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IMPORTANT: IF YOU ARE IN ANY DOUBT ABOUT THE CONTENTS OF THIS PROSPECTUS YOU SHOULD CONSULT YOUR PROFESSIONAL ADVISER.

State Street Unit Trust Management Limited, the authorised contractual scheme manager of the ACS, is the person responsible for the information contained in this Prospectus. To the best of its knowledge and belief (having taken all reasonable care to ensure that such is the case) the information contained herein does not contain any untrue or misleading statement or omit any matters required by the Collective Investment Schemes Sourcebook to be included in it. State Street Unit Trust Management Limited accepts responsibility accordingly.

PROSPECTUS

STATE STREET AUTHORISED CONTRACTUAL SCHEME

(An authorised contractual scheme formed as a co - ownership scheme under section 235A of the Financial Services and Markets Act 2000)

(A UCITS Scheme with FCA product reference number 728502)

This document constitutes the Prospectus for State Street Authorised Contractual Scheme which has been prepared in accordance with the Collective Investment Schemes Sourcebook.

This Prospectus is dated, and is valid as at 2 June 2025

Copies of this Prospectus have been sent to the FCA and the Depositary.

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Contents Page

1. Definitions ................................ ................................ ................................ ................................ .................. 2 2. Details of the ACS and its Structure ................................ ................................ ................................ ........... 6 2.1 General Information ................................ ................................ ................................ ....................... 6

2.2 The Structure of the ACS ................................ ................................ ................................ ................ 7 3. Buying, Redeeming, Conversion and Switching of Units ................................ ................................ .......... 10 3.1 Buying Units ................................ ................................ ................................ ................................ . 10 3.2 Redeeming Units ................................ ................................ ................................ .......................... 12 3.3 Late Trading ................................ ................................ ................................ ................................ .. 13 3.4 Switching ................................ ................................ ................................ ................................ ...... 13

3.5 Conversions ................................ ................................ ................................ ................................ .. 14 3.6 Dealing Charges ................................ ................................ ................................ ............................ 15 3.7 Transfers ................................ ................................ ................................ ................................ ...... 17 3.8 Restrictions and Compulsory Redemption ................................ ................................ ................... 17 3.9 Suspension of dealings in the ACS or a Sub - fund ................................ ................................ ......... 18

3.10 Money laundering ................................ ................................ ................................ ........................ 18 3.11 Market Timing ................................ ................................ ................................ .............................. 18 3.12 Governing law ................................ ................................ ................................ .............................. 18 4. Valuation of the ACS ................................ ................................ ................................ ................................ 19 4.1 General ................................ ................................ ................................ ................................ ......... 19 4.2 Calculation of the Net Asset Value ................................ ................................ ............................... 19

4.3 Price per Class of Unit in each Sub - fund ................................ ................................ ....................... 21 4.4 Pricing basis ................................ ................................ ................................ ................................ .. 21 4.5 Publication of Prices ................................ ................................ ................................ ..................... 21 4.6 Fair Value Pricing ................................ ................................ ................................ .......................... 21 5. Risk Factors ................................ ................................ ................................ ................................ .............. 22

5.1 Basis Risk… ................................ ................................ ................................ ................................ ... 22 5.2 Cash Position Risk ................................ ................................ ................................ ......................... 22 5.3 Client Assets – Insolvency of Depositary Risk ................................ ................................ ............... 22 5.4 Conflicts of Interest Risk ................................ ................................ ................................ ............... 22 5.5 Counterparty Risk ................................ ................................ ................................ ......................... 24 5.6 Currency Hedging Risk ................................ ................................ ................................ ................. 24

5.7 Currency Risk ................................ ................................ ................................ ................................ 25 5.8 Cybersecurity Risk ................................ ................................ ................................ ....................... 25 5.9 Depositary and Custodial Risk ................................ ................................ ................................ ...... 26 5.10 Depositary Receipts Risk ................................ ................................ ................................ ............. 26 5.11 Derivatives Risk ................................ ................................ ................................ ........................... 26 5.12 Effect of Initial, Conversion or Switching Risk… ................................ ................................ ............ 27

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5.13 EMIR and OTC Derivatives Contract Risk ................................ ................................ ...................... 27 5.14 Equity Investing Risk ................................ ................................ ................................ ..................... 27 5.15 Errors, Error Correction Policies and Unitholder Notification ................................ ..................... 27 5.16 ESG Criteria in Index Methodoloy Risk ................................ ................................ ......................... 28 5.17 Frequent Trading/Portfolio Turnover Risk ................................ ................................ ................... 28 5.18 Inflation Risk ................................ ................................ ................................ ................................ . 28

5.19 Index Licensing Risk ................................ ................................ ................................ ...................... 28 5.20 Index Error Risk ................................ ................................ ................................ ............................ 28 5.21 Index Tracking Risk ................................ ................................ ................................ ....................... 29 5.22 Index Risk/Passive Strategy Risk ................................ ................................ ................................ ... 29 5.23 Index Risk ................................ ................................ ................................ ................................ ..... 29 5.24 Investments in Multiple Countries Risk ................................ ................................ ........................ 29

5.25 Investment in Other Undertakings in Collective Investments (UCIs) Risk ................................ ... 30 5.26 Investment Style Risk - Large Cap Companies ................................ ................................ .............. 30 5.27 Investment Style Risk - Small, Mid and Micro Cap Companies ................................ ..................... 30 5.28 Investment Risk ................................ ................................ ................................ ........................... 31

5.29 IPO Risk Factor ................................ ................................ ................................ ............................. 31 5.30 Issuer Risk ................................ ................................ ................................ ................................ .... 31 5.31 Large Unitholder Risk ................................ ................................ ................................ ................... 31 5.32 Law or Regulation Risk ................................ ................................ ................................ ................. 31 5.33 Leveraging Risk ................................ ................................ ................................ ............................ 31 5.34 Limited Investment Program Risk ................................ ................................ ................................ 31

5.35 Liquidity Risk ................................ ................................ ................................ ................................ 32 5.36 Liquidity, Settlement and Derivatives Risk ................................ ................................ ................... 32 5.37 Management Risk ................................ ................................ ................................ ........................ 33 5.38 Market Disruption and Geopolitical Risk ................................ ................................ ..................... 33 5.39 Market Risk ................................ ................................ ................................ ................................ .. 33 5.40 OTC Clearing Risk ................................ ................................ ................................ ......................... 34

5.41 Preferred Securit i es Risk ................................ ................................ ................................ .............. 34 5.42 Provisional Allotment Risk ................................ ................................ ................................ ........... 35 5.43 Proxy Voting Program Risk… ................................ ................................ ................................ ........ 35 5.44 REIT Risk ................................ ................................ ................................ ................................ ....... 35 5.45 Repurchase Agreements Risk ................................ ................................ ................................ ....... 35

5.46 Risks Related to Screening ................................ ................................ ................................ ........... 36 5.47 Russia Sanctions Risk ................................ ................................ ................................ ................... 36 5.48 Securities Lending Risk ................................ ................................ ................................ ................. 36

5.49 Settlement Time Misalignment Risk… ................................ ................................ ....................... 37 5.50 Suitability Risk ................................ ................................ ................................ .............................. 37

5.51 Taxation Risk… ................................ ................................ ................................ ............................ 37 5.52 Tax Status of the Scheme Risk… ................................ ................................ ................................ 38 5.53 Umbrella Fund Structure Risk… ................................ ................................ ................................ 38

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5.54 Unitholder Indemnity Risk… ................................ ................................ ................................ ..... 38 5.55 Valuation Risk… ................................ ................................ ................................ ....................... 38 6. Management and Administration ................................ ................................ ................................ .................... 39

6.1 Regulatory Status ................................ ................................ ................................ ......................... 39 6.2 ACS Manager ................................ ................................ ................................ ................................ 39 6.3 The Depositary ................................ ................................ ................................ ............................. 39 6.4 The Investment Manager ................................ ................................ ................................ ............. 41 6.5 The Administrator ................................ ................................ ................................ ........................ 42 6.6 The Registrar and Transfer Agent ................................ ................................ ................................ . 42

6.7 The Auditors ................................ ................................ ................................ ................................ . 42 6.8 Conflicts of Interest ................................ ................................ ................................ ...................... 42 6.9 Proxy Voting and Asset Stewardship ................................ ................ ………………………………………… 43 6.10 Best Execution ................................ ................................ ................................ .............................. 44

7. Fees and Expenses ................................ ................................ ................................ ................................ ... 44

7.1 General ................................ ................................ ................................ ................................ ......... 44 7.2 Annual Management Charge ................................ ................................ ................................ ....... 44 7.3 Increase in the Annual Management Charge ................................ ................................ ............... 44 7.4 Dealing Charges ................................ ................................ ................................ ............................ 44 7.5 Charging of fees to capital or income ................................ ................................ ........................... 44 7.6 Costs and expenses included within the Annual Management Charge ................................ ........ 44

8. Other Payments Out of the Property of the ACS ................................ ................................ ...................... 45 8.1 Allocation of fees and expenses between Sub - funds ................................ ................................ ... 46 9. Unitholder Meetings and Voting Rights ................................ ................................ ................................ ... 46 9.1 ACS, Class and Sub - fund Meetings ................................ ................................ ............................... 46 9.2 Requisitions of Meetings ................................ ................................ ................................ .............. 46 9.3 Notice and Quorum ................................ ................................ ................................ ...................... 46

