This important information relates to Alquity Group Limited, Alquity Investment Management Limited (“AIML”), Alquity (Asia) Limited, and its products including the Alquity Indian Subcontinent Fund (collectively “Alquity”). AIML is authorised and regulated by the Financial Conduct Authority in the United Kingdom.

Please read these terms and conditions carefully and before proceeding. Together with the privacy policy, they govern our relationship with you in relation to this website. If you have any questions about them or do not wish to accept them, please contact us before using this website.

Restricted Access

This website is not directed to any person in any jurisdiction which prohibits the publication or availability of this website or where such publication or availability would subject any Alquity entity to any registration requirement within such jurisdiction.

Please do not access the website if the publication or availability of this website is in any way prohibited in your jurisdiction. Persons in respect of whom such prohibitions apply must not agree to these conditions. It is your responsibility to be aware of and to observe all the applicable laws and regulations of your jurisdiction. If you are in any doubt, please do not proceed and consult with your professional advisers as to whether you require any governmental or other consents or need to observe any formalities to enable you to access the information. By proceeding, you are representing and warranting that the applicable laws and regulations of your jurisdiction allow you to access the information.


Alquity maintains this site for distribution to, and use by, its site visitors. Any application for Alquity’s products or services should be made only after review of the applicable Prospectus or Offering Memorandum and the terms and conditions applicable to such products or services. Any information, including the Prospectus, in respect of applications can be obtained from Alquity.   Please see our contact details that are listed below.

Stewardship Code

Under the FCA Rules, AIML is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.

AIML is an emerging markets fund manager with a Luxembourg UCITS IV Fund. AIML does not take an activist shareholder approach. Consequently, while AIML supports the general objectives and principles that underlie the Code, the provisions of the Code are not relevant to the type of trading currently undertaken by AIML. If AIML’s investment strategy changes in such a manner that the provisions of the Code become relevant, AIML will amend this disclosure accordingly.

No Offer or Advice

This site is intended as a general introduction to Alquity and its products. The material on this website has been prepared for informational purposes only and is NOT INTENDED TO AND SHALL NOT IN ANY WAY CONSTITUTE AN INVITATION, AN OFFER OR SOLICITATION to invest in any investment products. Information contained in this website DOES NOT CONSTITUTE INVESTMENT ADVICE.

Any decision in respect of investments should be made solely upon the information contained in the relevant offering documents, including the Key Investor Information Document (“KIID”) which forms an integral part of the legally and regulatory required documentation. The KIID is a strictly regulated document with respect to its form and content and focuses on key elements of the investment objectives, risk, costs and historic performance. The KIID is updated on no less than an annual basis and upon the modification of any material parameters. The latest KIID must be consulted prior to any investment decision. Upon request all other legally and regulatory required documentation (prospectus, annual and semi-annual financial statements, etc.) will be provided.

The latest KIIDs, as applicable and other material investor information is available on this website. Potential investors should read the relevant offering documents carefully for further details including the risk factors before any investment decision is made. Prospective investors should consult their own professional advisers, stock brokers, lawyers, accountants, tax consultants, bank managers or any other professional advisers they consider necessary before making an investment.

Nothing in this website constitutes investment, legal or other advice nor is it to be relied upon in making an investment decision. Nothing in this website constitutes an offer or an invitation to make an offer to sell securities or to provide investment services of any description.

Risk Notice

Please refer to the applicable KIID, Prospectus or Offering Memorandum for details regarding the relevant risk factors to be taken into account, before making an investment.


If you wish to make a complaint about this website, please send a written complain to the Compliance Officer at the following address: Alquity Investment Management, 9 Kingsway, London, WC2B 6XF

Accuracy of Information

Any geographic, political, economic, statistical, financial and exchange rate data may in certain cases be presented in approximate or summary or simplified form and may change over time. Any reference to any specific company, financial product or asset class in whatever way is used for illustrative purposes only and does not constitute a recommendation on the same. While all the reasonable care has been taken in preparing the material on this website, no warranty whatsoever is given and no responsibility or liability is accepted for any loss arising directly or indirectly in connection with or as a result of any person acting on any information, opinion or statement expressed in the same. The information is not guaranteed as to accuracy, nor is it a complete statement of the financial products or markets referred to. Opinions expressed are subject to change without notice. The views expressed herein do not necessarily reflect the views of the Alquity Group, AIML or Asia as a whole or any part thereof, nor do they constitute investment or any other advice.

