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NEWTON GENERIC IMPORTANT INFORMATION

This page contains important legal information - please read carefully before proceeding further. The information below explains the legal and regulatory restrictions in relation to the information contained on this Website and the countries in which Newton funds are authorised.

Newton Investment Management Limited is authorised and regulated by the Financial Conduct Authority. Registered in England No. 1371973. VAT registration number GB: 577 7181 95. BNY Mellon Fund Managers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England No. 1998251. The registered address of Newton Investment Management Limited and BNY Mellon Fund Managers Limited is BNY Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA. Both firms are members of the IMA. Newton Capital Management Limited is authorised and regulated in the United Kingdom by the Financial Conduct Authority. Registered in England no. 2675952. Newton Capital Management Limited is registered in the United States as an investment adviser under the Investment Advisers Act of 1940.

Only Newton Capital Management Limited and Newton Capital Management LLC offer services in the United States.

All companies cited above are wholly owned subsidiaries of The Bank of New York Mellon Corporation.

Please note that where AUM has been specified on this website, it relates to the Newton Group of companies, including Newton Investment Management Limited, Newton Capital Management Limited and Newton Capital Management LLC. In addition, AUM for the Firm may include assets managed by the firm's officers as dual officers or employees of The Bank of New York Mellon and assets of wrap fee account(s) and high net worth client model(s) for which Newton Capital Management Limited provides advice in the form of non-discretionary model portfolios.

Terms & Conditions of access to the Internet Site of Newton and the Newton Privacy Policy ("the Terms")

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Please read the Terms carefully. By accessing any page of this Website, you agree to be bound by the Terms below. If you do not agree to the Terms below, please do not access any pages of this Website.

These Terms are a legal document setting out your rights and obligations and those of Newton Investment Management Limited (and its Associates as defined in section 1260 of the Companies Act 2006) ("Newton") in relation to the services offered by Newton through this Website ("the Services"). These Terms contain the full and complete understanding between Newton and you relating to this Website or the Services. No advice or information, whether oral or written, obtained by you through or from the Website or from any conversation with Newton staff or a professional financial adviser will operate to vary these Terms.

These Terms may be amended by Newton at any time. Following an amendment to these Terms, this page will be updated to reflect the change, and users of Client zone will also be prompted to read and accept our current Terms the next time they access Client zone.

Please note that the Website may use pop-up windows to display certain types of information. Please therefore ensure that you have disabled pop-up blockers from your browser when using the Website. Newton will not be held liable for any loss incurred as a result of your inability to view information resulting from the use of pop up blockers.

1. Jurisdiction and Governing Law

The Terms and any and all contracts concluded under them are governed by and shall be construed in accordance with the laws of England and Wales and all references in these Terms to laws and regulations are references to English laws and regulations unless otherwise specified. You agree that any dispute/s arising out of the Terms or otherwise between us shall be subject to the exclusive jurisdiction of the Courts of England and Wales.

2. Content of Website

Whilst considerable care has been taken to ensure the information contained within this Website is accurate and up-to-date, no warranty is given as to the accuracy or completeness of any information and no liability is accepted for any errors or omissions in such information. All products referred to on this Website are subject to change without notice. Newton may amend this Website and our products and services at any time with or without notice to you. You agree that Newton shall not be liable to you or to any third party for any amendment, modification, suspension, or discontinuance of the Website or any products or services offered through the Website. Newton accepts no responsibility for any information contained in any website accessed via a hypertext link from this Website. No other UK or other country based person/company may link their website into Newton's Website without the express written permission of Newton. The content, accuracy and opinions expressed in such websites are not checked, analysed, monitored or endorsed by us. Access to any third party website is at your own risk. You agree that Newton has no responsibility or liability for third party websites and that Newton shall not be liable in any way for any damage or loss caused in relation to the content, goods, products or services available through such third-party websites. Users should refresh their browser each time they visit the Website to ensure that they access the most up to date version of the Website.

