Sustainable Investing Position 

By incorporating ESG considerations to our investment decisions, we protect capital, apply our responsible investment principles to purposeful investments, and achieve our fiduciary, societal, and environmental responsibilities.

Through our capital flow, we aim to reinforce companies that are contributing and transitioning to a low-carbon and circular economy in socially-just and nature-positive ways. We seek rewards from those who are well-positioned to succeed financially from their commitments to the global climate, biodiversity, and sustainable development goals that ultimately drive necessary change for a more sustainable economy.

 

Sustainable Investing Philosophy

Our position compels us to assess double materiality impacts and adopt an inclusionary approach to sustainable investing for our ESG Funds.
We focus on what matters – a Strong Return on Investment, a Sustainable Environment and Economy.

 

 

ESG Integrated Investment Process

 

  • We REVIEW inadequate efforts to take necessary action on risks material to the company’s performance and long-term survival.
  • We REINFORCE transitions and contributions to a low-carbon and circular economy that seek just benefits for communities and greater gains for biodiversity.
  • We REWARD commitments to global climate, biodiversity and sustainable development goals that lead to a sustainable economy.

 

 

Stewardship

Stewardship is used as an overarching term encompassing the approach that investors take as active and involved owners of the entities in which they invest through voting and engagement. It involves preserving and enhancing the value of assets with which we have been entrusted. It is the use of influence we have as investors to maximize overall long-term value including the value of common economic, social and environmental assets; on which returns and interests of our clients and beneficiaries depend.

We deliver this through our investment approach and decisions at the firm and fund levels. Stewardship is a consequence of investment to us, where longer-term value creation is the main driver for engagement, not so much short-term activism. As such, we employ various stewardship tools that include ESG monitoring and ESG engagement.

 

Important Information:

Please refer to the respective product prospectus for specific details before making any investment decision.
This advertisement or publication has not been reviewed by the Monetary Authority of Singapore.

Environmental Risk Management

We incorporate environmental risks into our broader risk management framework and investment decision making. We consider environmental risks across key risk areas such as physical risk, transition risk, and reputational risk, and assess their potential impact at both issuer and portfolio levels.

Our approach includes, where relevant and practicable:

  • Identification, assessment and monitoring of environmental risk exposures.
  • Use of risk indicators and metrics (such as carbon emissions and intensity).
  • Portfolio-level monitoring and escalation of material risks to the Investment Committee and/or Board of Directors.

 

Climate Scenario Analysis

We conduct quarterly climate scenario analysis as part of climate stress testing to assess portfolio resilience under different climate pathways. Scenario analysis is used to:

  • Identify portfolio exposures to climate-related physical and transition risks.
  • Support portfolio monitoring discussions and prioritisation of risk actions.
  • Key observations are highlighted to the Investment Committee.

 

Sustainable Investment Governance Structure

Our sustainable investment governance structure provides oversight and accountability for how environmental and climate-related risks are managed across our investment activities. The Board of Directors provides strategic direction and oversight, while management and control functions support implementation through defined roles and escalation pathways.

 

Oversight & Policy

Board of Directors and Senior Management

Sets direction and provides oversight of the environmental and climate-related risk management framework, ensuring appropriate resources, and reporting and disclosures are in place. Our approach is guided by relevant international frameworks such as Task Force on Climate-related Financial Disclosures (TCFD) and Principles for Responsible Investment (PRI).

 

Investment Committee

  • Provides oversight of both the Investment and ESG Teams. Review risks relevant to investment selection decision making, which includes material ESG risks, highlighted by members from Investment, ESG, Risk Management and Compliance Teams.
  • Monitors that appropriate actions are taken in a timely manner.
  • Significant matters are highlighted to senior management and to the Board of Directors.

 

Implementation & Management (First Line of Defence)

Investment Team

Integrates ESG framework, including environmental risk management, into research, security selection and portfolio construction. Team members maintain ongoing monitoring of portfolio environmental risks.

 

ESG Team

Leads the development and ongoing enhancement of the ESG framework, which includes environmental risk management. This covers tools, assessment metrics and reporting. Conducts proprietary ESG research (internally referred to as ESG Rapid Reports), under specific conditions, to assess and provide an overall ESG rating on investee companies.