Links to External Websites

The website also contains links that lead to other websites. These links are provided solely for your convenience and do not constitute any endorsement, sponsorship or approval of the material in such sites.


The information contained on this site is subject to copyright with all rights reserved. Except as maybe expressly authorized, no information or material contained on this site may be reproduced, transmitted, displayed or commercially exploited in whole or in part without the written consent of Alquity.


Your use of this website and reliance on the information herein are entirely at your own risks. In no event shall any Alquity entity, or any of its subsidiaries or affiliates, and their respective officers, directors, employees, representatives, agents, information providers, service providers, suppliers, licensors and licensees, and all other related, associated, or connected persons be liable for any loss, damage or injury to any data, income, goodwill, property or third parties, whether it be direct, indirect, special, punitive, exemplary, consequential or incidental, caused by or arising out of or in relation to (i) the use of access of this website and the information therein or (ii) any failure of performance, error, omission, interruption, deletion, defect, transmission blackout, incorrect data transmission, delay in operation, computer virus or other destructive items. Where a claim is brought against Alquity, or any Alquity entity, by a third party in relation to your use of this website, you hereby agree to fully reimburse Alquity for all losses, costs, actions, proceedings, claims, damages, expenses (including reasonable legal costs and expenses), or liabilities, whatsoever suffered or incurred directly by Alquity or any Alquity entity as a consequence of improper use of this website. Neither party should be liable to the other for any loss or damage which may be suffered by the other party due to any cause beyond the first party’s reasonable control including without limitation any power failure.

Decisions based on information contained herein are the sole responsibility of the user, and in exchange for using this site, the user agrees to hold Alquity harmless against any claims for damages arising from any decisions the user makes based on such information.





Alquity Investment Management Ltd (AIML) is the Investment Manager for the Alquity SICAV, a Luxemburg domiciled UCITS fund.  AIML is regulated by the Financial Conduct Authority (FCA).

AIML is classified as a “BIPRU €50k limited licence firm” and its Pillar 1 capital resources are set at the higher of €50k or its Fixed Overheads Requirement of £762k. AIML held Tier 1 capital totalling £2,242k as at 30 June 2018 and this exceeded the Pillar 1 requirement by 194%.

AIML has carried out its own assessment of the amount of capital required to cover its business needs and risks, as required to determine its Pillar 2 capital resources requirement. Based on this assessment AIML has sufficient capital to meet its Pillar 1 and 2 capital resources requirements.

Risk Management

AIML has established a risk management framework predicated on the need to manage the full range of risks facing the Firm including market, credit, liquidity, operational, third party and regulatory risk. This assesses each risk for the likelihood of its occurrence and its impact, after allowing for the controls in place. AIML continually monitors its current and future capital requirements through this risk management framework.

Operational risk

Operational risk continues to represent the greatest potential risk of loss for AIML.  AIML has a risk register which is kept update and is an effective self assessment of operational risk considering the likelihood and impact of operational risks materialising. It is recognised that operational risk is inherent in any business process and we seek to manage this by maintaining a robust control environment which includes documented policies and procedures which incorporate appropriate checks and balances.  Assurance is provided by the Compliance Officer and Senior staff at AIML and Saffery Champness which performs the financial audits.

Market risk

AIML does not have the regulatory permissions to deal on its own account and the main market risk for Investment Managers is in relation to foreign exchange exposure.  AIML is not materially affected by risks arising from foreign exposures but risk weights all long and short foreign exchange positions at 8% in order to calculate the CRR.

Credit risk

The main credit risks for AIML are from (i) the counterparties which surplus cash has been deposited and (i) the risk of clients not paying invoices raised by AIML as fees for the funds under management. Given that AIML banks with Barclays Bank and the nature of the main client base being Luxembourg SICAVs and the processes we have for collecting and managing receivables, we would consider this to be a low risk.

Significant Redemptions

The business is at risk from unfavorable cyclical movements that would lower the value of the underlying assets of the funds or increase the volatility of the markets making fund management more difficult, thereby reducing performance that may lead to redemptions and ultimately lower management fees.

