Alvarium Fund Managers (UK) Limited

Limits on the record

• No New Business

  1. The Firm must not, without prior written consent of the FCA: a. where the Firm acts as Alternative Investment Fund Manager (‘AIFM’) or an Authorised Corporate Director (‘ACD’), for or on behalf of any fund, accept any new investors or accept any additional investor capital; b. establish, become the ACD or an AIFM of, or take on the management of any funds; c. conduct any new business in relation to the following regulated activities under the Firm’s Part 4A permission: to advise, deal in investments as agent, manage investments, make arrangements and/or arrange deals in investments, arrange safeguarding and administration of assets, establish, operate or wind up a CIS and/or agree to carry on a regulated activity. d. seek to act as a regulatory Principal nor appoint any Appointed Representatives; and e. appoint or act as an investment manager for, or on behalf of, any AIFM or fund. Effective date 2. The Requirements are to take effect immediately on their acceptance by the Authority and notification of such to the Firm by email. 3. The Requirements will stay in effect unless and until varied or cancelled by the Authority (either on the application of the Firm or of the Authority’s own volition).

• Asset Requirement

  1. The Firm must not, other than in the ordinary course of business or without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets (whether in the United Kingdom or elsewhere). 2. The assets requirement does not apply to monetary payments or the disposal of assets made by the Firm in the ordinary course of business. For the purposes of paragraph 1, the Authority considers that the following would be in the ordinary course of business: a. transactions giving effect to instructions initiated by clients of the Firm, other than any clients that are also the Firm’s controllers, members, officers or employees; b. payments of funds to the Firm’s suppliers or other third parties in satisfaction of the Firm’s contractual and/or legal obligations (including but not limited to payments of or on account of professional fees or expenses, including but not limited to legal, compliance and/or other professional fees or expenses of any professionals or consultants appointed by the Firm to advise in connection with its restructuring/wind down or otherwise); c. usual and proper salary payments made by the Firm; and d. the transfer or disposal of any of the Firm’s or its fund’s investment management agreements to any third party, provided that (a) the Firm gives the Authority no less than five working days’ prior written notice of any such transfer or disposal, such notice to include details of the investment management agreements to be transferred or disposed and the details of any counterparty, and (b) the Authority provides its written consent to the Firm for such a disposal. 3. For the purposes of paragraph 1, the Authority considers that the following payments would not be regarded as payments made in the ordinary course of business: a. payments of unusual or significant amounts to the Firm’s controllers, members, officers, employees or any connected persons (which shall include any management or performance fees); b. the making of any capital distribution; and c. the making of any gift or loan by the Firm to any party. Effective date 4. The Requirements are to take effect immediately on their acceptance by the Authority and notification of such to the Firm by email. 5. The Requirements will stay in effect unless and until varied or cancelled by the Authority (either on the application of the Firm or of the Authority’s own volition).

• Reporting requirements

  1, The Firm must, as soon as possible, provide the Authority with its calculations of the following figures: a. the amount incurred over and above the expense cap on the Home Long Income Fund (“The Fund”); and b. the amount of fees that have been overcharged to the Fund. 2. The Firm must, by 12pm Friday every fortnight, provide the Authority with copies of the Firm’s bank accounts. 3. The Firm must, by 12pm Friday every fortnight, provide the Authority with written confirmation that it is adhering to the Requirements in this VREQ. Effective date 4. The Requirements are to take effect immediately on their acceptance by the Authority and notification of such to the Firm by email. 5. The Requirements will stay in effect unless and until varied or cancelled by the Authority (either on the application of the Firm or of the Authority’s own volition).

• This firm may handle your money in passing but must not hold it, so payments should go to the product provider, never to a personal account.