9.4 Voting Rights ................................ ................................ ................................ ................................ 46 10. Taxation ................................ ................................ ................................ ................................ ................... 47 10.1 General ................................ ................................ ................................ ................................ ......... 47 10.2 The Sub - funds ................................ ................................ ................................ .............................. 47 10.3 UK tax resident Unitholders ................................ ................................ ................................ ......... 47 10.4 Double Tax Treaties ................................ ................................ ................................ ...................... 48

10.5 Non - UK tax resident Unitholders ................................ ................................ ................................ . 49 10.6 Stamp Duty ................................ ................................ ................................ ................................ ... 49 10.7 Disclosure of Information ................................ ................................ ................................ ............. 49 10.8 Taxation Liability and Indemnity ................................ ................................ ................................ .. 49 10.9 International tax compliance (including FATCA and CRS) ................................ ............................ 50 11. Winding Up of the ACS or Termination of a Sub - fund ................................ ................................ .............. 50

11.1 General ................................ ................................ ................................ ................................ ......... 50 11.2 Winding up of the ACS ................................ ................................ ................................ ................. 50 11.3 Termination of a Sub - fund ................................ ................................ ................................ ........... 51

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11.4 Events on termination ................................ ................................ ................................ .................. 51 12. General Information ................................ ................................ ................................ ................................ 52 12.1 Accounting Periods ................................ ................................ ................................ ...................... 52

12.2 Income Allocations ................................ ................................ ................................ ....................... 52 12.3 Equalisation ................................ ................................ ................................ ................................ .. 52 12.4 Annual Reports ................................ ................................ ................................ ............................. 52 12.5 Documents of the ACS ................................ ................................ ................................ ................... 52 12.6 Complaints ................................ ................................ ................................ ................................ ... 53 12.7 Risk Management ................................ ................................ ................................ ........................ 53

12.8 Benchmark Contingency Plan ................................ ................................ ................................ ....... 53 12.9 Remuneration ................................ ................................ ................................ .............................. 53 12.10 Notices ................................ ................................ ................................ ................................ ......... 5 4 12.11 Telephone Recordings ................................ ................................ ................................ .................. 54

Appendix I Sub - fund Details

Appendix II Eligible Securities Markets and Eligible Derivatives Markets

Appendix III Investment and Borrowing Powers of the ACS

Appendix IV Categories of Professional Clients as set out in the FCA Handbook

Appendix V Certificate of Eligibility

Appendix VI Past Performance Tables and Investor Profile

Appendix VII List of other authorised collective investment schemes operated by the ACS Manager

Appendix VIII Directory

Appendix IX Sub - custodians used by the Custodian

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Important Information

No person has been authorised by the ACS Manager to give any information or to make any representations in connection with the offering of Units other than those contained in the Prospectus and, if given or made, such information or representations must not be relied on as having been made by the ACS Manager. The delivery of this Prospectus (whether or not accompanied by any reports) or the issue of Units shall not, under any circumstances, create any implication that the affairs of the ACS have not changed since the date hereof.

The distribution of this Prospectus and the offering of Units in certain jurisdictions may be restricted. Persons into whose possession this Prospectus comes are required by the ACS Manager to inform themselves about and to observe any such restrictions. T his Prospectus does not constitute an offer or solicitation by anyone in any jurisdiction in which such offer or solicitation is not authorised or to any person to whom it is unlawful to make such offer or solicitation.

Units are not listed on any investment exchange.

The Units have not been and will not be registered in the United States of America under any applicable legislation. They may not be offered or sold in the United States of America, any state of the United States of America or in its territories and posses sions or offered or sold to US Persons. The ACS has not been and will not be registered in the United States of America under any applicable legislation.

Potential investors should not treat the contents of this Prospectus as advice relating to legal, taxation, investment or any other matters and are recommended to consult their own professional advisers concerning the acquisition, holding or disposal of Un its.

The provisions of the ACS Deed are binding on each of the Unitholders and a copy of the ACS Deed is available on request from the ACS Manager.

This Prospectus has been issued for the purpose of section 21 of the FSMA by the ACS Manager.

The distribution of this Prospectus in certain jurisdictions may require that this Prospectus is translated into the official language of those countries. Should any inconsistency arise between the translated version and the English version, the English ve rsion shall prevail.

This Prospectus is based on information, English law and practice at the date hereof. The ACS Manager cannot be bound by an out of date prospectus when it has issued a new prospectus and investors should check with the ACS Manager that this is the most recently published prospectus.

In order to comply with legislation implementing UK obligations under intergovernmental agreements relating to the automatic exchange of information to improve international tax compliance (including the United States provisions commonly known as FATCA, an d the OECD’s Common Reporting Standard known as CRS) the ACS Manager will collect and report information about Unitholders for this purpose, including information to verify their identity and tax status.

When requested to do so by the ACS Manager or its agent, Unitholders must provide information to be passed on to HM Revenue & Customs, and to any relevant overseas tax authorities. By signing the application form to subscribe for Units, each Unitholder is agreeing to provide such information upon request at any time from the ACS Manager or its delegate. The ACS Manager may exercise its right to redeem completely the holding of a Unitholder (at any time upon any or no notice) if the Unitholder fails to provide the ACS Manager with the information the ACS Manager requests to satisfy its ob ligations under any international tax compliance regulations or other similar automatic exchange of information requirements.

Prospective investors and Unitholders should note that they are providing the ACS Manager with personal information, which may constitute personal data within the meaning of the Data Protection Legislation. The personal data of prospective investors and re gistered Unitholders shall be processed in accordance with the Privacy Statement. The ACS Manager (including its delegates) may transfer your information to countries located outside of the United Kingdom and the European Economic Area (the EEA). This may happen when our servers, suppliers and/or service providers are based outside of t he United Kingdom and the EEA. The data protection laws and other laws of these countries may not be as comprehensive as those that apply within the United Kingdom and the EEA. In these instances we will take steps to ensure that your privacy rights are re spected. Details relevant to you may be provided upon request. All communications by the Investment Manager and the ACS Manager in relation to this Prospectus shall be in English.

IMPORTANT: If you are in any doubt about the contents of this Prospectus you should consult your professional adviser.

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1. Definitions

“ACS” State Street Authorised Contractual Scheme, constituted as a co - ownership scheme;

“ACS Deed” the deed constituting the ACS as amended from time to time in accordance with the COLL Sourcebook;

“ACS Manager” State Street Unit Trust Management Limited, the authorised contractual scheme manager and its successors as authorised contractual scheme manager, of the ACS;

“ACS Manager’s Group” the group of companies consisting of the ultimate holding company of the ACS Manager and each of the subsidiaries of that holding company;

“Administrator” State Street Bank and Trust Company, or such other entity as is appointed to act as administrator to the ACS from time to time;

“Annual Management Charge” the periodic fee payable to the ACS Manager as set out in detail in paragraph 7.2;

“Approved Bank” (in relation to a bank account opened by the ACS):

(a) if the account is opened at a branch in the United Kingdom:

(i) the Bank of England; or

(ii) the central bank of a member state of the Organisation for Economic Co - operation and Development; or

(iii) a bank; or

(iv) a building society; or

(v) a bank which is supervised by the central bank or other banking regulator of a member state of the OECD; or

(b) if the account is opened elsewhere:

(i) a bank in (a); or

(ii) a credit institution established in an EEA State and duly authorised by the relevant home state regulator; or

(iii) a bank which is regulated in the Isle of Man or the Channel Islands; or

(iv) a bank supervised by the South African Reserve Bank;

“Associate” any member of the ACS Manager’s Group or any other person whose business or domestic relationship with the ACS or the ACS’s associate might reasonably be expected to give rise to a community of interest between them which may involve a conflict of interest in dealings with third parties;

“A “Auditor ” PricewaterhouseCoopers LLP, or such other entity as is appointed to act as auditor to the ACS from time to time;

“Authorised Contract” a contract which the ACS Manager is authorised to enter into on behalf of the Unitholders for the purposes of, and in connection with, the acquisition,

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management and/or disposal of any Scheme Property (but does not include a contract by which a person becomes a Unitholder);

“Base Currency” the currency in which the accounts of the ACS are to be prepared. Where the context requires, reference to “base currency” shall be to the currency to be used for a particular Sub - fund or Class or payments in relation to either of them;

“Benchmark Contingency Plan” has the meaning given in section 12.8 of the Prospectus;

“Benchmark Index” as disclosed in relation to each Sub - fund in Appendix I;

“Benchmark Regulation” has the meaning given in section 12.8 of the Prospectus;

“Business Day” as disclosed in relation to each Sub - fund in Appendix I;

“CASS” the Client Asset Rules Sourcebook published by the FCA and forming part of the FCA Handbook;

“Certificate of Eligibility” the certificate in the form set out in Appendix V, or as may be amended by the ACS Manager from time to time, to be provided by each new prospective Unitholder confirming that they are an Eligible Investor;

“Class” or “Classes” in relation to Units, means (according to the context) all of the Units related to a single Sub - fund or a particular class or classes of Unit related to a single Sub - fund;

“COBS” the Conduct of Business Sourcebook published by the FCA and forming part of the FCA Handbook;

“COLL” refers to the appropriate chapter or rule in the COLL Sourcebook;

“COLL Sourcebook” the Collective Investment Schemes Sourcebook issued by the FCA as amended from time to time;

“Contractual Scheme Rules” the rules in the COLL Sourcebook made by the FCA under section 261J of FSMA (Contractual Scheme Rules) in relation to:

(a) the constitution, management and operation of authorised contractual schemes;

(b) the powers, duties, rights, and liabilities of the ACS manager and depositary of any such scheme;

(d) the winding up of any such scheme;

“Conversion” the conversion of Units in one Class in a Sub - fund to Units of another Class in the same Sub - fund and “Convert” shall be construed accordingly;

“Co - Ownership Scheme” a collective investment scheme which satisfies the conditions in section 235A(3) of FSMA and which is authorised for the purposes of FSMA by an authorisation order;

“Custodian” State Street Bank and Trust Company;

“ Data Protection Legislation ” means (i) Regulation EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as it forms part of the law of England and Wales, Scotland and Northern Ireland

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by virtue of the European Union (Withdrawal) Act 2018 and (ii) the Data Protection Act 2018 and other applicable UK laws;

“Dealing Cut Off Point” in respect of each Dealing Day, as further disclosed in relation to each Sub fund in Appendix I;

“Dealing Day” as disclosed in relation to each Sub - fund in Appendix I;

“Depositary” HSBC Bank plc, or such other person as is appointed to act as Depositary of the ACS from time to time;

“Depositary Services Agreement” has the meaning given in section 6 of the Prospectus;

“EEA State” a member state of the European Union and any other state which is within the European Economic Area;

“Efficient Portfolio Management” techniques and instruments which relate to transferable securities and approved money - market instruments and which fulfil the following criteria:

(a) they are economically appropriate in that they are realised in a cost effective way;

(b) they are entered into for one or more of the following specific aims:

(i) reduction of risk;

(ii) reduction of cost;

“Eligible Institution”

(iii) generation of additional capital or income for the scheme with a risk level which is consistent with the risk profile of the scheme and the risk diversification rules laid down in COLL;

one of certain eligible institutions as defined in the glossary of definitions to the FCA Handbook;

“Eligible Investor” (1) the trustee or other duly authorised representative acting on behalf of a pension fund which is authorised or registered in the United Kingdom or a European Economic Area State or elsewhere; or

(2) an insurance company which is authorised or regulated in the United Kingdom or a European Economic Area State or elsewhere, investing in respect of unit linked funds of the insurance company which are restricted to pension fund investors;

and, in each case, which satisfies at least one of the following criteria:

(a) is a professional ACS investor (being a person who is a professional client for the purpose of the FCA Handbook (as set out in Appendix IV));

(b) is a large ACS investor (being a person who in exchange for Units makes a payment of not less than £1 million or contributes property with a value of not less than £1 million);

or a nominee of such an entity (and “Eligible Investors” shall be construed accordingly);

“EU UCITS” means an Undertaking for Collective Investments in Transferable Securities established pursuant to the EU UCITS Directive;

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“EU UCITS Directive” means the European directive (Directive EC/2009/65/EC) relating to undertakings for collective investment in transferable securities (as amended);

“Euro” or “EUR” or “€” monetary unit of the official currency of the Eurozone countries;

“FCA” the Financial Conduct Authority or any other regulatory body which may assume its regulatory responsibilities from time to time;

“FCA Handbook” the FCA Handbook of Rules and Guidance, as amended from time to time;

“FCA Rules” the rules contained in the COLL Sourcebook, as amended or replaced from time to time, which shall, for the avoidance of doubt, not include guidance or evidential provisions contained in such Sourcebook;

“FSMA” the Financial Services and Markets Act 2000, as amended or replaced from time to time;

“HMRC” Her Majesty’s Revenue & Customs;

“Investment Manager” State Street Global Advisers Limited, the investment manager appointed by the ACS Manager in respect of the ACS, or such other entity as may from time to time be appointed as investment manager;

“Lending Agent”

“London Business Day”

means State Street Bank and Trust Company, London Branch;

Monday to Friday and being a day on which the London Stock Exchange is open for trading;

“Member State” means a member state of the European Economic Area;

“Net Asset Value” or “NAV” the value of the Scheme Property of a Sub - fund (or, as the context requires, of all existing Sub - funds of the ACS) less all the liabilities of that Sub - fund (or of all existing Sub - funds of the ACS) determined in accordance with the ACS Deed;

“OTC” over - the - counter;

“Privacy Statement” the privacy statement adopted by the ACS Manager as amended from time to time. The current version is available on www.ssga.com;

“Register” the register of Unitholders;

“Registrar and Transfer Agent” State Street Global Advisors Limited, or such other entity as is appointed to act as registrar and transfer agent to the ACS from time to time;

“Regulations” the Collective Investment in Transferable Securities (Contractual Scheme) Regulations 2013 (SI 2013/1388) and the FCA Handbook (including the COLL Sourcebook) and any other applicable rules made under FSMA from time to time in force. This does not include guidance or evidential requirements contained in that Sourcebook;

“Scheme Property” the scheme property of a Sub - fund or of all existing Sub - funds (as appropriate);

“Sub - fund” or “Sub - funds” a sub - fund of the ACS (being part of the Scheme Property of the ACS which is pooled separately) to which specific assets and liabilities of the ACS may be allocated and which is invested in accordance with the investment objective applicable to such sub - fund;

“Subscription Settlement Time” the date and time specified for the receipt of monies for payment of subscription monies set out in respect of each Sub - fund in Appendix I;

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“Switch” the switch, where permissible, of Units of one Sub - fund for Units of another Sub - fund and “Switching” shall be construed accordingly;

“Taxation” all forms of taxation whenever created or imposed and whether in the UK or elsewhere and shall include any taxes, duties, levies and any other amount in the nature of taxation in any relevant jurisdiction, including all fines, interest, penalties and expenses incidental and relating to any such tax, duty, levy or charge and their negotiation, settlement or dispute and any actual or threatened claim in respect of them;

“Tracking Error” a measure of how closely and consistently a Sub - fund tracks its benchmark index over time. The anticipated maximum level of Tracking Error for each Sub - fund is set out in Appendix I;

“UK UCITS” means an Undertaking for Collective Investments in Transferable Securities established pursuant to the UK UCITS Directive;

“UK UCITS Directive” the European directive (Directive EC/2009/65/EC) relating to undertakings for collective investment in transferable securities (as amended) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of the European Union (Wit hdrawal) Act 2018;

“UK UCITS Requirements” means the UK UCITS Directive and any supporting or delegated EU legislation to Directive EC/2009/65/EC (to the extent and as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of the European Union (Withdrawal) Act 2018), the Regulations and any FCA Handboo k rules to implement or supplement the UK UCITS Directive;

“Unit” or “Units” a unit or units in the ACS (including fractions of Units, with one fraction being equivalent to one thousandth of a Unit);

“Unitholder” a holder of registered Units;

“US” or “United States” the United States of America (including the States and the District of Colombia) and any of its territories, possessions and other areas subject to its jurisdiction;

“US Persons” a person who falls within the definition of “US Person” as defined in rule 902 of regulation S of the United States Securities Act 1933 and shall include additionally any person that is not a "Non - United States Person" within the meaning of United States Commodity Futures Trading Commission Regulation 4 .7;

“Valuation Point” the point, whether on a periodic basis or for a particular valuation, at which the ACS Manager carries out a valuation of the Scheme Property for the ACS or a Sub - fund (as the case may be) for the purpose of determining the price at which Units of a Class may be issued, cancelled or redeemed. For details of the Valuation Point of a Sub - fund see Appendix I; and

“VAT” value added tax.

2. Details of the ACS and its Structure

2.1 General Information

2.1.1 The ACS

State Street Authorised Contractual Scheme is an authorised contractual scheme in co - ownership form authorised by the FCA with effect from 5 February 2016. Please note that approval by the FCA in this context refers only to approval under FSMA 2000 and does not in any way indicate or suggest endorsement or approval of the ACS as an investment .

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The ACS has an unlimited duration.

As a consequence of being constituted as an authorised co - ownership scheme, the Sub - funds may be treated as tax transparent for the purposes of income and/or gains by relevant taxing jurisdictions where Unitholders are subject to taxation and therefore, in most cases, also treated as tax transparent by the ju risdictions from which any underlying income or gains arising to the Sub - fund are derived. Such tax transparency cannot, however, be guaranteed.

Where a Sub - fund is regarded as tax transparent in relevant taxing jurisdictions, each Unitholder should be entitled to claim the benefits of any applicable double taxation treaty between that Unitholder’s jurisdiction of residence and the jurisdiction in which any underlying income or gains arise. Each Unitholder should take appropriate advice as to the tax treatment of their investment in the Sub - fund.

In order for such treaty benefits to be available in relation to any underlying income and gains, it will generally be necessary that the Unitholder’s jurisdiction of tax residence (“the investor jurisdiction”) recognises the tax transparency of the releva nt Sub - fund and that the jurisdiction having primary taxing rights over such income and gains (“the investment jurisdiction”) respects the transparent treatment of the Sub - fund by the investor jurisdiction. In cases where either the tax authority in the in vestor jurisdiction does not recognise the tax transparency of the Sub - fund or the tax authority in the investment jurisdiction does not respect the transparent treatment by the tax authority in the investor jurisdiction, withholding or other taxes may ari se which would not have arisen had the Unitholder directly owned the underlying investments. In other words, that Unitholder would not obtain the benefits of tax transparency in relation to such income or gains.

It will be the responsibility of the Custodian, where appropriate, to make the necessary filings for reclaims of any tax withheld in cases where such reclaims are available, or, where appropriate, to protect against amounts being withheld in the first plac e.

