly owned SPV project companies, sustainability and ESG matters are managed at the fund level. Accordingly, the Company does not engage with “investee companies” (SPVs) on ESG matters as part of its ESG approach. 

The Investment Adviser and the Board of Directors are responsible for engagement with external stakeholders such as shareholders, suppliers and service providers in relation to the continued implementation of the Company’s ESG strategy throughout the asset lifecycle.  

To support the Company’s ESG Strategy and communicate the Company’s ESG objectives, the Company has adopted a suite of applicable policies including the Environmental Policy, Human Rights Policy, and Supplier Code of Conduct. The commitments made within these policies are delivered by the Company’s key suppliers and service providers, who work together to monitor, manage, and report ESG performance across the asset lifecycle and any relevant supply chain activities. 

(l) Designated reference benchmark.  

The Company has not designated an index as a reference benchmark.  

Transparency of remuneration policies in relation to the integration of sustainability risks

Sustainability risks are not integrated into the Company’s remuneration policies. There are no performance-related elements (including in relation to the integration of sustainability risks) to Non-Executive Directors’ fees. The Company does not operate any type of incentive, share scheme or award.

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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.

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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.

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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.