 

Independent Monitoring (Second Line of Defence)

Risk Management & Compliance Team

Provides independent oversight to ensure ESG-related risks are identified, assessed and managed across portfolios. Conducts ongoing compliance monitoring, which includes ensuring that the firm complies with paragraph 8 of Circular No. CFC 02/2022 Disclosure and Reporting Guidelines for Retail ESG Funds (as issued by the Monetary Authority of Singapore), which requires that at least two-thirds of the net asset value of the Sustainable Reserve Fund is invested in companies which the firm deems to have satisfactory overall ESG rating.
Material findings are escalated to Investment Committee for review and action.

 

Assurance (Third Line of Defence)

Internal Audit

Provides independent assurance over governance arrangements, processes and controls.

 

Important Information:

Please refer to the respective product prospectus for specific details before making any investment decision.
This advertisement or publication has not been reviewed by the Monetary Authority of Singapore.

ESG Research Process

We believe industry-specific transition is necessary in order to meet the global goals for climate, nature and sustainable development. Targets and goals that can be adequately measured and managed allow us to monitor performance and change over time. We take reference from scientific bodies, such as IPCC and IPBES, and the Global Goals set within the Paris Agreement, the Global Biodiversity Framework and the SDGs.

 

ESG Assessment Process – Sustainalytics Indicators

To support our ESG integration framework approach, we engage Sustainalytics as an ESG data provider, whose methodology aligns with our ESG Research Framework.

We customise the use of Sustainalytics data by using up to 26 indicators from Sustainalytics to assess each investee company in our portfolio of investments. The 26 indicators are purposefully chosen to align to our three (3) research objectives: 

  • Objective 1 – Managing ESG risk.
  • Objective 2 – Mitigating negative externalities.
  • Objective 3 – Measuring positive change and impact.

This customised assessment is performed on a monthly basis for Sustainable Reserve Fund and on a quarterly basis for all other funds that we manage. This assessment is also conducted on a new underlying investment in the Sustainable Reserve Fund.

For a satisfactory overall ESG rating, we internally assign either “low risk” or “medium risk” rating to an issuer. For clarity, we deem that an issuer has an unsatisfactory overall ESG rating when it is rated as “high risk”.

Below are the 26 indicators along with the descriptions:

No. Indicator Name Description of Indicator
1 Environmental Policy This indicator assesses a company’s commitment to manage its operations with a view to prevent, reduce or mitigate any harmful effects on the environment and natural resources.
2 GHG Reduction Programme This indicator assesses the strength of a company’s programme and associated initiatives to manage and reduce GHG emissions associated with its operational boundary.
3 Board Independence This indicator assesses the percentage of independent directors on the board, as defined by Sustainalytics’ in-house criteria for judging director independence.
4 Board Gender Diversity This indicator assesses directors gender representation within the board to verify whether there is gender balance. The assessment evaluates gender identities across male, female and non-binary.
5 Board Gender Representation Target This indicator assesses the strength of a company’s target to ensure board gender equality.
6 Global Compact Signatory This indicator identifies whether a company is a member of the internationally recognized United Nations Global Compact (UN Global Compact). This demonstrates a company’s commitment to aligning its strategies and operations with universal principles on human rights, labour, the environment and anti-corruption, and to taking actions that advance societal goals.
7 ESG Governance This indicator provides an assessment of whether a company has assigned board or executive level responsibility for oversight of ESG issues. The indicator tracks whether there are specific management committees in charge of managing ESG issues across the group.
8 Risk Oversight This indicator assesses a company risk management system, with an emphasis on the board role in the supervision of the risk management framework.
9 GHG Performance Incentive Plan This indicator assesses a company’s remuneration process with a focus on programmes that link greenhouse gas (GHG) emissions reductions or wider climate-related targets to remuneration.
10 ESG Reporting Standards This indicator assesses a company’s environmental, social and governance (ESG) disclosures and the extent to which the reporting adheres to best practice guidelines or globally recognized sustainability reporting standards.
11 Verification of ESG Reporting This indicator assesses a company’s disclosure of whether its ESG reporting has been externally verified in accordance with a recognized assurance standard. Both the scope of verification and the level of assurance for the report are assessed.
12 Scope of GHG Reporting This indicator assesses the greenhouse gas (GHG) emissions associated with a company’s business activities, including both direct (scope 1) and indirect (scope 2 and 3) emissions.
13 GHG Reduction Programme This indicator assesses the strength of a company’s programme and associated initiatives to manage and reduce GHG emissions associated with its operational boundary.
14 GHG Emissions Targets This indicator assesses the strength of a company’s greenhouse gas (GHG) emissions reduction targets.
15 GHG Emissions Target Progress This indicator assesses whether a company is on track to meet its stated greenhouse gas (GHG) reduction targets.
16 Discrimination Policy This indicator assesses a company’s commitment to prohibit workplace discrimination and ensure equal opportunity, and it is aligned with the International Labour Organization’s (ILO) related conventions.
17 Diversity Programmes This indicator assesses a company’s initiatives to strengthen workplace diversity and develop a more inclusive workforce, including having managerial or board level oversight, targets, training and guidance.
18 Human Capital Development This indicator assesses a company’s initiatives to recruit, retain and develop human capital to manage risks associated with skilled labour shortages or labour relations issues, including, talent development and retention initiatives and detailed reporting on risks relating to human capital management.
19 Freedom of Association Policy This indicator assesses a company’s commitment to ensure that its employees have the right to associate and collectively bargain. Collective bargaining, a negotiation process between employers and employees aimed that aims to form agreements to regulate working salaries, conditions and benefits, should be permitted.
20 Business Ethics Programme This indicator assesses a company’s initiatives to ensure that business ethics are promoted and adhered to. The indicator focuses especially on the process and implementation of its internal code of conduct, particularly on ethical issues.
21 Whistleblower Programmes This indicator assesses the quality and scope of a company’s mechanisms for reporting illegal or unethical actions, including disclosure of the number of reports received, actions taken and investigation mechanisms.
22 Bribery & Corruption Policy This indicator assesses a company’s commitment to reduce or eliminate instances of bribery and corruption across its business activities (including its own operations and its supply chain). A bribe includes any illegal payment from one party to another while corruption includes the abuse of entrusted power for private gain.
23 Bribery & Corruption Programmes This indicator assesses a company’s programmes to eliminate or reduce instances of bribery and corruption across its business activities (including its own operations and its supply chain).
24 ESG Governance This indicator provides an assessment of whether a company has assigned board or executive level responsibility for oversight of ESG issues. The indicator tracks whether there are specific management committees in charge of managing ESG issues across the group.
25 Scope of Social Supplier Standards This indicator assesses a company’s commitment to prevent violations of human rights across its suppliers’ operations. Such violations or social issues include: workers’ health and safety, minimum living wages and maximum working hours, freedom of association and the right to collective bargaining, child and forced labour, acceptable living conditions, non-discrimination, and disciplinary practices.
26 Supplier Environmental Policy This indicator assesses a company’s commitment to purchase goods and services that have a reduced environmental impact throughout their life cycle, compared to alternatives (that serve the same purpose) that would normally be purchased.

 

ESG Assessment Process – Proprietary ESG Research

Under specific conditions, we will conduct ESG risk assessment on an investee company using our proprietary ESG research. The research reports produced by our proprietary ESG research are internally referred to “ESG Rapid Reports”. This research is based on three (3) research objectives mentioned above.

Each research objective includes Environmental, Social, and Governance metrics financially material to the industry and where relevant, specific to the assessed investee company. Each research objective assesses risks and opportunities across domains that address, amongst others, social injustice, health, climate change, biodiversity loss, and pollution.

We use our proprietary ESG research to assess an investee company if any of the following conditions is met:

  1. The investee company is a new underlying investment in the Sustainable Reserve Fund that has scored an unsatisfactory overall ESG rating based on the assessment result from the evaluation of Sustainalytics indicators described above.
  2. The investee company is one of the top ten (10) largest holdings in the Sustainable Reserve Fund, irrespective of its overall ESG rating based on assessment result from the evaluation of Sustainalytics indicators described above.
  3. The investee company is one of the issuers named in the high carbon intensity or high nature impact watch list. This watch list is guided by Climate Action 100+ and Nature Action 100. Climate Action 100+ is a global, investor-led initiative that engages 169 companies globally to drive stronger climate governance, reduce greenhouse gas emissions, and improve climate-related disclosures and transition plans. Nature Action 100 is a global, investor-led initiative that engages 100 large companies across eight key sectors that are systemically important for nature and ecosystem services.

The issuance of the ESG Rapid Reports is prioritised based on the above order of 1 to 3.

The primary sources of ESG information used for the ESG Rapid Reports are:

  • Sustainability reports and annual financial reports issued by the company.
  • Information, such as company policies, made publicly available by the company.
  • Controversial news on the company, published by credible and reputable news organisations.