3. Use of the Website

You agree that you will only use the Website in a way which is consistent with the Terms and which complies with applicable laws and regulations. In particular, you agree that you will not use the Website to send or upload any material containing software, viruses or other codes, programs or files designed to interrupt, destroy, damage or limit the functionality of any computer software, hardware or telecommunications equipment or in any other manner which would interfere with or disrupt the Website.

4. Product Availability

The information contained on this Website does not constitute a distribution, an offer to buy or sell or the solicitation of an offer to buy or sell securities or investments in any jurisdiction or to engage in any other transaction, or to provide any investment advice or service. Some products detailed on this Website are only available to persons in certain named countries. If you are accessing this Website outside the UK, your local legislation may not permit us to offer products to you in your own country. Please check with your professional financial adviser as to whether such products are available in the country in which you are resident.

Persons resident in territories other than the UK should consult their professional financial advisers as to whether they require any governmental or other consents or need to observe any formalities to enable them to invest in Newton products described in this Website. The provision of the information in this Website does not constitute an offer to purchase securities to any person in the United States or to any U.S. Person as such term is defined under the United States Securities Act of 1933, as amended.

5. Advice

Information contained within this website should not be construed as advice on the merits of suitability of its products. No information or advice, whether oral or written obtained from Newton, through this Website or otherwise, shall create any warranty.

Newton only provides information about its own products and services. Newton believes that it is important that any investments you make are suitable for your needs. Therefore we recommend prior to making an investment into any of our products you consult with a professional financial adviser who will be able to consider your particular investment and help you to determine which is most appropriate for your circumstances.

6. Taxation

Except where stated otherwise, the contents of this Website are based on Newton's interpretation of United Kingdom taxation law and practice as at the date appearing at the foot of each product fact sheet.

While we believe this interpretation is correct, we can give no guarantee that tax reliefs and the tax treatment of funds will remain the same in the future. The value of any tax reliefs will depend on individual financial circumstances and the country of residence of the relevant investor. If you are in any doubt, you are advised to consult your professional financial adviser.

7. Liability

To the extent permitted by law, Newton accepts no legal liability for loss, damages or expenses of any kind including (without limitation) direct, indirect, incidental, special or consequential losses, damages or expenses, or loss of any profit, goodwill or reputation, even if expressly advised of the possibility of such loss, damages or expenses, which you may suffer or incur directly or indirectly by you accessing this Website or from your inability to access this Website.

Nothing in these Terms seeks to exclude or restrict any duty or liability Newton has under the Financial Services and Markets Act 2000 or otherwise under the regulatory system in the United Kingdom.

Newton reserves its right to restrict, suspend or terminate your use of this Website at any time in Newton's absolute discretion including without limitation where it believes that you have not acted in accordance with these Terms. Newton will use all reasonable efforts to keep this Website operational at all times.

Newton does not guarantee the Website or that use of the Website will be free from fault or error nor that the Website will be permanently accessible. Access to the Website may be interrupted or restricted for routine or emergency maintenance or repairs or to introduce new facilities, products, functionality or services. Newton cannot be held responsible for any disruptions inherent in the operation of the Internet and the World Wide Web including viruses beyond Newton's control and Newton excludes all liability for direct and indirect losses thereby caused or contributed to. Newton encourages the use of antivirus programmes so that you can protect your computer from viruses and other malware.

