Legal Notice, Disclaimer and Privacy Policy

This document sets forth the Portfolio Analytics Privacy Policy (the "Privacy Policy") for this website, (the "Site"). If you have objections to the Privacy Policy, you should not access or use this Site. This Privacy Policy does not govern privacy practices associated with offline activities or any other websites.Portfolio Analytics (Pty) Ltd is a provider of discretionary investment management services to individuals, institutions and retirement funds. Portfolio Analytics utilises the web for both marketing and service delivery. Portfolio Analytics supports ethical use of personal information and subscribes to the privacy policy herein.

Changes in Privacy Policy
All "personal information" ("personal information" is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains) that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. Portfolio Analytics reserves the right to change the Privacy Policy from time to time at its sole discretion, and will provide notice of material changes on the home page of the Site. If as the result of such changes, you want to alter the ways in which Portfolio Analytics is allowed to use your personal information, you can do so by following the procedure described below in the section titled "Updating your personal information and privacy preferences." You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the Site after such notice has been posted for thirty (30) days. However, if Portfolio Analytics sells assets to another entity, or is acquired by, or merged with, another entity, Portfolio Analytics may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent.

Collection of personal information
As a visitor to this Site, you can engage in many activities without providing any personal information. In connection with other activities, Portfolio Analytics may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, Portfolio Analytics may ask that you provide us personal information, such as your first and last name, mailing address (including postal code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other personal information. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

How your personal information is used
Portfolio Analytics collects your information in order to record and support your participation in the activities you select. If, for example, you subscribe to a service, the information is used to register your subscription preferences and rights, if any, to support or other benefits that may be made available to registered subscribers. Your personal information is also used to keep you informed about other products and services of Portfolio Analytics and selected third parties if you have so opted to receive such communications. Portfolio Analytics may collect information about the use of the Site, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. Portfolio Analytics may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.

Your choices with respect to personal information
Portfolio Analytics recognises and appreciates the importance of responsible use of information collected on this Site. Except in the particular circumstances described in this Privacy Policy, Portfolio Analytics will not provide your name to other companies or organizations without your consent.There are other instances in which Portfolio Analytics may divulge your personal information. Portfolio Analytics  may provide your personal information if necessary, in Portfolio Analytics' good faith judgment, to comply with laws or regulations of a governmental or regulatory body or in response to a valid subpoena, warrant, or order or to protect the rights of Portfolio Analytics or others.

Privacy-related inquiries and complaints
Portfolio Analytics takes its users' privacy concerns seriously. If you believe that Portfolio Analytics has not complied with this Online Privacy Policy with respect to your personal information or you have other related inquiries or concerns, you may write to the Managing Director of Portfolio Analytics at the following address: PO Box 411939, Craighall, 2024In your letter, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Portfolio Analytics Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly. Please note that Portfolio Analytics is not responsible for the content or privacy practices of non-Portfolio Analytics websites to which this Site may link.  You should review the privacy policy of such sites before using the sites.

Terms and conditions

1. Ownership & Copyright
Copyright in all website content ("content") made available through this website is protected by intellectual property law. Unauthorised copying, reproduction, retransmission, distribution, dissemination, sale, publication, broadcast or other use, or exploitation of this material will constitute an infringement of such protection.The copyright in all material of Portfolio Analytics (Pty) Ltd published on this website shall continue to vest in Portfolio Analytics. Your access to this website, and the information contained on it, does not in any way convey or transfer any right in or to the intellectual property rights of Portfolio Analytics. If you so wish, Portfolio Analytics  hereby authorises you to view, copy, download to a local drive, print and distribute the content of this website, or any part thereof, if:
• The content is used for personal information purposes only;
• The content is used for non-commercial purposes. You are expressly prohibited from incorporating any material of Portfolio Analytics' proprietary material from this website in any other work, publication or website;
• Any reproduction of Portfolio Analytics' content from this website or portion thereof must include this notice in its entirety; and• The trademarks, logos and service marks may not be used without the written permission of the owner thereof.

2. Content
This website is only intended to provide general information regarding Portfolio Analytics and its products and services and it is not intended to provide exhaustive information of any subject dealt with.The information in this website including, without limitation, all research, opinions or other content is therefore not intended nor does it constitute financial, accounting, tax, legal, investment, consulting or other professional advice or services. Before making any decision or taking any action, which might affect your personal finances or business, you should consult your own professional advisors.This website could include technical, typographical or other inaccuracies and you are urged to contact Portfolio Analytics to confirm all information contained on these pages prior to placing reliance thereon. Portfolio Analytics expressly reserves the right, in its sole and absolute discretion, to alter or amend any criteria or information set out in this website without notice.