Based on information we extract from the above sources, we use a scoring system of at least 35 metrics and these metrics are relevant to each of the three research objectives. The metrics assess, amongst other things, the level of action taken by the issuer, the issuer’s contribution/transition to the green economy, and the issuer’s commitment to its own targets and to global goals. Some of the metrics are associated with the Sustainability Accounting Standards Board (SASB), Task Force on Climate-Related Financial Disclosures (TCFD) and UN-supported Principles for Responsible Investment (PRI).

Each metric is scored on a scale of 1 to 10. For objectives 1 and 2, scoring focuses on the quality of disclosures and strength of commitments. For objective 3, scoring focuses on measurable, time-bound targets with a clear implementation trajectory.

The overall ESG rating of the investee company, whether satisfactory or unsatisfactory, is determined by the weighted average score of the assessed metrics. This overall ESG rating derived from our proprietary ESG research will supersede the overall ESG rating, if any, derived from the assessment of the Sustainalytics indicators.

In the Sustainalytics ESG assessment, the 26 indicators reflect what is measured in the rapid report metrics. The ESG Rapid Reports’ 35 metrics are categorised into 9 groupings and these groupings can be matched to the Sustainalytics indicators chosen. The aforesaid reinforces the shared objective of assessing double materiality.

For the purpose of paragraph 8 of Circular No. CFC 02/2022 Disclosure and Reporting Guidelines for Retail ESG Funds (“ESG Circular”) issued by the Monetary Authority of Singapore, at least two-thirds of the net asset value of the Sustainable Reserve Fund must be invested in companies we deem to have satisfactory overall ESG rating.

Important Information:

Please refer to the respective product prospectus for specific details before making any investment decision.
This advertisement or publication has not been reviewed by the Monetary Authority of Singapore.

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FATCA NOTICE

With effect from 1st July 2014, this FATCA Notice (the “Notice”) forms part of the terms and conditions of our products and services (the “Terms and Conditions”) governing your relationship (“you”, “your”, “yours” referred to herein include joint-account holders and beneficiary holders of an entity who are a natural person) with Phillip Capital Management (S) Ltd and its related corporations (collectively referred to herein as “PCM”, “us”, “we” or “our”) and should be read in conjunction with those Terms and Conditions, including those under our Personal Data Protection Notice.The existing terms and conditions of any contractual agreement entered into between PCM a nd you (the “Existing Terms and Conditions”) remain in full force and effect. In the event of any conflict or inconsistency between the provisions of this Notice and those of the Existing Terms and Conditions, the provisions of this Notice shall prevail.

We may from time to time update the Terms and Conditions listed here to ensure their consistency with our future developments,industry trends and/or any changes in legal or regulatory requirements. Such updates will be published at http://www.phillipfunds.com/ .

On March 18, 2010, the United States of America’s (“U.S.”) Hiring Incentives to Restore Employment Act of 2010 (Pub.L.111-147H.R.2847)) (the “Act”) was enacted into law. Section 501(a) of the Act added a new chapter 4 (sections 1471-1474) to Subtitle A of the U.S.’s Internal Revenue Code (Code).Chapter 4 expands the information reporting requirements imposed on foreign financial institutions (as defined in section 1471(d)(4)) (FFIs) with respect to certain U.S. accounts (as defined in section 1471(d)(1)) of specified U.S. person, and imposes withholding, documentation, and reporting requirements with respect to certain payments made to certain foreign entities.

PCM will be obliged to comply with the provisions of FATCA under the terms of the inter-governmental agreement (“IGA”) Model I between the U.S. and Singapore and under the terms of Singapore’s subsidiary legislation which will be issued pursuant to Singapore’s Income Tax Act (Cap. 134) to implement the IGA. “FATCA” or “Foreign Account Tax Compliance Act” means Chapter 4 (sections 1471 to 1474) to Subtitle A of the U.S. Internal Revenue Code.

“FATCA” or “Foreign Account Tax Compliance Act” means Chapter 4 (sections 1471 to 1474) to Subtitle A of the U.S.Internal Revenue Code.

“U.S. person” means a U.S. citizen or resident individual, a partnership or corporation organised in the U.S. or under the laws of the U.S. or any state of the U.S. thereof, a trust if: (i) a court within the U.S.would have authority under the applicable law to render orders or judgments concerning substantially all issues regarding the administration of the trust; and (ii) one or more U.S. persons have the authority to control all substantial decisions of the trust, or an estate of a decedent that is a citizen or resident of the U.S..This definition shall be interpreted in accordance with the provisions of the U.S. Internal Revenue Code.

