Heritage Capital Management Limited provides investment management services, mainly to private clients. Our offices are London SW1.

Our principle business is the management of investments for private clients, with portfolios of investments as widely diversified as necessary to ensure that our clients’ money is invested in a manner suitable and appropriate to their general investment objectives and their attitude to risk.

Things you should know before accessing this web site

Please read the information on this page carefully as it refers to any legal and regulatory restriction which may apply to various aspects of our website.

The material on this site is directed only at persons in the United Kingdom and is not an offer to take advantage of our services to persons in any other jurisdiction other than the UK. By proceeding you are representing and warranting that you are not resident in, or a citizen of, a jurisdiction outside the UK.

The information contained in this website has been compiled with considerable care and in good faith, to ensure its accuracy at the date of publication. However, no representation or warranty, express or implied, is made to its accuracy or completeness. We accept no liability for any loss or damage caused by incorrect information. You should independently verify any information before relying on it. Furthermore, no information on this site constitutes investment, tax, legal or other advice.

Although we hope that this website will be of use to you, we accept no liability and offer no warranties in relation to it and its content to the fullest extent such liability can be excluded by law.

Information on this website is subject to change without notice.

Heritage Capital Management Limited (HCML)

HCML is registered in England (company number 1435797) and is authorised and regulated by the Financial Conduct Authority (FCA). Its offices are at Broadway House, Tothill St, London, SW1H 0BT.

For further details of the regulated company, please contact the FCA on 0800 111 6768 or 020 7066 1000, or find HCML’s entry in the FCA register on the FCA’s website at www.fca.org.uk.

Risk Warnings

Stockmarkets and currency movements may cause the value of investments and the income from them to fall as well as rise, and investors may not get back the amount they originally invested.

Past performance is not a guide to future returns.

Where investments are made in markets considered to be ’emerging’, unquoted securities or smaller companies, their potential volatility may increase the risk to the value of, and the income from, the investment. Funds investing in these sectors and markets are only suitable for those investors who are prepared to accept the above average volatility inherent in investments in these sectors and markets.

Some funds may invest in complex financial instruments known as derivatives. Where this occurs there are additional risks associated with investments (made directly or through investment vehicles which invest) in such derivatives.

The information on this website does not in any way constitute investment advice. Nor does it constitute a recommendation. It is not intended to be relied upon by you in making (or refraining from making) any specific investment or other decisions. If you are in any doubt as to the information contained in these pages, please contact your independent financial adviser, stockbroker, solicitor, bank manager or other professional adviser.

Nothing on this Website constitutes or forms a part of any offer for sale or subscription of, or any invitation to offer to buy or subscribe for, any securities or other financial instruments, nor should it or any part of it form the basis of, or be relied upon in any connection with any contract or commitment whatsoever.

All electronic communications with the Company may be monitored in the UK in accordance with the UK Regulation of Investigatory Powers Act, Lawful Business Practice Regulations, 2000.

Copyright and reproduction of information

The copyright in the website and (unless otherwise indicated) its contents including all information, graphics, code, text and design are owned by HCML. Unauthorised use of this material is strictly forbidden.

Under no circumstances should the information on this website be copied, reproduced or redistributed other than printing or downloading for personal use only.

No rights of any kind are licensed or assigned or shall otherwise pass to persons accessing these pages.

Your use of this website

You agree that you will not:

  • place on this website any information which is abusive, illegal, libellous, pornographic, discriminatory or otherwise offensive;
  • transmit any virus, ‘worm’, ‘Trojan Horse’ or other item of a destructive nature to this site, and it is your responsibility to ensure that whatever

you download or select for your use from this site is free from such items;

  • seek damages from any such perpetrator.

Links to other websites and the world wide web

This site may contain links to other websites, which are not under our control and therefore we cannot accept any responsibility for their content, nor for the services or products offered through such websites.

Links must not be established to any pages of this website without our prior written consent.

Should the viewer leave this site via a link contained herein, and view content that is not provided by HCML, the viewer does so at its own risk. The content to which you link will not have been developed, checked for accuracy, or otherwise reviewed by HCML. HCML is not responsible for damages or losses caused by any delays, defects or omissions that may exist in the services, information or other content provided in such site, whether actual, alleged, consequential or punitive. HCML makes no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party, including, without limitation, the accuracy, subject matter, quality or timeliness of any electronic content.

Business changes

If HCML experiences a group reorganisation or is sold to a third party, the personal information provided to us may be transferred to that reorganised entity or third party to be used for the purposes highlighted above.

HCML policy for managing conflicts of interest in connection with investment research

Introduction

This policy reflects compliance with the FCA’s Principles for Business and Conduct of Business Rules. It does not create third party rights or duties that would not already exist if the policy had not been publicly available, and it does not form part of any contract between HCML and any client or prospective client. It is continually updated to reflect changes in legislation and good practice.

Application

This policy applies to investment research that is research that provides an impartial assessment of the value or prospects of its subject matter or research that would reasonably be intended as providing an impartial assessment.

Notwithstanding the above, HCML may from time to time publish research material that does not purport to be impartial in which case this policy will not apply. If and when HCML publishes such material, it will be clearly distinguishable from material the Company holds out as being impartial.

How does HCML identify conflicts?

HCML has implemented policies to identify and deal with conflicts that occur from time to time between recipients of its research and others. HCML manages those conflicts of which it is aware and monitors the effectiveness of its policies and procedures. In particular HCML makes every effort to disclose the interests both of itself and its employees in the subject matter of a research report. Typically, interests regarded as disclosable include interests of HCML or its employees and Directors in the securities referred to in any research.

Privacy Statement

Your data controller

For the purposes of the UK Data Protection Act 1998, the data controller in respect of any personal information provided is HCML. In this privacy statement “we”, “us” and “our” means HCML. The Act’s eight principles establish enforceable standards for obtaining, holding, using or disclosing information. The Act also requires appropriate security arrangements to be in place to protect personal data and gives individuals the right to access personal information held about them.

What personal information do we hold

We collect and use certain types of information about people we deal with as part of our investment services activity. These include individual clients and prospective clients, our own employees, suppliers and others we conduct business with.

Uses made of your personal information

The personal information that you provide to us will be used for a number of different purposes including: to help us develop new products and services; to contact you in relation to your enquiry; for internal analysis and research; to comply with legal or regulatory requirements; and to identify you when you contact us. We may use external third parties to process your personal information on our behalf in accordance with these purposes.

Sharing of your personal information

The personal information provided may also be shared with other organisations in order for us to comply with any legal or regulatory requirements.

Correction of incorrect information

With limited exceptions, you have the right to ask for a copy of the information that we hold on you in which case if permitted you may be charged for it. If any of such information is wrong, please tell us so that we can correct it.

Further information

If you have any queries, please see The Information Commissioner’s Office web site or contact the HCML Data Protection Officer at Broadway House, Tothill St, London, SW1H 0BT.

Conclusion

In proceeding to view this website you are acknowledging that you have read and understood the above and will abide by its terms and conditions.