Any economic benefit from such claims will be attributed to the appropriate Class of Units in the relevant Sub - fund, in order that only the Unitholders entitled to relevant treaty benefits should benefit from the amounts reclaimed. To this end, Unitholders will be required to provide the ACS Manager with evidence of their tax residence and of their particular tax status for treaty benefit purposes within that jurisdiction. It will be the responsibility of the Unitholder to notify the ACS Manager promptly sh ould there be a change in such status and, in any event, within 10 days of such change.

Unitholders are not liable for the debts of the Sub - fund or Sub - funds in which they are invested. Unitholders are not liable to make any further payment to a Sub - fund after they have paid the purchase price of their Units. They are, however, liable for any tax arising in respect of their proportionate share of the income and gains in the Sub - fund of Sub - funds in which they have invested.

The Scheme Property of each Sub - fund is beneficially owned by its Unitholders as tenants in common. Details of the Sub - funds are set out in Appendix I.

2.1.2 Base Currency

The base currency of the ACS is pounds sterling. Sub - funds may from time to time at the discretion of the ACS Manager be denominated in a currency other than the base currency. The currency of each Sub - fund is set out in Appendix I.

2.2 The Structure of the ACS

2.2.1 The Sub - funds

The ACS is structured as an umbrella authorised contractual scheme, in that different Sub - funds may be established from time to time by the ACS Manager with the approval of the FCA. On the introduction of any new Sub - fund, a revised prospectus will be prep ared setting out the relevant details of each Sub - fund.

The ACS is a UK UCITS scheme.

The assets of each Sub - fund are beneficially owned by the Unitholders in that Sub - fund as tenants in common and must not be used to discharge any liabilities of, or meet any claims against, any person other than the Unitholders in that Sub - fund. Consequent ly, the assets of each Sub - fund will be treated as separate from those of every other Sub - fund and will be invested in accordance with the investment objective and investment policy applicable to that Sub - fund. Investment of the assets of each of the Sub - f unds must comply with the COLL Sourcebook and the investment objective and policy of the relevant Sub - fund.

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Subject to the above, each Sub - fund will be charged with the liabilities, expenses, costs and charges of the ACS attributable to that Sub - fund, and within each Sub - fund charges will be allocated between Classes in accordance with the terms of issue of Unit s of those Classes. Any assets, liabilities, expenses, costs or charges not attributable to a particular Sub - fund may be allocated by the ACS Manager in a manner which it believes is fair to the Unitholders generally. This will normally be pro rata to the Net Asset Value of the relevant Sub - funds.

Please see paragraph 5.51 below “Umbrella Fund Structure Risk”.

Details of the Sub - funds, including their investment objectives and policies and charges, are set out in Appendix I.

The eligible securities markets and eligible derivatives markets on which the Sub - funds may invest are set out in Appendix II. A detailed statement of the general investment and borrowing restrictions in respect of each type of Sub - fund is set out in Appen dix III.

2.2.2 Eligible investors

Units may not be issued to a person other than an Eligible Investor.

In addition to the Certificate of Eligibility in the form set out in Appendix V, investors will be required to provide the ACS Manager with such information and documents as it may require regarding the investor and its tax status to enable appropriate tax treatment and benefits to be available.

In addition, investors must also meet any other investment criteria for any Class in which they intend to invest.

In the event that the ACS Manager becomes aware that the Units are vested in a person other than an Eligible Investor (or reasonably believes this to be the case) the ACS Manager reserves the right to redeem such Units forthwith. In these circumstances, th e Unitholder will immediately be deemed to have renounced title to the entire holding to the ACS Manager and the ACS Manager will redeem the entire holding. This will normally be at the next Valuation Point but the ACS Manager may create a special Valuatio n Point for this purpose upon giving the Depositary reasonable prior notice of the creation of such special Valuation Point.

Where it comes to the attention of the ACS Manager either through the Unitholder informing the ACS Manager or otherwise that an Eligible Investor holds Units in a Class which is inappropriate to its tax status (for example where the tax reclaim rate diverg es from that of other Unitholders in that Class due to changes in its own tax status or domestic exemptions affecting that Unitholder), or where the Unitholder has failed to provide the ACS Manager with such documentation as the ACS Manager may require in order to establish the Unitholder’s tax status, or does not meet any of the other investment criteria for the Sub - fund or Class in which the investor intends to invest or is invested, the ACS Manager reserves the right to redeem or convert (at the ACS Mana ger’s discretion and if an appropriate Class is available) such Units, as appropriate, forthwith. This will normally be the next Valuation Point but the ACS Manager may create a special Valuation Point for this purpose, upon giving the Depositary reasonabl e prior notice. In the event that no suitable alternative Class exists, the Unitholder will immediately be deemed to have renounced title to the entire holding to the ACS Manager. In such scenarios, the ACS Manager is not obliged to give the Unitholders pr ior notice of its actions and the Unitholder bears any consequent risks, including that of market movement.

In the event that a Unitholder becomes aware that it is not an Eligible Investor or that it beneficially owns Units which are inappropriate for its tax status, or for which it does not meet the other investment criteria as set out in this Prospectus and th e Appendices, then it must inform the ACS Manager as soon as possible and the ACS Manager will take action in accordance with the above provisions.

2.2.3 Classes of Units

Fractions of Units can be issued and these will be one thousandth of a whole unit.

Units have no par value and, within each Class in each Sub - fund subject to their denomination, are entitled to participate equally in the profits arising in respect of, and in the proceeds of, the termination of the relevant Sub fund or the winding up of the ACS. Units do not carry preferential or pre - emptive rights to acquire further Units.

The details of the Units presently available for each Sub - fund, including details of their criteria for eligibility, subscription and fee structure, are set out in Appendix I. Units may be available as both income and accumulation Units in respect of each Sub - fund. Further details of the Units presently available for each Sub - fund, including details of their criteria for subscription and fee structure, are set out in Appendix I. At present only accumulation Units are issued.

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Holders of accumulation Units are not entitled to be paid the income attributed to those Units, but rather that income is automatically transferred to (and retained as part of) the capital assets of the relevant Sub - fund on each interim income allocation d ate (if any), as well as on each interim accounting date (if any) and each annual accounting date. This income will be reflected in the price of an accumulation Unit. The classes of accumulation Units available at the date of this Prospectus have interim i ncome allocation dates on every Business Day save the annual accounting date.

If any distribution Units should be issued, then their holders will be entitled to be paid the distributable income attributed to those Units and the Prospectus will be updated accordingly to set out this procedure.

Further Classes of Unit may be established from time to time by the ACS Manager with the agreement of the Depositary and in accordance with the ACS Deed and the Regulations. On the introduction of any new Class, either a revised prospectus or a supplementa l prospectus will be prepared, setting out the details of each Class.

The currency of denomination for each new Class of Units will be determined at the date of creation and set out in the Prospectus issued in respect of the new Class of Units. Hedged Unit Classes may be made available in certain Sub - funds (see section 2.2.4 ).

Where a Sub - fund has different Classes, each Class, where relevant, may attract different rates of non - United Kingdom withholding or other taxes or charges, and so monies may be received or deducted from the Scheme Property attributable to such Classes in unequal proportions. In these circumstances, the proportionate interests of the Classes within a Sub - fund will be adjusted accordingly.

If a Unitholder’s tax status changes (for example, where its withholding tax rate or tax reclaim rate diverges from that of the other Unitholders in a Class due to changes in taxation treaties or domestic exemptions affecting the Unitholder), or where the Unitholder has failed to provide in a timely fashion such documentation as the ACS Manager may require in order to establish the Unitholder’s tax status, or where the Unitholder fails to meet any other investment criteria for that Sub - fund or Class the ACS Manager may in its sole discretion redeem that Unitholder’s Units or may Convert their Units into an appropriate Class as referred to in the paragraph headed “Eligible Investors” above, if an appropriate Class is available.

In such scenarios and subject to the provisions of paragraph 2.2.2, the ACS Manager is not obliged to give the Unitholder prior notice of its actions and the Unitholder bears any consequent risks, including that of market movement.

The net proceeds from subscriptions to a Sub - fund will be invested in the specific pool of assets constituting that Sub - fund. The ACS will maintain for each current Sub - fund a separate pool of assets, each invested for the exclusive benefit of the Unithold ers in the relevant Sub - fund.

To the extent that any Scheme Property, or any assets to be received as part of the Scheme Property, or any costs, charges or expenses to be paid out of the Scheme Property, are not attributable to one Sub - fund only, the ACS Manager will allocate such Scheme Property, assets, costs, charges or expenses between Sub - funds in a manner which the ACS Manager consider s is fair to all Unitholders of the ACS.

Units in the ACS are not currently listed on any investment exchange.

Units may be made available as either income or accumulation Units. Holders of distribution Units will be entitled to be paid the distributable income attributed to those Units. Holders of accumulation Units have income automatically transferred to the cap ital assets of the relevant Sub - fund on each interim and/or annual accounting date. This income is reflected in the price of an accumulation Unit.

Unitholders are entitled (subject to certain restrictions, in particular as regards meeting the eligibility criteria) to Convert all or part of their Units in a Class in a Sub - fund for Units of another Class within the same Sub - fund, where available, or to Switch them for Units of any Class within a different Sub - fund of the ACS. Details of these Conversion and Switching facilities and the restrictions are set out in paragraph 3.4 for Switching and paragraph 3.5 in the case of Conversions.