8. 'Client zone' Service

In addition, the following applies to the Newton Client zone facility:

"Client zone" is a secure section of the Website that provides online access to certain information relating to your investment account. Information available via "Client zone" includes the valuations of the holdings in your account (which may include audited periodic valuation statements as well as unaudited daily and periodic valuations of the holdings in your account) and the most recent unaudited stock transactions. Unaudited information has not been reconciled, reviewed or finalised by Newton. The unaudited daily and periodic valuations and unaudited stock transactions are provided by way of information only. Newton cannot guarantee the accuracy of, and shall not accept liability for, any reliance placed upon the unaudited daily and periodic valuations or unaudited stock transactions available via "Client zone", including any unaudited or audited data which is able to be downloaded and manipulated by you. Newton does not take responsibility for the data or how this data may be displayed on your computer. For complete audited valuations and stock transactions please refer to the periodic valuation statements, where available, via "Client zone" and which may also be sent to you by Newton in accordance with your investment management agreement, if relevant.

You shall assume responsibility for ensuring that your username and password are kept secure and secret at all times and not disclose these to anybody else. Your username and password should be reserved for your use only. Newton does not accept liability for any unauthorised access to your account via "Client zone", or for any use or misuse of any information by any person authorised to have access to your account via "Client zone". You, or any person authorised by you, to have access to your account shall notify Newton in the event that you or they no longer require access to "Client zone". If you or they know, or suspect, that someone else has obtained the username or password to your account or accessed your account without authorisation, please contact Newton immediately.

Newton may stop or suspend access via "Client zone" if it reasonably considers it necessary, including without limitation because it suspects that there may be unauthorised access.

9. Downloading and Copying

You may download materials and information from the Website to a single personal computer and/or print a hard copy of any materials and information from the Website in order to help you decide whether to invest in a Newton fund or to take advice from a professional financial adviser regarding any Newton fund provided that you do not delete, change or modify in any way any copyright notices or disclaimers attaching to such materials and information. Except for this limited licence you may not copy, reproduce, re-publish, upload, post, transmit or distribute any material on this Website in any way. Doing so could constitute an infringement of Newton's and/or a third party's copyright and other intellectual property rights and/or may constitute an infringement of laws, rules or regulations applicable to the marketing or sale of securities.

10. Ownership and Copyright

The copyright and other intellectual property rights contained in the Website and (unless otherwise indicated) its contents including all information, graphics, code, text and design are owned by Newton. All material on this Website is Newton Investment Management Limited. All rights reserved. Unauthorised use of this material is strictly forbidden.

In the event of a professional financial adviser wishing to publish or distribute written marketing or other promotional material based upon the content of this Website he/she may only do so having first obtained the prior written consent of Newton.

11. Trademarks

This Website contains names and logos which are trademarks of Newton. Any unauthorised use of any of these names and logos would constitute an infringement of those trademarks and is thus forbidden.

12. Severability

In the event that any part of these Terms is held by a court of competent jurisdiction to be invalid or unenforceable then the remainder of the Terms shall remain valid and enforceable. If any part of these Terms is found by a court of competent jurisdiction to be invalid, then you nevertheless agree that the court shall endeavour to give effect to Newton's intentions as reflected in the Terms.

13. Regulatory Information

Newton Investment Management Limited is authorised and regulated by the Financial Conduct Authority. Registered in England No. 1371973. BNY Mellon Fund Managers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England No. 1998251. The registered address of Newton Investment Management Limited and BNY Mellon Fund Managers Limited is BNY Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA. Both firms are members of the IMA. Newton Capital Management Limited is authorised and regulated in the United Kingdom by the Financial Conduct Authority. Registered in England no. 2675952. Newton Capital Management is registered in the United States as an investment adviser under the Investment Advisers Act of 1940.

Only Newton Capital Management Limited and Newton Capital Management LLC offer services in the United States.

All companies cited above are wholly owned subsidiaries of The Bank of New York Mellon Corporation.