  • You shall provide all required documentation or information, including but not limited to your date of birth, countries of citizenship, countries of permanent residence, countries of tax residency and associated taxpayer identification numbers, which may be required to enable PCM to ascertain your U.S. tax status and share information and /or documents relating to you and/or your account(s) with domestic and international authorities for the purpose of complying with all the requirements of FATCA, the IGA between Singapore and U.S or other countries,any applicable Singapore or international laws or regulations.
  • You represent and warrant that you have provided to PCM all documentation or information in relation to change in your tax status or as required by PCM for compliance with all the requirements of FATCA, the IGA between Singapore and U.S or other countries,any applicable Singapore or international laws or regulations. You shall provide all required documentation or information within seven (7) days of a request from PCM in writing or otherwise.
  • You shall notify PCM in writing immediately in the event of any change that affects your tax status for the purpose of complying with the requirements of FATCA, the IGA between Singapore and U.S or other countries,any applicable Singapore or international laws or regulations. Such change that affects your tax status may include any change of the country or territory of your domicile or residence or any change of your nationality or obtaining of any new nationality. In these instances, you shall provide all information and/or documents as required or requested by PCM.
  • You acknowledge and agree that when you fail to provide accurate and timely information pursuant to this Notice, for the purpose of complying with the FATCA, the IGA between Singapore and U.S or other countries, any applicable Singapore or international laws or regulations, PCM may deem you as a recalcitrant and/or a reportable person and report this information to the Singapore Inland Revenue Authority, in accordance with applicable laws and regulations, which will in turn report to the IRS.
  • It is the existing policy of PCM that investment products and investment accounts managed by PCM (“PCM Products and Services”) are not being offered or sold to U.S. Persons and that subsequent transfer of PCM Products and/or Services to a U.S.Persons are prohibited.
  • If investment accounts or products managed by PCM are beneficially owned by a U.S. Person or if PCM deemed you as a recalcitrant and/or a reportable person,PCM may compulsorily cancel your pending subscription order or capital injection,terminate the contractual relationship with you and withhold an amount for transferring to the relevant tax authorities as required under the FATCA, the IGA between Singapore and U.S or other countries, any applicable Singapore or international laws or regulations. PCM shall have no liability for losses,fees, costs, expense, damages, liabilities of any kind which you may have suffered in connection with such cancellation, termination, withholding amount and/or as a result of our complying with the requirements of FATCA, the IGA between Singapore and U.S or othercountries,any applicable Singapore or international laws or regulations,even if we make an incorrect assessment and decision.

PDPA

PERSONAL DATA PROTECTION NOTICE

With effect from 1st July 2014, this Personal Data Protection Notice (the “Notice”) forms part of the terms and conditions of our products and services (the “Terms and Conditions”) governing your relationship (“you”, “your”, “yours” referred to herein include joint-account holders and beneficiary holders of an entity who are a natural person) with Phillip Capital Management (S) Ltd and its related corporations (collectively referred to herein as “PCM”, “us”, “we” or “our”). Without prejudice to the existing terms and conditions of any contractual agreement entered into between PCM and you (the “Existing Terms and Conditions”), which remain in full force and effect, this Notice shall be read in conjunction with the Existing Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Notice and those of the Existing Terms and Conditions, the provisions of this Notice shall prevail.

We are required under the Personal Data Protection Act (“PDPA”) to put in place the necessary arrangements to protect personal data and comply with the PDPA. Personal data includes any data and information, whether true or not, about an individual (a natural person) who can be identified from that data or information, such as your name, NRIC, passport or other identification number, telephone numbers, address, email address and any other information relating to individuals which you or your authorized representative have provided to us or we are likely to have access to (“Personal Data”).

This Notice outlines the purposes for the collection, use and/or disclosure of your Personal Data by PCM, how we protect your Personal Data and your rights with respect to the collection, use and/or disclosure of your Personal Data. This Notice supplements but does not supersede nor replace any other consents which you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use and/or disclose your Personal Data. We may from time to time update the Terms and Conditions listed here to ensure their consistency with our future developments, industry trends and/or any changes in legal or regulatory requirements. Such updates will be published at http://www.phillipfunds.com/.