2.2.4 Hedged Unit Classes

Hedged share classes allow the ACS Manager to use currency hedging transactions to reduce the effect of fluctuations in the rate of exchange between the currencies of the underlying investments of the Sub - fund and the currency of denomination of each hedge d Unit Class. In respect of hedged Unit Classes, the ACS Manager may utilise various instruments including, but not limited to: forward currency contracts, currency futures and currency swaps to seek to reduce the effect of exchange rate fluctuations betwe en the currencies of the underlying

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investments of the Sub - fund and the currency of denomination of each hedged Unit Class (e.g. Sterling, Euro or US Dollar), based on the total value of each hedged Unit Class.

Unit Class hedging activity will not form part of the investment policy of any Sub - fund. The effects (i.e. gains or losses) and costs associated with hedging transactions will be attributed to the relevant Unit Class only. The currency transactions will no t cause the hedged Unit Classes to be leveraged. The value of each Unit Class to be hedged will be made up of both capital and income and the ACS Manager will aim to fully hedge the relevant hedged Unit Class although this may not always be achievable for various reasons. As such the hedged Unit Classes will not be completely protected from all currency fluctuations. For details of whether currency hedging is applicable to a Unit Class, please refer to the “Hedged Unit Class” section of Appendix I applicable to that Unit Class.

3. Buying, Redeeming, Conversion and Switching of Units

The dealing office of the Registrar and Transfer Agent is normally open from 9am to 5pm (London time) on each Dealing Day in respect of each Sub - fund to receive requests for the purchase, sale, Conversion and Switching of Units.

The ACS Manager may vary these times at its discretion.

The ACS Manager will accept instructions to purchase, sell, Switch or Convert the title of Units on the basis of an authority communicated by electronic means and sent by the Unitholder, or delivered on their behalf by a person that is authorised by the FC A, subject to:

(a) prior agreement between the ACS Manager (or the Registrar or Transfer Agent, on behalf of the ACS Manager) and the person making the communication as to the electronic media by which such communication may be delivered; and how such communications will be identified as conveying the necessary authority;

(b) assurance from any person who may give such authority on behalf of the investor that they will have obtained the required appointment in writing from the investor; and

(c) the ACS Manager (or the Registrar or Transfer Agent, on behalf of the ACS Manager) being satisfied that any electronic communications purporting to be made by an investor or his agent are in fact made by that person.

In addition, the ACS Manager may from time to time make arrangements to allow Units to be bought or sold on - line or through other communication media.

The ACS Manager will neither sell nor redeem (as those terms are defined in the FCA Rules) Units for its own account.

3.1 Buying Units

3.1.1 Procedure

An investor may effect an initial application for Units in a Sub - Fund by submitting each of the following duly completed documents to the Registrar and Transfer Agent for review and approval by it:

(a) an application form;

(b) a Certificate of Eligibility in the form set out in Appendix V of this Prospectus; and

(c) such other documents and information as the ACS Manager may require regarding the investor, and in particular in relation to such investor’s tax status, and to enable appropriate tax treaty benefits to be available.

The application form must be sent in accordance with the procedure set out in the application form.

An investor must also complete a dealing form for the initial and any subsequent purchases of Units and send this to the Registrar and Transfer Agent for review and approval by it and the ACS Manager. The ACS Manager may, at its discretion, also require investors to provide the documents listed at (b) and (c) above on subsequent purchases of Units.

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Valid instructions to purchase Units received before the relevant Dealing Cut Off Point will be processed at the Unit price calculated, based on the Net Asset Value per Unit, at the next Valuation Point following receipt of the instruction and subject to t he application of any applicable dilution levy or initial charge, except in the case where dealing in a Sub - fund has been suspended as set out in paragraph 3.9.

Payment in cleared funds in respect of orders for the purchase of Units is due on the Subscription Settlement Time specified for each Sub - fund in Appendix I. An application to purchase Units will only be deemed to have been accepted by the ACS Manager once it is in receipt of a valid dealing form, Certificate of Eligibility, and such other documents as the ACS Manager may require regarding the investor and in particular its tax status and to enable appropriate tax treaty benefits to be available and, if req uired by the ACS Manager, cleared funds for the application.

The ACS Manager, at its discretion, has the right to cancel a purchase deal if settlement is not received by the Subscription Settlement Time and any loss arising on such cancellation shall be the liability of the applicant. The ACS Manager is not obliged to issue Units, or may cancel any Units that have already been issued, if it does not receive cleared funds from an investor by the Subscription Settlement Time.

The ACS Manager reserves the right to charge interest at up to 4% above the prevailing Bank of England base rate, on the value of any settlement received later than the relevant Subscription Settlement Time.

No interest will be paid to investors on funds transferred prior to the Subscription Settlement Time or which are otherwise held prior to investment. Such funds may be subject to negative interest (if applicable).

A purchase of Units in writing or via any other communication media made available is a legally binding contract. Applications to purchase, which have been approved by the ACS Manager are, unless subsequently agreed otherwise by the ACS Manager, irrevocabl e. However, subject to its obligations under the Regulations, the ACS Manager has the right to reject, on reasonable grounds, any application for Units in whole or part, and in this event the ACS Manager will return any money sent, or the balance of such m onies, at the risk of the applicant.

Any subscription monies remaining after a whole number of Units have been issued will not be returned to the applicant. Instead, fractions of Units will be issued and these will be one thousandth of a whole Unit.

3.1.2 Documents the buyer will receive

A confirmation giving details of the number and price of Units bought will be issued no later than the end of the Business Day following the Valuation Point by reference to which the price is determined.

Registration of Units can only be completed by the ACS Manager upon receipt of any required registration details. These details may be supplied in writing to the ACS Manager or by returning to the ACS Manager the properly completed registration form and co py of the confirmation.

Ownership of Units will be evidenced by an entry on the Register. It is not possible to issue bearer units in an authorised contractual scheme. Income information provided in respect of periodic distributions on Units will show the number of Units held by the recipient at the end of the period.

3.1.3 Minimum subscriptions and holdings

The minimum initial subscriptions, subsequent subscriptions and holdings levels for each Class of Unit in a Sub - fund are set out in Appendix I.

If following a redemption, Switch or Conversion a holding in any Class of Unit should fall below the minimum holding for that Class, the ACS Manager has a discretion to effect a redemption of that Unitholder’s entire holding in that Class of Unit. The ACS Manager may use this discretion at any time. Failure not to do so immediately after such redemption, Switch or Conversion does not remove this right.

3.1.4 Issue of Units in exchange for in specie assets

The ACS Manager may, at its discretion, arrange for the ACS to issue Units in exchange for assets other than cash, but will only do so where the Depositary has taken reasonable care to determine that the ACS’s acquisition of those assets in exchange for the Units concerned is not likely to result in any material prejudice to the int erests of Unitholders. If any fee, cost or expense is incurred by the ACS in connection with the in specie transfer of assets by an investor then the number of Units issued to the investor will be reduced accordingly by the ACS Manager. Where the ACS Manag er considers the deal to be substantial in relation to the total size of the Sub - fund it may require the investor to contribute in specie.

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The ACS Manager will ensure that the beneficial interest in the assets is transferred to the ACS with effect from the issue of the Units.

The ACS Manager will not issue Units in any Sub - fund in exchange for assets the holding of which would be inconsistent with the investment objective or policy of that Sub - fund.

3.2 Redeeming Units

3.2.1 Procedure

Every Unitholder has the right to require the redemption of their Units on any Dealing Day, unless the value of Units which a Unitholder wishes to redeem will mean that the Unitholder will hold Units with a value less than the required minimum holding.

An investor may effect a redemption of Units in a Sub - Fund by sending a duly completed dealing form to the Registrar and Transfer Agent for review and acceptance by the Registrar and Transfer Agent. Valid instructions to redeem Units received before a Deal ing Cut Off Point by the ACS Manager will be processed at the Unit price calculated, based on the Net Asset Value per Unit, at the next Valuation Point following receipt of the instruction and subject to the application of any applicable dilution levy, exc ept in the case where dealing in a Sub - fund has been suspended as set out in paragrap h 3.9.

Please refer to Appendix I for the Dealing Cut Off Point applicable to each Sub - fund.

A redemption instruction in respect of Units in writing or via any other communication media made available is a legally binding contract. However, an instruction to the ACS Manager to redeem Units, although irrevocable, may not be settled if the redemptio n represents Units where the money due on the earlier purchase of those Units has not yet been received or if insufficient documentation or anti - money laundering information has been received by the ACS Manager.

In addition, on redemption a Unitholder’s income in the form of a tax reclaim which is accrued in the Net Asset Value per Unit but not yet received by the relevant Sub - fund, will be taken into account in the calculation of the Net Asset Value per Unit for the purposes of the redemption. Following a redemption, if it transpires that any such amount is paid to the former Unitholder and not paid to the relevant Sub - fund or the former Unitholder was not entitled to the tax reclaimed or the relevant tax reclaim fails in whole or in part (otherwise than through the negligence, fraud or wilful default of the ACS Manager, the Depositary or any other service provider), then the former Unitholder will be required to pay over to the Sub - fund a matching or equivalent am ount or amounts to each cancelled part of the accrual (the “Relevant Accrual Amount”) in the price of the relevant Units (while all foreign exchange risk will be borne by the Unitholder).In the event that a former Unitholder does not make good any such amo unt for whatever reason, the liability will remain with the relevant Sub - fund. If the Unitholder does not, upon request, pay to the relevant Sub - fund an amount equivalent to the Relevant Accrual Amount the ASC Manager has discretion to redeem any remaining Units in any Sub - fund belonging to such Unitholder for an amount equivalent to (so far as reasonably practicable) the value of such Relevant Accrual Amount.