Where AUM has been specified on this website, it relates to the Newton Group of companies, including Newton Investment Management Limited, Newton Capital Management Limited, and Newton Capital Management LLC. In addition, AUM for the Firm may include assets managed by the firm's officers as dual officers or employees of The Bank of New York Mellon and assets of wrap fee account(s) and high net worth client model(s) for which Newton Capital Management Limited provides advice in the form of non-discretionary model portfolios

Basel II Pillar 3 Disclosure
Newton Investment Management Limited and Newton Capital Management Limited are subsidiaries of Mellon International Holdings S.Ã r.l (Lux) ("MIH") and therefore form an integral part of the MIH Basel II Pillar 3 disclosure to meet local regulatory requirements. A copy of this disclosure can be found on the BNY Mellon web site using the following link: Basel II Pillar 3 disclosure.

14. Risk Warnings

Past performance is not a guide to the future. The value of investments and the income from them can go down as well as up. You may not get back the amount originally invested.
The value of overseas securities will be influenced by the rate of exchange used to convert them back into the base currency of the fund.

The Newton High Yield Bond and European High Yield Bond funds will and the Intrepid Fund may invest in sub-investment grade bonds which typically have lower credit ratings than other bonds and as such carry a higher degree of default risk which may affect the capital value of your investment and your capital may be eroded.

Certain funds may invest in emerging markets stocks which have additional settlement, dealing and custody risks.

Equity based investments including unit trusts and investment companies with variable capital (ICVCs) should not be considered as short-term investments and should typically be held for at least five years.

The Balanced, Equity & Bond, European High Yield Bond, Higher Income and High Yield Bond funds charge their annual management charge to the capital account of the fund and investors should be aware that there is a potential for future capital erosion.

Yields will vary and are not guaranteed. Investors should seek out the current yield published in The Financial Times.

Research and analysis contained in this Website has been produced by Newton Investment Management Limited and is for information purposes only and should not be construed as information or a recommendation to buy and sell a particular security. Anyone considering making such an investment should consult their professional financial adviser. Other content of this site may have been provided by external sources which is believed to be accurate and complete but cannot be guaranteed as such. Any opinions are expressed in good faith but are subject to change without prior notice.

An investor seeking to invest in any product appearing on this Website should only do so after reading the relevant documentation which can include but is not limited to the latest annual Report and Accounts, the Prospectus, the Key Investor Information Document (KIID) and any Supplements or Addenda or other prevailing terms and conditions. Anyone considering making an investment should consult their professional financial adviser and should consider his/her own personal circumstances before making a decision.

15. Linking

We do not endorse and accept no responsibility for the content of any website not operated by Newton which you may visit by following a link from this Website.
No other website, without the prior written permission of Newton is authorised to link to any part of this Website other than the home page nor when so linking to place, integrate or display any bar, frame or partial frame or any additional branding or graphic around the view of this Website presented to the internet user.

16. Complaints Procedures

17. Fraudulent E-mails and Web Sites

Please be advised that Newton will never contact you by e-mail to confirm credit card or financial transactions or to confirm or request personal account information or any other type of sensitive information (this type of fraudulent activity is often referred to as phishing).

If you do receive an e-mail that asks you to confirm credit card or financial transactions, provide or confirm sensitive information (such as passwords or sign-on IDs), or personal information (such as social security numbers, credit card numbers or personal bank account numbers), please assume that the request is fraudulent.

Some e-mails, links or websites may even include the Newton logo or resemble existing Newton Internet sign-on pages. Despite the graphics, you should continue to assume that the request is fraudulent because Newton will never contact you by e-mail to request or confirm personal or sensitive account information.

If you receive e-mail requests to visit a Newton branded website or to submit personal information, consider them fraudulent and notify Newton by sending an email to specifying 'Possible Fraudulent Activity' in the subject. We strongly recommend that you do not submit your personal information via the site or e-mail, or respond in any way.

NEWTON WEBSITE PRIVACY POLICY

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Privacy Policy

At the Newton Group, we take the issue of privacy very seriously. We would like to assure visitors to our Website of the security, privacy and confidentiality that they would expect from a leading financial services institution.

Information Collected

General
We do not collect any personal information from anyone who is merely visiting or browsing our Website. However, personal information may be requested from visitors who choose to respond to online surveys or to send Newton an email message.