Loss of Key Personnel

Staff members may leave the firm for a variety of reasons, taking with them crucial information and skills required for the operation of the business.  The firm ensures that there are documented procedures to maintain work flows in the short-term.  This supports the ongoing approach by all staff members to cross-review and learn each others roles to the extent practicable.

Reputational Damage from Operational Errors

The reputation of the firm is at risk of being damaged at all times by way of poor controls around investor communication and payments.  This could have a lasting negative impact and is therefore closely monitored by the operations team.  The firm uses the services of an independent reputable Administrator and this relationship is managed by the operations team as well.  Combined with an ongoing re-assessment of systems and procedures, the risk of operational errors is mitigated.

Group Risk aggregation

AIML is owned by Alquity UK Limited and ultimately the shareholders of Alquity UK Limited. It is not part of a group in that all the entities within the structure have the same common goal of investment management.



Alquity treats your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you.  Alquity use your personal information in accordance with the following Data Protection Policy and will fully comply with all applicable UK data protection legislation.

All information provided to Alquity through this website is used solely by Alquity and is not sold or provided to any other company. Personal financial information and information about our investors is regarded as private, and as such is not shared with anyone in any manner, regardless of the method by which we obtained such information. Nonetheless, Alquity reserves the right to cooperate fully with state, local, federal, and international officials in any investigation relating to any content (including personal or private electronic communication transmitted on the Alquity site) or purported unlawful activities of any user of the Alquity site.

  1. What does Alquity do with your information?
 We may process, transfer and disclose your personal information for the purposes of:
Providing you with services, managing your accounts and complying with your instructions
Verifying your identity, taking credit decisions 
Detecting and preventing fraud 
Compliance with laws and public duties monitoring and/or recording our telephone calls and electronic transactions with you in order to accurately carry out your instructions, to assist in improving our services and in the interests of security and crime prevention 
Market research and providing you with information via mail, telephone or other means about any Group company’s products or services from time to time; and
analysis in order to assess and improve our business or the business of the Group and the services we offer
  2. What about cookies?
 Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognise your browser and to provide you with certain features and information.
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether.

Please note that when you confirm that you have read this important information we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this site on a later occasion. The cookie will expire when you close your browser or sooner should there be a change to this important information. A cookie is a small data file. Such cookies do not retrieve information about you stored on your hard drive and do not corrupt or damage your computer or computer files. You are not obliged to accept a cookie that we send you, and you can in fact modify your browser so that it will not accept cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.

  1. Will Alquity pass your information on? 
We will never sell, rent or trade your personal information to an outside company.
Your personal information may however be passed to and used by companies within the Alquity Group and our agents and sub-contractors who administer or process the information on our behalf. Please write to: Compliance Officer, Alquity Investment Management Limited, 9 Kingsway, London, WC2B 6XF or email complianceofficer@alquity.com for an up to date list of the companies within the Alquity Group.

International transfer:
 Alquity is an international business with processing units based in many different geographical locations. As a result, we may transfer or process your personal information outside the European Economic Area (EEA) to such countries that may not offer the same level of data protection as the United Kingdom.

  1. Access rights
 You have a right to access the personal data that is held about you. To obtain a copy of the personal information Alquity holds about you, you should write to: Compliance Officer, Alquity Investment Management Limited, 9 Kingsway, London, WC2B 6XF or email complianceofficer@alquity.com. We will respond to you within 40 days of receipt of the request and we will charge the statutory rate for this service which at present is £10.
If there are any inaccuracies in the information we hold about you, please notify us of this in order that we may correct the information that we hold about you.
  2. How to opt-out 
If you do not want to receive information about any Group company’s products or services please let us know. Please note that if you let us know but decide later that you do not want to receive any such information just let us know by telephoning us on 020 7557 7850 or by writing to: Alquity Investment Management Limited, 9 Kingsway, London, WC2B 6XF

If you have any comments or questions about our Data Protection Policy please telephone us on 020 7557 7850 or write to: Compliance Officer, Alquity Investment Management Limited, 9 Kingsway, London, WC2B 6XF or email complianceofficer@alquity.com