The ACS Manager has the discretion to withhold payment of an amount equivalent to any tax reclaim which is accrued in the Net Asset Value per Unit, but which has not yet been received by the relevant Sub - fund, from amounts paid to a Unitholder on a redempt ion, such amounts being paid out to the Unitholder only when they are received by the Sub - fund in order to ensure that the remaining Unitholders are not disadvantaged.

For details of dealing charges see paragraph 3.6 below.

3.2.2 Documents a redeeming Unitholder will receive

A confirmation giving details of the number and price of Units redeemed will be sent to the redeeming Unitholder (or the first named Unitholder, in the case of joint Unitholders) together with (if sufficient written instructions have not already been given) a form of renunciation for completion and execution by the Un itholder (or by all the joint Unitholders) no later than the end of the Business Day following the later of the request to redeem Units or the Valuation Point by reference to which the price is determined.

Payment of redemption proceeds will normally be made via bank transfer in accordance with any instruction received. The ACS Manager may recover any bank charge levied on such transfers. Instructions to make payments to third parties (other than to nominees or intermediaries associated with the Unitholder account) will not normally be accepted.

Such payment will be made within the timeframes set out for each Sub - fund in Appendix I.

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3.2.3 Minimum redemption

Part of a Unitholder’s holding may be redeemed but the ACS Manager reserves the right to refuse a redemption request if the value of the Units of any Sub - fund to be redeemed is less than the minimum stated in respect of the appropriate Class in the Sub - fun d in question (see Appendix I).

3.2.4 In specie redemptions

If a Unitholder requests the redemption of Units the ACS Manager may at its discretion and where it considers the deal to be substantial in relation to the total size of the Sub - fund concerned or in some way detrimental to the Sub fund, arrange, having given prior notice in writing to the Unitholder, that, in place of payment for the Units in cash, the ACS transfers property or, if requested by the Unitholder and agreed to by the ACS Manager, the net proceeds of sale of the relevant property, to the Unitholder. Before the redemption proceeds of the Units become payable, the ACS Manager must give written notice to the Unitholder that the relevant property or the proceeds of sale of the relevant property will be transferred to that Unitholder so that the Unitholder can requi re the net proceeds of redemption rather than the relevant property if he so desires.

The Depositary must take reasonable care to ensure that the property concerned would not be likely to result in any material prejudice to the interests of Unitholders.

The ACS Manager will select the property to be transferred or sold in consultation with the Depositary.

3.2.5 Deferred Redemption

If the Registrar and Transfer Agent receives requests for the redemption of Units in excess of 10% of a Sub - Fund’s Net Asset Value in respect of any Dealing Day, the ACS Manager, may, at its sole discretion, elect to restrict the total value of Units to be redeemed to 10% of that Sub - fund’s Net Asset Value. If the ACS Manager elects to restrict the redemption of Units in this manner then all relevant redemption requests will be scaled down pro rata to the value of the Units request ed to be redeemed and, subject to the above restriction, any Units which are not redeemed on a Dealing Day, shall be treated as if a request for redemp tion has been made in respect of such Units, for the next and each subsequent Dealing Day, until all of the Units to which the original request(s) related have been redeemed. All deals relating to an earlier Valuation Point will be completed before those r elating to a later Valuation Point are considered.

3.3 Late Trading

“Late Trading” is defined as the acceptance of a subscription, redemption, Conversion or Switch order received after a Sub - fund’s applicable Valuation Point for that Dealing Day. Late Trading is not permitted. Late Trading will not include a situation in w hich the ACS Manager is satisfied that orders which are received after the Dealing Cut Off Point but before the Valuation Point have been made by investors before then (e.g. where the transmission of an order has been delayed for technical reasons).

3.4 Switching

Subject to any restrictions on the eligibility of investors for a particular Unit Class, a Unitholder may at any time Switch all or some of his Units of one Sub - fund (“Original Units”) for Units of another Sub - fund (“New Units”) in the ACS, subject to the transferee Sub - fund having an appropriate Class for the switching Unitholder. The number of New Units issued will be determined by reference to the respective prices of New Units and Original Units at the Valuation Point applicable at the time the Original Units are redeemed and the New Units are issued.

Unitholders wishing to Switch will be required to provide to the ACS Manager a Certificate of Eligibility for the Class to be Switched into together with such other documents and information as the ACS Manager may require regarding the investor including t he investors ability to meet the investment criteria and in particular in relation to such investor’s tax status and to enable appropriate tax treaty benefits to be available.

The ACS Manager may, at its discretion, make a charge on the Switching of Units between Sub - funds. Any such charge on Switching does not constitute a separate charge payable by a Unitholder, but is rather the application of any initial charge on the New Un its, subject to certain waivers. For details of the charges on Switching currently payable, please see paragrap h 3.6.2 “Charges on Switching or Conversion”. The ACS Manager may adjust the number of New Units to be issued to reflect the application of any charge on Switching together with any other charges or levies in respect of the application for the New Units or redempt ion of the Original Units as may be permitted pursuant to the COLL Sourcebook.

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If a partial Switch would result in the Unitholder holding a number of Original Units or New Units of a value which is less than the minimum holding in the Class concerned, the ACS Manager may, if it thinks fit, Switch the whole of the applicant’s holding of Original Units to New Units (and make a charge on Switching) or refuse to effect any Switch of the Original Units. S ave as otherwise specifically set out, the general provisions on procedures relating to redemption will apply equally to a Switch.

Written instructions must be received by the ACS Manager before a Dealing Cut Off Point in the Sub - fund or Sub funds concerned to be dealt with at the prices at the next Valuation Point or at such other Valuation Point as the ACS Manager at the request of the Unitholder giving the relevant instruction may agree. Switching requests received after a Dealing Cut Off Point will be held over until the next Dealing Day in each of the relevant Sub - fund or Sub - funds.

The ACS Manager may adjust the number of New Units to be issued to reflect the application of any charge on Switching together with any other charges or levies in respect of the application for the New Units or redemption of the Original Units as may be pe rmitted pursuant to the COLL Sourcebook.

Please note that under UK tax law a Switch of Units in one Sub - fund for Units in any other Sub - fund is treated as a redemption of the Original Units and a purchase of New Units and will, for persons subject to taxation, be a realisation of the Original Uni ts for the purposes of UK capital gains taxation, which may give rise to a liability to tax, depending upon the Unitholder’s circumstances. Each Unitholder should take appropriate advice as to the tax treatment of their investment in the Sub - fund.

A Unitholder who Switches Units in one Sub - fund for Units in any other Sub - fund will not be given a right by law to withdraw from or cancel the transaction.

3.5 Conversions

Subject to any eligibility criteria in relation to a Unit Class, Unitholders are permitted to Convert their Units in one Class in a Sub - fund for Units of another Class (if any) in the same Sub - fund.

Conversions will be effected by the ACS Manager recording a change of Class on the Register.

Investors should note that whilst Conversions are permitted, as Classes are designed for specific tax purposes related to the investors in those Classes, opportunities for Conversions are limited.

If a Unitholder should wish to Convert Units it should apply to the ACS Manager in the same manner as for a sale as set out above including the same requirements as to Certificates of Eligibility and such other documents as the ACS Manager may require rega rding the investor and in particular its tax status and to enable appropriate tax treaty benefits to be available. Unitholders should note that because of these requirements, Conversions may not be possible.

Where Conversions are possible, the ACS Manager will carry out instructions to Convert Units as soon as possible but this may not be at the next Valuation Point and instructions may be held over and processed with Conversion instructions given by other Uni tholders and in some cases may not be effected until the end of the relevant accounting period. Unitholders should contact the ACS Manager for further information on when a Conversion may be effected.

The number of Units to be issued in the new Class will be calculated relative to the latest price of the Units being Converted and the Units being issued.

Where a Conversion of Units would, if effected in accordance with the terms of any Conversion notice, result in a Unitholder holding less than the permitted minimum holding (by number or value) of Units in either Class as set out in the Prospectus from tim e to time, then the ACS Manager may (at its discretion) decide either to:

(a) treat the Unitholder in question as having served a conversion notice in respect of their entire holding of Units; or

(b) refuse to give effect to the conversion notice in question.

For the avoidance of doubt, each Conversion notice shall relate only to the Conversion of Units of a single Class.

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The ACS Manager may at its discretion make a charge on the Conversion of Units between Classes in a Sub - fund. For details of the charges on Conversion currently payable, please see paragraph 3.6.2 “Charges on Switching or Conversions”.

Please note that under UK tax law, conversions will not ordinarily be treated as a disposal for capital gains tax purposes (except if one or other of the Classes is hedged, or they are both hedged differently). Each Unitholder should take appropriate advic e as to the tax treatment of their investment in the Sub - fund.

3.6 Dealing Charges

The Sub - funds will be single priced (with either a dilution adjustment or dilution levy).

The price per Unit at which Units are bought, redeemed, Switched or Converted is the Net Asset Value per Unit. Any initial, Switching or Conversion charge or dilution levy, is payable in addition to the price or is deducted from the gross subscription or t he proceeds of the redemption monies.