3. No Offer
No information or content contained on these pages should be construed as an offer by Portfolio Analytics. All services offered by Portfolio Analytics are subject to signature of the appropriate application forms and other documentation relating thereto and are governed by the standard terms and conditions of Portfolio Analytics in respect thereof and Portfolio Analytics shall not be bound in any manner until a formal written agreement has been entered into. Portfolio Analytics reserves the right to reject at its discretion any application submitted for services contained on this website.

4. Transmission of Information
Information transmitted via the Internet, including e-mail, is susceptible to monitoring and interception. You are discouraged from transmitting to Portfolio Analytics any information, which may be confidential, proprietary or sensitive. You shall bear all risk of transmitting such information in this manner and under no circumstances will Portfolio Analytics be liable for any loss, harm or damage suffered by you as a result thereof. Portfolio Analytics reserves the right to request independent verification of any information transmitted via e-mail.

5. Links to Third Party Sites
Portfolio Analytics may provide hypertext links to websites on the Internet which are operated by third parties. Visitors are advised to use caution and discretion when searching or accessing such links. Under no circumstances does Portfolio Analytics take responsibility for the content and/or services or products offered on third party websites that may be linked to this website and Portfolio Analytics gives no warranty, guarantee and makes no representation in respect of such linked websites.

6. Disclaimer
Portfolio Analytics strives to ensure that the content on this website is up to date and accurate. Whilst all care is taken by Portfolio Analytics in the preparation of the content of this website, the content is provided "as is" and no warranty, express or implied, is given or made by Portfolio Analytics. If Portfolio Analytics becomes aware that the information on the website is inaccurate or out of date it will use its reasonable endeavours to remove it or take other appropriate action. Portfolio Analytics reserves the right to alter or amend any information on this website without notice.The information, research, opinions and recommendations contained in this website are for general information purposes only, and must be interpreted solely as statements of opinion and not statements of fact. The information on this site is not intended to and does not constitute solicitation, recommendation or advice, and Portfolio Analytics does not purport to act in any way as a financial advisor. Portfolio Analytics accepts no liability for or in any respect of any direct, indirect or consequential liability, loss or damage of any kind or nature, howsoever arising, from the reliance on, or use of, information provided on this website.The website may contain links to other websites, for information purposes, which are not under the control of and are not maintained by Portfolio Analytics. Portfolio Analytics shall not be responsible for any loss or damage suffered by you as a result of using the links provided on the website.The copyright and all other rights in the information on this website is owned by or licensed to Portfolio Analytics. Access to and use of the website is subject to these terms and all applicable laws. You are invited to browse the website for your personal information, education and communication about Portfolio Analytics. You are prohibited from copying, reproducing, modifying, distributing, republishing, displaying, posting or transmitting any part of the website without the permission of Portfolio Analytics. You may view or print individual pages only for your own personal, non-commercial use provided you keep intact all copyright and other proprietary notices.

7. Risk & No Liability
Your use of this website and the information contained therein is entirely at your own risk and you assume full responsibility in respect of any loss or damage resulting from the use thereof. Neither Portfolio Analytics, its affiliated companies, holding company, subsidiaries or subsidiaries of its holding company, or their officers, agents, consultants or employees shall be liable for any direct, consequential or indirect loss or damages suffered by a visitor or any other person relating to the use of this website or the information contained therein.The visitor hereby indemnifies Portfolio Analytics and its suppliers from and against any and all losses, liability, cost or damages suffered or incurred by a visitor or any other person arising out of or in connection with the use of the website or any other website which can be accessed from this website, however such loss or liability may occur, and whether such loss or liability is foreseeable, financial, personal, consequential, incidental or otherwise.

8. Jurisdiction
These terms and conditions shall be governed by and construed in accordance with the laws of the Republic of South Africa.

9. Unit Trust Disclaimer
Figures quoted are from Morningstar for a lump sum investment, using NAV-NAV figures net of fees with income distributions, prior to deduction of applicable taxes, reinvested. Annualised performance quoted is the average return per year over the period. Collective Investment Schemes in Securities (CIS) prices are calculated on a Net Asset Value (NAV) basis, which is the total value of all assets in the Fund, including any income accrual and less all permissible deductions in terms of the Act, divided by the number of participatory interests in issue. Different classes of participatory interests apply to certain portfolios and are subject to different fees and charges. Performance is shown for the most expensive class of the portfolio and individual investor performance may differ as a result of initial fees, actual investment date, date of any subsequent reinvestment and any dividend withholding tax. A schedule of fees, charges and maximum commissions is available on request from the manager. The annual management fee is levied monthly on the daily value of the Fund, and no performance fees are charged. Commission and incentives may be paid and if so, would be included in the overall costs.