Email and Product Inquiry
Visitors to our Website are invited to send email messages to Newton in order that we may respond to enquiries regarding Newton or our products or services. These contact details are available from the 'Contact us' page on this website.

Use of Cookies
A cookie is a small piece of information about an Internet session that may be created when a visitor accesses a Website. Our Website uses cookies to facilitate easier navigation within the site and provide a higher level of convenience for the visitor. Your internet browser is likely to accept cookies by default, however you can set your browser to reject cookies and delete them from your system at any time. The cookies used by Newton do not retrieve any information from the visitor's personal computer. For more information, please read our Cookie policy.

Use of Information Collected

Improved Customer Service
Newton uses the information collected from visitors to its Website to address the specific needs of those visitors and to provide better customer service, including the supply of the latest information regarding Newton products.

Record of Communications
The information collected is also used to maintain a record of communications between Newton and its Website visitors, and to comply with any applicable legal or regulatory requirements.

Data Protection
The uses of your personal information are covered by the registrations of the Newton Group under the Data Protection Act 1998. The personal information you supply may be used to provide the service applied for, confirm/update customer records and establish your identity. The information will be held on a database and may be shared with and used by any company within The Bank of New York Mellon Corporation in the UK and internationally who are obliged by law or agreement to comply with the principles set out in the European Directive 95/46/EC. Newton may also be required to transfer personal information to HM Revenue & Customs from time to time in order to process tax returns. Under the Act you have the right to obtain a copy of the information held about you by contacting Newton Investment Management Limited, in writing at any time, for which you may be charged a fee. You hereby agree that we may use, disclose and transfer this personal data as described herein. If you do not wish for your details to be used in the above manner and/or if you do not wish to receive marketing approaches relating to products and services offered by The Bank of New York Mellon Corporation which we believe may be of interest to you, then please write to Newton Investment Management Limited at BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA.

Access to Information Collected

Employees
Selected Newton employees have access to the information collected in order to respond to each visitor's needs and provide that visitor with information regarding specific products in which they may have an interest. Newton employees are instructed to use strict standards of care when handling the personal/confidential information of Newton customers, and the handling of such information is dealt with in The Bank of New York Mellon's Code of Conduct, which applies to its subsidiaries. Newton employees who do not conform to The Bank of New York Mellon's confidentiality rules are subject to disciplinary sanctions.

Third Parties
Newton does not transmit any personal information collected through its Website to any third-party marketers. However, Newton does offer the opportunity to its Website visitors to link to the Web pages of third parties who provide products and services not supplied by Newton. Once the visitor leaves the Newton site, Newton does not receive any further information from the visitor.

Visitors
Visitors having specific questions regarding any information they have sent to Newton through the Newton Website should send an email to

Information for Residents of the United States

Protection of Social Security Numbers
In this section, "We" refers to the family of companies owned by the Bank of New York Mellon Corporation.

Like all financial services companies, we collect a variety of information about individuals, including but not limited to our customers and employees. In many cases that information includes individuals' Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws such as tax laws and anti-money-laundering laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers Social Security numbers to our employees, and in certain cases to non-affiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorised purposes.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies or with non-affiliated parties for administrative purposes, such as to process transactions, verify identities and service accounts. We disclose Social Security numbers as required or permitted by law, such as to the Internal Revenue Service or to credit bureaus. When necessary, we disclose Social Security numbers to regulatory agencies, law enforcement agencies, courts and parties to lawsuits.

We may share Social Security numbers among our affiliated companies for marketing purposes, but only in compliance wit legal restrictions, including required opportunities to opt out of such sharing. We do not, without consent of the individual involved, share Social Security numbers with parties not affiliated with us to enable them to market their own products or services.

Children's Information
We respect the privacy of your children and do not knowingly collect or retain personally identifiable information from children under the age of 13 or through our Websites.