1. PCM may collect, use and/or disclose your personal data for any of the following purposes listed below (collectively “Permitted Purposes”):-

i) carrying out activities, duties and obligations in connection with our products and services which you have applied for, including evaluating your eligibility and credit profile, verifying the identity or authority of your representatives, administration of your account and/or managing our overall relationship with you (including but not limited to the outsourcing of any of our functions to service providers or vendors, due diligence checks, accounting and portfolio valuation, billing and collections, business continuity and print management);

(ii) developing new services and/or products;

(iii) providing you with marketing, advertising and promotional information, materials and/or documents related to financial products and/or services that we may be selling, marketing, offering or promoting, whether such financial products or services exist now or are created in the future;

(iv) marketing and promotional events, including but not limited to images, photographs or videos of you during the events;

(v) meeting or complying with PCM’s internal policies and procedures and any applicable rules, law, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (both national and international) (including but not limited to disclosures to regulatory authorities or financial industry self-regulatory bodies; conducting audit checks (internal/external), surveillance and investigation; handling of customer feedback or complaint; dispute resolutions; recording of telephone conversations and/or electronic communications with you; conducting checks or investigations for prevention and/or detection of financial crimes such as money-laundering, financing of terrorism, fraud and/or bribery etc.);

(vi) legal purposes, including but not limited to obtaining legal advice and enforcing or defending our legal and/or contractual rights against you;

(vii) risk management, statistical and trend analysis;

(viii) processing and/or storing data and/or information related to your relationship with PCM.

2. PCM, in order to facilitate the discharge of its duties and obligations to you, may be required to disclose your Personal Data for the Permitted Purposes and/or for processing of the Permitted Purposes on a need-to-know basis, to any of the following entities and the directors, officers, staff, employees and agents of any such entities, whether located within or outside Singapore (“Relevant Persons”):-

(i) any associate or related company of PCM and the directors, officers, staff, employees and agents of any such person;

(ii) any actual or proposed assignee or transferee of any of PCM’s rights and obligations or any actual or proposed delegate of any of PCM’s functions and duties under its contractual relationship with you;

(iii) any relevant governmental, supervisory or regulatory authority or court of law, including the Monetary Authority of Singapore, to which PCM is or may be subject;

(ix) any person in order to give effect to any instruction from you or any person acting or purporting to be acting on behalf of you;

(x) any person as PCM may consider necessary in order to comply with any order, directive or policy of any court or governmental or regulatory authority in any jurisdiction;

(xi) any person when required to do so in accordance with the laws of any applicable jurisdiction or rules of any professional self-regulatory bodies or securities exchanges;

(xii) any agent, contractor or third party service provider who provides their services in connection with the operation of PCM’s fund management business, including but not limited to the custodians, trustees, fund administrators, registrars, banks, legal firms, accounting and auditing firms, printing firms, IT service providers, credit reference agencies, credit bureaus, data screening entities for the purpose of due diligence checks and the prevention and detection of financial crimes.

3. PCM’s related companies and third party service providers shall be bound by the same provisions as set out in this Notice and we will require them to ensure that your Personal Data are kept confidential and secure.

4. You represent and warrant that your Personal Data provided to us is accurate and complete for us to make a decision that affects you or to disclose your Personal Data to the above-mentioned Relevant Persons on a need-to-know basis. Where applicable, when you provided Personal Data relating to another individual (e.g. your dependent, spouse, children and/or parents) to us, you represent and warrant that such Personal Data is accurate and complete and the consent of that individual has been obtained for the collection, use and disclosure of his/her Personal Data in accordance with the provisions listed in this Notice.

5. We will retain your Personal Data to the extent that one or more of the Purposes for which your Personal Data was collected, used and/or disclosed is/are still valid and for legal, regulatory reporting or regulatory investigations purposes for which retention may be necessary.

6. PCM may terminate any contractual relationship which you may have with us, if any information provided to us is insufficient, misleading or erroneous or if any information that is required to be disclosed to any regulatory authority for compliance with any law or regulation is not provided by you.

7. You may request access to or make corrections to your Personal Data records. Depending on the information requested PCM may charge a small fee when you request access to your Personal Data. Upon your request and subject to the provisions under the PDPA, PCM will respond accordingly within reasonably possible time. Please submit your request to our Data Protection Officer via [email protected].

8. You may withdraw your consent to any use or disclosure of your Personal Data for any or all of the Purposes as set out in this Notice by giving written notice to us. If you withdraw your consent(s), depending on the nature of your request, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship in place. Such withdrawal may be considered a termination by you of any agreement you may have with us. Where there is any breach of your contractual obligations or undertakings, PCM’s legal rights and remedies are expressly reserved in such event.