CIS are traded at ruling prices and can engage in scrip lending and borrowing. Transaction cut-off time is at 14h00 daily, and the Fund is valued daily at 17h00 using forward pricing. Fund prices are published each business day at and in select media publications.CIS are generally medium- to long-term investments. The value of participatory interests may go down as well as up and past performance is not necessarily a guide to the future. The manager does not provide any guarantee with respect to the capital or the return of the portfolios. Fluctuations or movements in exchange rates may cause the value of underlying international investments to go up or down. International Investments may include additional risks such as potential constraints on liquidity and repatriation of funds, macroeconomic risk, political risk, foreign exchange risk, tax risk, settlement risk as well as potential limitations on the availability of market information. Portfolio Analytics aggregates all foreign investments within the Portfolio Analytics offshore portfolio. The portfolios may therefore be invested in the Portfolio Analytics offshore portfolio from time to time. Analytics International and SIP may earn an annual investment management fee of up to 1% on all such investments. A fund of funds is a portfolio that invests in portfolios of collective investment schemes, which levy their own charges, which could result in a higher fee structure for the fund of funds. The Portfolio Analytics portfolios are portfolios established and administered by Ci, and Portfolio Analytics has been appointed to manage and market the portfolios. Portfolio Analytics is an indirect shareholder of Ci. As a shareholder, Portfolio Analytics may earn dividends from time to time and participation in any dividends may be linked to the revenue generated by Ci from the Portfolio Analytics portfolios, and from any other Ci portfolios. Ci retains full legal responsibility for this co-named portfolio. Additional information on the portfolio may be obtained, free of charge, directly from Ci.The portfolios may be closed to new investments at any time in order to be managed in accordance with its mandate.Ci Collective Investments (RF) (Pty) Limited’s trustee is FirstRand Bank Limited.Ci Collective Investments (RF) (Pty) Limited is an associate member of the Association for Savings & Investment SA (ASISA) and is registered under the CIS Control Act.Risk management and compliance

Regulation and Compliance
Portfolio Analytics is a licensed discretionary financial services provider and our business is regulated by the Financial Sector Conduct Authority (FSCA).Portfolio Analytics is committed to the Treating Customers Fairly (“TCF”). For further information on the TCF outcomes, please contact us directly.

Governing Law
• Financial Advisory and Intermediary Services Act, No 37 of 2002 ("FAIS")Portfolio Analytics is an authorised financial services provider in terms of the Financial Advisory and Intermediary Services Act No. 37 of 2002 (FAIS). FSP number 631. (Category II)
• Collective Investments Scheme Control Act, no 45 of 2002 ("CISCA")Ci Collective Investments (RF) (Pty) Limited offers a range of institutional unit trust portfolios to meet the investment needs of its investors.
• Financial Intelligence Centre Act, no 38 of 2001 ("FICA")As an accountable institution, we are required to comply with FICA and other anti-money laundering legislation such Protection of Constitutional Democracy Against Terrorist and Related Activities Act, No 33 of 2004 ("POCDATARA"). FICA requires us to establish and verify the identities of our client according to the Customer Due Diligence and Enhanced Due Diligence requirements of the Act, prior to transacting. In addition, FICA requires any suspicious transactions to be reported to the Financial Intelligence Centre.
• Securities Services Act, No 36 of 2004 ("SSA")The Securities Services Act replaced the Stock Exchanges Control Act, 1985, the Financial Markets Control Act, 1989, the Custody and Administration of Securities Act, 1992 and the Insider Trading Act, 1998. Apart from consolidating the above Acts, it also strives to maintain a healthy balance between investor protection and the enhancement of international competitiveness of securities services in South Africa.
• Promotion of Access to Information Act, no 2 of 2000As per Section 51 of The Promotion of Access to Information Act No. 2 of 2000, please contact us directly regarding the procedures to be followed in requesting further information from us (for the purpose of exercising or protecting rights).

Corporate Governance
In terms of good corporate governance and in addition to complying with our primary legislation, Portfolio Analytics adheres to the following internal policies:
• Code of Conduct
Complaints handling and resolutionConflicts of Interest Management Policy
• Gifting - both receiving and giving Our internal compliance team is responsible for monitoring the following:
• Regulation compliance
• Mandate compliance
• Pre-trade and post-trade compliance
• Policy compliance• Business Continuity
• Risk Management Portfolio Analytics has outsourced its compliance to Moonstone (Pty) Ltd.  Moonstone ensures overall compliance in terms of our primary legislation and keeps Portfolio Analytics abreast of legislative changes.

Institutional Administration
Our institutional administration is outsourced to Curo Fund Services.

Retail Administration
Our retail administration is outsourced to Silica Financial Administration Solutions (Pty) Limited.