3.6.1 Initial charge

The ACS Manager may impose a charge on the purchase of Units in each Class. The initial charge is calculated as a percentage of the price of a Unit in respect of each Unit Class and is set out in Appendix I. The ACS Manager may waive or discount the initia l charge at its discretion.

Any initial charge will be deducted from the subscription monies and is payable by the Unitholder to the ACS Manager.

From the initial charge received, or out of its other resources, the ACS Manager may pay a commission to relevant intermediaries.

3.6.2 Charges on Switching or Conversions

On the Switch or Conversion of Units, the ACS Deed authorises the ACS Manager to impose a charge. The charge on a Conversion or Switch shall be directly recoverable from the Unitholder concerned and may be accounted for in any adjustment made of the number of new Units to be issued pursuant to the Prospectus.

There are currently no charges on the Conversion or Switch of Units as set out in Appendix I for the relevant Sub fund other than the dilution levy that may be applied on a Switch of Units in a Sub - Fund.

3.6.3 Dilution

The actual cost of purchasing or selling underlying investments in a Sub - fund may deviate from the mid - market value used in calculating its Unit price, due to dealing charges, commissions, taxes, market impact and any spread between buying and selling prices of the Sub - fund’s underlying i nvestments. These dealing costs could have an adverse effect on the value of a Sub - fund, known as “dilution” which may adversely affect the performance of a Sub - fund. In order to mitigate the effect of dilution the Regulations allow the ACS Manager to make a dilution levy or dilution adjustment on the purchase, redemption or Switch of Units in a Sub - fund. Whether the ACS Manager applies a dilution levy or makes a dilution adjustment to a particular Sub - fund is set out in Appendix I.

3.6.4 Dilution Levy

Upon the acquisition or redemption or Switch of Units the dilution levy will be applied in connection with the associated costs of acquisition, liquidation or Switch (as the case may be) of the underlying Sub - fund investments (except to the extent that the ACS Manager is able to match an acquisition or redemption of Units against a corresponding redemption or acquisition of such Units).

The ACS Manager does not benefit from any dilution levy because any such amount will be paid into the relevant Sub - fund.

The need to charge a dilution levy will depend on the volume of purchases and redemptions. It is not possible to predict accurately whether dilution would occur at any point in time but given the nature of the holdings in the Sub - funds and the types of inv estors, the ACS Manager expects that a dilution levy will be applied on most occasions.

The estimated maximum dilution levy (where applicable) in relation to each Sub - fund is as detailed in Appendix I.

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The ACS Manager, in its absolute discretion, may waive, reduce or increase the dilution levy. The ACS Manager may alter its current dilution policy in accordance with the procedure set out in the Regulations.

3.6.5 Dilution Adjustment

A dilution adjustment is an adjustment to the Unit price (which means that the price of a Unit will be above or below the price which would have been resulted from the mid - market valuation) on the purchase, redemption, issue or cancellation of Units for th e purposes of reducing dilution in a Sub - fund (or to recover an amount which it has already paid or reasonably expects to pay in the future). This is also known as “swing pricing”. Where the dilution adjustment is applied to the price, it is applied for th e benefit of the Sub - fund and its Unitholders and the ACS Manager will not benefit from the dilution adjustment.

The level of any such dilution adjustment for each Sub - fund will be calculated by reference to the estimated or actual costs of dealing in the underlying investments of the Sub - fund, including any dealing spreads, commission, transfer taxes and in the case of securities traded on markets that are closed at the Valuation Point, the actual movements in the price of those securities from their last close price to the actual traded price, in accordance with the COLL Sourcebook.

The need to make a dilution adjustment will depend on the volume of sales or redemption of Units on any given day. The ACS Manager may make a dilution adjustment if, in its opinion, the existing Unitholders (prior to sales) or remaining Unitholders (follow ing redemptions) are likely to be economically adversely affected.

Unless the ACS Manager determines otherwise (and it is in the interests of Unitholders), a dilution adjustment will be made in the following circumstances:

(a) the Sub - fund is, in the opinion of the ACS Manager, experiencing a period of continued net outflows;

(b) the Sub - fund is, in the opinion of the ACS Manager, experiencing a period of continued net inflows;

(c) the Sub - fund experiences a level of net redemptions or net sales on any given day which exceed a pre determined level (“the Swing Threshold”) for each Sub - fund determined by the ACS Manager as reasonably necessary in order to avoid dilution to that Sub - fund. The Swing Threshold will be reviewed on an annual basis for each Fund; or

(d) in any other case where the ACS Manager is of the opinion that it is in the interests of Unitholders and potential Unitholders that the dilution adjustment be adjusted.

Generally, the estimated rate of dilution adjustment shall not exceed 2%of the Net Asset Value per Unit of the relevant Sub - fund. In extraordinary market circumstances, the rate of dilution adjustment could exceed this amount.

Where a dilution adjustment is made, it will increase the dealing price when there are net inflows into a Sub - fund and decrease the dealing price when there are net outflows.

As dilution is directly related to the value of inflows and outflows of money from a Sub - fund, it is not possible to predict accurately whether dilution will occur at any future point in time. Consequently it is also not possible to accurately predict how frequently the ACS Manager will impose a dilution adjustment. However, based on future projections the ACS Manager expects to apply the dilution adjustment 50 times per year.

Because the dilution adjustment for a Sub - fund will be calculated by reference to the costs of dealing in the underlying investments of that Sub - fund, including any dealing spreads and movements in the price of securities from their last close price to the actual traded price where those securities are traded on markets that are closed at the valuation point (both of which can vary with market conditions), the amount of any dilution adjustment can vary over time. The ACS Manager will regularly monitor the rate and frequency of dilution adjustments made in respect of each Sub - fund.

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Calculation of dilution adjustment

In applying a dilution adjustment the Manager intends to use the following basis of valuation:

(I) when by reference to any valuation point the aggregate value of the Units of all classes of a Fund issued exceeds the aggregate value of Units of all classes cancelled (a net inflow), any adjustment will generally be upwards. The dilution adjustment shall not exceed the Manager’s reasonable estimate of the difference between what the price would have been had the dilution adjustment not been taken into account and what the price would have been if the assets of the Fund had been valued on the best available market offer basis (plus dealing costs); and

(II) when by reference to any valuation point the aggregate value of the Units of all classes of a Fund cancelled exceeds the aggregate value of Units of all classes issued (a net outflow), any adjustment will generally be downwards. The dilution adjustment sha ll not exceed the Manager’s reasonable estimate of the difference between what the price would have been had the dilution adjustment not been taken into account and what the price would have been if the assets of the Fund had been valued on the best available market bid basis (less dealing costs).

3.7 Transfers

Unitholders are not entitled to transfer their Units.

3.8 Restrictions and Compulsory Redemption

In addition to the eligibility criteria referred to in paragraph 2.2.2, the ACS Manager may from time to time impose such restrictions as it may think necessary for the purpose of ensuring that no Units are acquired or held by any person in breach of the law or governmental regulation (or any interpretation of a law or regulat ion by a competent authority) of any country or territory or which would result in the ACS incurring any liability to taxation which the ACS is not able to recoup itself or suffering any other adverse consequence. In this connection, the ACS Manager may, i nter alia, reject in its discretion any application for the purchase, redemption, Conversion or Switch of Units.

If it comes to the notice of the ACS Manager that any Units (“affected Units”):

(a) are owned directly or beneficially in breach of any law or governmental regulation (or any interpretation of a law or regulation by a competent authority) of any country or territory; or

(b) would result in the ACS incurring any liability to taxation which the ACS would not be able to recoup itself or suffering any other adverse consequence (including a requirement to register under any securities or investment or similar laws or governmental regulation of any country or territory); or

(c) (in addition to the Certificate of Eligibility or any other necessary documentation referred to in paragraph 2.2.2 and any other Class specific criteria) are held in any manner by virtue of which the Unitholder or Unitholders in question is/are not qualified to hold such Units or if it reasonably believes this to be the case; or

(d) are owned by a Unitholder who is registered in a jurisdiction (where the Sub - fund is not registered or recognised by the relevant competent authority) whereby communication with that Unitholder by the ACS Manager, on behalf of the Sub - fund, might constitut e a breach of the regulations in that jurisdiction (unless specific action is taken by the ACS Manager to prevent such a communication constituting a breach); or

(e) are held in a manner which constitutes a breach of the ACS Deed or this Prospectus as to eligibility or entitlement to hold any Units,

the ACS Manager may give notice to the Unitholder(s) of the affected Units requiring that a request in writing be given for the redemption of such Units in accordance with the COLL Sourcebook. If any Unitholder upon whom such a notice is served does not wi thin 10 days after the date of such notice submit a written request for their redemption to the ACS Manager or establish to the satisfaction of the ACS Manager (whose judgement is final and binding) that he or the beneficial owner is qualified and entitled to own the affected Units, he shall be deemed upon the expiry of that 10 day period to have given a request in writing for the redemption or cancellation (at the discretion of the ACS Manager) of all the affected Units.

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A Unitholder who becomes aware that he is holding or owns affected Units shall immediately, unless he has already received a notice as set out above, submit a request in writing to the ACS Manager for the redemption of all his affected Units.

Where a request in writing is given or deemed to be given for the redemption of affected Units, such redemption will (if effected) be effected in the same manner as provided for in the COLL Sourcebook.

In addition units may be compulsorily redeemed in the circumstances set out in paragraph 3.2.1.