Important Information

By accessing and using this website (the “Website”) and any web page hereof, you agree to be bound by the terms and conditions below. Reference to these general terms of use should be made each time you access and use the Website.

This Website, its services and contents are provided for your use by PhillipCapital, which is a group of companies who together offer a full range of financial services to retail, corporate and institutional customers. Member companies in Singapore include Phillip Securities Pte Ltd, Phillip Securities Research Pte Ltd, Phillip Financial Pte Ltd, Phillip Nova Pte Ltd, Phillip Capital Management (S) Ltd (“PCM”),Phillip Private Equity Pte Ltd, Phillip Japan Fund Management Pte Ltd, CyberQuote Pte Ltd, IFS Capital Limited and ECICS Limited. Member companies can otherwise be identified by their authorised use of PhillipCapital brand name along with their own name in their documentation and literature.

 

Use of Information and Materials

The materials and contents of this website are provided to you for general information only and should not be used as a recommendation or basis for making any specific investment, business or commercial decision. These pages should not be construed as a recommendation, an offer or solicitation for the subscription, purchase or sale of the securities, and specifically funds or any investment products, mentioned herein, or, in any jurisdiction to any person to whom it is unlawful to make such an invitation or solicitation in such jurisdiction. Accordingly, no warranty whatsoever is given and no liability whatsoever is accepted for any loss arising whether directly or indirectly as a result of your acting based on this information.

Investments are subject to investment risks including the possible loss of the principal amount invested, and are not obligations of, deposits in, guaranteed or insured by PCM or any of its subsidiaries, associates, affiliates or Participating Dealers (“PDs”). Past performance is not necessarily indicative of the future or likely performance of the fund(s). There can be no assurance that investment objectives will be achieved. Any use of financial derivative instruments will be for hedging and/or for efficient portfolio management. The value of any investments and the income from them may fall as well as rise. There can be no assurance that investment objectives will be achieved.

Investments in the fund(s) managed by PCM are not obligations of, deposits in, or guaranteed by PCM or any of its affiliates.

The information contained in these pages is not intended to provide professional advice and should not be relied upon in that regard. It also does not have any regard to your specific investment objective, financial situation and any of your particular needs. You should read the relevant prospectus and the accompanying product highlights sheet (“PHS”) for disclosure of key features, key risks and other important information of the relevant fund(s) and obtain advice from a financial adviser (“FA”) before making a commitment to invest in the fund(s). In the event that you choose not to obtain advice from a qualified financial adviser, you should assess and consider whether the investment product is suitable for you before proceeding to invest and we do not offer any advice in this regard unless mandated to do so by way of a separate engagement. A copy of the prospectus and PHS are available from PCM or any of its authorized distributors.

You are advised to read the applicable Terms and Conditions governing each account and the relevant Risk Disclosure Statement, if any, carefully before investing in any investment products.

The contents of this website, including these terms and conditions, are subject to change and may be modified, deleted or replaced from time to time and at any time at the sole and absolute discretion of PhillipCapital. Any opinions or views herein are made on a general basis and are subject to change without notice.

The value of the units and the income accruing to the units may fall or rise. You should read the Prospectus and the accompanying Product Highlights Sheet (“PHS”) for disclosure of key features, key risks and other important information of the ETF and obtain advice from a financial adviser (“FA”) before making a commitment to invest in ETF. A copy of the Prospectus and PHS are available from PCM or any of its PDs.

The ETF is not like a typical unit trust as it is intended for the units of the ETF (the “Units”) to be listed and traded like any share on the Singapore Exchange Securities Trading Limited (“SGX-ST”). Listing on the SGX-ST does not guarantee a liquid market for the Units which may be traded at prices above or below its net asset value (“NAV”) or may be suspended or delisted. Investors may buy or sell the Units on SGX-ST when it is listed. Investors cannot create or redeem Units directly with PCM and have no rights to request PCM to redeem or purchase their Units. Creation and redemption of Units can be done through PDs if investors are clients of the PDs, who have no obligation to agree to create or redeem Units on behalf of any investor and may impose terms and conditions in connection with such creation or redemption orders. Please refer to the Prospectus for more details.

