Anti-money laundering, anti-bribery and “know your client” processes: 
To fulfill our regulatory and legal obligations relating to the prevention of money laundering, anti-bribery, fraud prevention, counter-terrorist financing, politically-exposed-persons checks, sanctions checks and any other “know your client” checks. We may use third party services, such as the Fund’s administrators or third-party screening service providers to help with these Processes. This includes confirming and verifying your identity; and screening against lists maintained by a third party which assists with this process (such as sanctions lists from governments around the world, as well as other information about individuals on this list which may include information about criminal convictions, which has been obtained from publicly available sources, such as newspapers and companies registries).

∙ Where the processing is required by law or regulation;

∙ Where the processing is necessary for us to perform a contract with you, or to take steps at your request prior to entering a contract; and

∙ Where we have a legitimate interest in carrying out the processing for undertaking “know your client” processes such as for the purpose of preventing money laundering, bribery, sanctions violations and detecting and protecting against fraud (unless your interests outweigh these interests).

Administration of your investment: 
To enable the Fund, the Investment Manager and the Fund’s administrator to assess and process your subscription application, administer your investment in shares of the Fund issuing and redeeming shares, receiving payments, and making payments to the applicants and maintain Shareholders’ registers.

∙ Where the processing is required by law or regulation;

∙ Where the processing is necessary for us to perform a contract with you, or to take steps at your request prior to entering into a contract; and

∙ Where we have a legitimate interest in carrying out the processing for the purpose of administering your investment in the Fund (unless your interests outweigh these interests).

Provision of investor services:

To enable the Fund, the Investment Manager and the Fund’s service providers to inform you about your investment in the Fund, to perform investor servicing functions in respect of your investment; and to update and maintain records and to provide the net asset value calculation of the Fund and other calculations.

∙ Where the processing is required by law or regulation;

∙ Where the processing is necessary for us to perform a contract with you, or to take steps at your request prior to entering into a contract; and

∙ Where we have a legitimate interest in carrying out the processing for the purpose of providing investor services to you (unless your interests outweigh these interests).

Relationship management: 
To enable us to efficiently manage our relationship with you or your business, keeping our records up to date, maintaining records of services provided and our interactions with you, including responding to any complaints we may receive from you and to seek to resolve these.

∙ Where the processing is required by law or regulation;

∙ Where the processing is necessary for us to perform a contract with you, or to take steps at your request prior to entering into a contract; and

∙ Where we have a legitimate interest in carrying out the processing for the purpose of managing our relationship with you efficiently (unless your interests outweigh these interests).

Manage service provider and distributor / intermediary relationships: 
To enable us to efficiently manage how we work with other companies that provide services to us.

∙ Where the processing is required by law or regulation;

∙ Where the processing is necessary for us to perform a contract with you, or to take steps at your request prior to entering into a contract; and

∙ Where we have a legitimate interest in carrying out the Processing for the purpose of managing how we work with other companies that provide services to us (unless your interests outweigh these interests).

Business, financial and risk management: 
To run our business in an efficient and proper manner, including audit, risk management processes, managing our financial position, business capability, planning, communications, corporate governance, and service provider management.

∙ Where the processing is required by law or regulation;

∙ Where the processing is necessary for us to perform a contract with you, or to take steps at your request prior to entering into a contract; and

∙ Where we have a legitimate interest in carrying out the processing for managing and operating the affairs of our business, and for the efficient management of our business as a whole (unless your interests outweigh these interests).

Legal and regulatory compliance: 
To comply with our legal and regulatory obligations, including “know your client” processes, the automatic exchange of tax information and legal judgements. To detect, investigate and prevent breaches of internal and regulatory policies, and criminal offence in accordance with applicable laws and regulations, including establishing, exercising, and defending our legal rights.

∙ Where the processing is required by law or regulation;

∙ Where we have a legitimate interest in carrying out the processing for the purpose of risk management, detecting and protecting against breaches of policies and applicable laws and regulations, and for establishing, exercising and defending our legal rights (unless your interests outweigh these interests).