The regular dividend distributions, either out of income and/or capital, calculated on the assumption that all dividends/distributions are reinvested after all charges, are not guaranteed and subject to PCM’s discretion. Such dividend distributions will reduce the available capital for reinvestment and may result in an immediate decrease in the NAV of the ETF. Past payout yields (rates) and payments do not represent future payout yields (rates) and payments. Please refer to <www.phillipfunds.com> for more information in relation to the dividend distributions.

Any use of financial derivative instruments will be for hedging and/or for efficient portfolio management. PCM reserves the discretion to determine if currency exposure should be hedged actively, passively or not at all, in the best interest of the ETF.

The information does not constitute, and should not be used as a substitute for tax, legal or investment advice.

Member companies of PhillipCapital, including PCM, their directors, officers, associates, agents, affiliates and/or employees may own or have positions in the investments mentioned herein or related thereto.

This information herein are not for any person in any jurisdiction or country where such distribution or availability for use would contravene any applicable law or regulation or would subject PCM to any registration or licensing requirement in such jurisdiction or country. The ETF is not offered to U.S. Persons.

The information provided herein is based on certain information, conditions and/or assumptions available as at the date of this publication that may be obtained, provided or compiled from public and/or third party sources which PCM has no reason to believe are unreliable; and may contain optimistic statements/opinions/views regarding future events or future financial performance of countries, markets or companies. Any opinion or view herein is an expression of belief of the individual author or the indicated source (as applicable) only. PCM makes no representation or warranty that such information is accurate, complete, verified or should be relied upon as such. You must make your own financial assessment of the relevance, accuracy and adequacy of the information in this material.

This advertisement has not been reviewed by the Monetary Authority of Singapore.

 

Timeliness, accuracy and completeness of information

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Copyright 

PhillipCapital and/or its member companies reserve all copyright and intellectual property rights to the services, content, information and data on the Website. The contents in the Website are protected by copyright and no part or parts hereof may be modified, reproduced, stored in a retrieval system, transmitted (in any form or by any means), copied, distributed, published, displayed, broadcasted, hyperlinked, used for creating derivative works or used in any other way for commercial or public purposes without the prior written consent of PhillipCapital and/or its member companies.

 

No Warranties 

While every care has been taken in preparing the contents contained in the Website, such contents are provided to you “as is” and “as available” without warranty of any kind either express or implied. In particular, no warranty regarding non-infringement, security, accuracy, fitness for a particular purpose or freedom from computer virus is given in conjunction with such contents. Member companies of PhillipCapital, their directors, officers, associates, agents and affiliates make no representations, endorsements or warranties of any kind about the services, content, information and/or data contained in the Website.

 

Separate Contracts 

The provision of any service or products provided by PhillipCapital and/or its member companies through the Website shall be expressly subject to the particular terms and conditions as contained in the contract for the supply of such service or product. Any warranties or representations made in relation to the provision of such service or product are as made in the contract only and PhillipCapital and/or its member companies make no separate warranty or representation through the Website or through these general terms of use.

 

Exclusion of Liability and Indemnity 

In no event shall PhillipCapital and/or its member companies be liable to you for any loss, damage, costs, charges and/or expenses of whatsoever nature and howsoever arising including legal fees on a full indemnity basis, cost of funding and loss or cost incurred by you as a result of or in connection with:

  1. any access, use or the inability to access or use this website, use of or reliance on the contents of this website;
  2. any transaction performed on any web page in the Website;
  3. any loss or abuse or unauthorized disclosure of information, including customer information;
  4. any system, server or connection failure, error, omission, interruption, interception, delay in operation or transmission, or computer virus;
  5. any use of or access to any websites linked to the Website;
  6. any service, product, information, data, software or other materials obtained from this Website or from any other websites linked to this Website;
  7. breach or violation of any third party rights, including but not limited to the violation of any proprietary or intellectual property rights or the enforcement of any of these general terms of use.

 

Governing Law 

These general terms of use shall be governed by and construed in accordance with the laws of the Republic of Singapore and all parties hereby agree to submit to the exclusive jurisdiction of the courts of the Republic of Singapore. Products and services referred to in this website are offered only in jurisdictions where and when they may be lawfully offered by PhillipCapital and/or its member companies. The contents in the Website are not intended for use by persons located in or resident in jurisdictions that restrict the distribution of such materials by us. Persons accessing these pages are required to inform themselves about and observe any relevant restrictions. The terms and conditions governing the use of the Website of each member company of PhillipCapital may differ and you should consult and carefully read the applicable terms and conditions before using the website.

This advertisement or publication has not been reviewed by the Monetary Authority of Singapore.