3.9 Suspension of dealings in the ACS or a Sub - fund

The ACS Manager may, with the prior agreement of the Depositary, and must without delay if the Depositary so requires, temporarily suspend the issue, cancellation, sale and redemption of Units in any or all of the Sub - funds where due to exceptional circumstances it is in the i nterests of all the Unitholders in the relevant Sub - fund or Sub - funds.

The ACS Manager and the Depositary must ensure that the suspension is only allowed to continue for as long as is justified having regard to the interests of Unitholders.

The ACS Manager or the Depositary (as appropriate) will immediately inform the FCA of the suspension and the reasons for it and will follow this up as soon as practicable with written confirmation of the suspension and the reasons for it to the FCA and the regulator in each EEA State where the relevant Sub - fund is offered for sale.

The ACS Manager will notify Unitholders as soon as is practicable after the commencement of the suspension, including details of the exceptional circumstances which have led to the suspension, in a clear, fair and not misleading way and giving Unitholders details of how to find further information about the suspensions.

Where such suspension takes place, the ACS Manager will publish details on its website (or that of the Investment Manager) or other general means, sufficient details to keep Unitholders appropriately informed about the suspension, including, if known, its possible duration. During the suspension, none of the obligations in COLL 6.2 (Dealing) will apply but the ACS Manager will comply with as much of COLL 6.3 (Valuation and Pricing) during the period of suspension as is practicable in light of the suspension .

Suspension will cease as soon as practicable after the exceptional circumstances leading to the suspension have ceased but the ACS Manager and the Depositary will formally review the suspension at least every 28 days and will inform the FCA of the review a nd any change to the information given to Unitholders.

The ACS Manager may agree during the suspension to accept orders in relation to Units in which case all deals accepted during and outstanding prior to the suspension will be undertaken at a price calculated at the first Valuation Point after the restart of dealings in Units.

3.10 Money laundering

The ACS Manager adheres to international anti - money laundering standards set by the Financial Action Task Force (FATF) and complies with all applicable anti - money laundering and sanctions laws and regulations. FATF is the global standard setting body for a nti - money laundering and combating the financing of terrorism (AML/CFT). In order to implement these standards, in certain circumstances investors may be asked to provide proof of identity when buying or redeeming Units. Until satisfactory proof of identit y is provided, the ACS Manager reserves the right to refuse to issue Units, pay the proceeds of a redemption of Units, or pay income on Units to the investor. In the case of a purchase of Units where the applicant is not willing to provide the information requested within a reasonable period, the ACS Manager also reserves the right to sell the Units purchased and return the proceeds to the account from which the subscription was made. These proceeds may be less than the original investment.

3.11 Market Timing

The repeated purchasing and selling of Units in response to short - term market fluctuations is known as “market timing”. The ACS Manager has a policy to prevent market timing. As part of its policy, the ACS Manager may refuse to accept an application to purchase Units from persons that they reasonably believe are engaged in market timing.

3.12 Governing law

All deals in Units are governed by English law.

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4. Valuation of the ACS

4.1 General

Sub - funds will be single priced. Currently, each of the Sub - funds is single priced and the Prospectus reflects this. In the event that Sub - funds are launched in the future with a different pricing basis, the Prospectus will be updated accordingly.

Currently, each Class of Units is single priced. As such, the price of a Unit is calculated by reference to the Net Asset Value of the Sub - fund to which it relates. The Net Asset Value per Unit of a Sub - fund is currently calculated on each Dealing Day at t he Valuation Point of the Sub - fund. For details of the Valuation Point of a Sub - fund, please see Appendix I.

The ACS Manager may at any time during a Business Day carry out an additional valuation if it considers it desirable to do so and may use the price obtained at such additional Valuation Point as the price for the day. The ACS Manager shall inform the Depos itary of any decision to carry out any such additional valuation. Valuations may be carried out for effecting a scheme of amalgamation or reconstruction, which do not create a Valuation Point for the purposes of dealings.

Where permitted and subject to the Regulations, the ACS Manager may, in certain circumstances (for example where a significant event has occurred since the closure of a market) substitute a price with a more appropriate price which in its opinion reflects a fair and reasonable price for that investment.

The ACS Manager will, upon completion of each valuation, notify the Depositary of the price of Units of each Class of each Sub - fund and the amount of any dilution levy made in respect of any purchase or redemption of Units.

A request for dealing in Units must be received by the Dealing Cut Off Point in order to be processed for the next Valuation Point. A dealing request received after this time will be held over and processed on the next Dealing Day, using the Net Asset Valu e per Unit calculated as at the Valuation Point on that next Dealing Day.

4.2 Calculation of the Net Asset Value

The value of the Scheme Property of each Sub - fund shall be the value of its assets less the value of its liabilities determined in accordance with the following provisions:

(a) All the Scheme Property of each Sub - fund (including receivables) is to be included, subject to the following provisions.

(b) Scheme Property which is not cash (or other assets dealt with in paragraph (c) below) or a contingent liability transaction will be valued as follows and the prices used will (subject as follows) be the most recent prices which it is practicable to obtain:

(i) securities will be valued at the Valuation Point;

(ii) In the case of units or shares in a collective investment scheme:

(A) if a single price for buying and selling units or shares is quoted, at that price; or

(B) if separate buying and selling prices are quoted, at the average of the two prices provided the buying price has been reduced by any initial charge included therein; or

(C) if, in the opinion of the ACS Manager, the price obtained is unreliable or no recent traded price is available or if no recent price exists, at a value which, in the opinion of the ACS Manager, is fair and reasonable;

(iii) In the case of any other transferable security:

(A) if a single price for buying and selling the security is quoted, at that price; or

(B) if separate buying and selling prices are quoted, at the average of the two prices; or

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(C) if, in the opinion of the ACS Manager, the price obtained is unreliable or no recent traded price is available or if no price exists, at a value which, in the opinion of the ACS Manager, is fair and reasonable;

(iv) In the case of property other than that described in (i), (ii) and (iii) above: at a value which, in the opinion of the ACS Manager, represents a fair and reasonable mid - market price.

(c) Cash and amounts held in current and deposit accounts and in other time - related deposits shall be valued at their nominal values.

(d) Property which is a contingent liability transaction will be treated as follows:

(i) if a written option or an off - exchange derivative the method of valuation will be agreed between the ACS Manager and the Depositary;

(ii) if an off - exchange future, it will be valued at the net value of closing out in accordance with a valuation method agreed between the ACS Manager and the Depositary;

(iii) if any other form of contingent liability transaction or if the property is an off exchange derivative, the method of valuation will be agreed between the ACS Manager and the Depositary.

(e) In determining the value of the Scheme Property of each Sub - fund, all instructions given to issue or cancel Units will be assumed to have been carried out (and any cash paid or received) whether or not this is the case.

(f) Subject to paragraphs (g) and (h) below, agreements for the unconditional sale or purchase of property which are in existence but uncompleted will be assumed to have been completed and all consequential action required to have been taken. Such unconditiona l agreements need not be taken into account if made shortly before the valuation takes place and, in the opinion of the ACS Manager, their omission will not materially affect the final net asset amount.

(g) Futures or contracts for differences which are not yet due to be performed and unexpired and unexercised written or purchased options will not be included under paragraph (f).

(h) All agreements are to be included under paragraph (f) which are, or ought reasonably to have been, known to the person valuing the property.

(i) There will be deducted an estimated amount for anticipated tax liabilities (whether of the United Kingdom or elsewhere) at that time including (as applicable and without limitation) capital gains tax, income tax, corporation tax, value added tax and stamp duty.

(j) There will be deducted an estimated amount for any liabilities payable out of the Scheme Property of the relevant Sub - fund and any tax thereon treating periodic items as accruing from day to day.

(k) There will be deducted the principal amount of any outstanding borrowings whenever payable and any accrued but unpaid interest on borrowings.

(l) There will be added an estimated amount for accrued claims for tax of whatever nature which may be recoverable.

(m) There will be added any other credits or amounts due to be paid into the Scheme Property of the relevant Sub - fund.

(n) There will be added a sum representing any interest or any income accrued due or deemed to have accrued but not received.

(o) Currencies or values in currencies other than the base currency will be translated at the relevant Valuation Point at a rate of exchange determined by the ACS Manager that is not likely to result in any material prejudice to the interests of Unitholders or potential Unitholders.

Notwithstanding the foregoing, the ACS Manager may, at its discretion, use other generally recognised valuation principles in order to reach a proper valuation of the Net Asset Value of the Scheme Property of a Sub - fund, in the event that it is impractical or manifestly incorrect to carry out a valuation of an investment in accordance with the

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above rules or it considers that valuation in accordance with such principles better reflects the value of a security, interest or position and are in accordance with generally accepted accounting principles.

4.3 Price per Class of Unit in each Sub - fund

The price per Unit at which Units are bought or are redeemed is the Net Asset Value per Unit. There will be a single price per Unit. Any initial, Switching, Conversion charge or dilution levy is payable in addition to the price or deducted from the proceed s and is taken from the gross subscription or redemption monies.

Each allocation of income made in respect of any Sub - fund at a time when more than one Class is in issue in respect of that Sub - fund shall be done by reference to the relevant Unitholder’s proportionate interest in the income property of the Sub - fund in qu estion calculated in accordance with the ACS Deed.

4.4 Pricing basis

The ACS Manager deals on a forward pricing basis. A forward price is the price calculated at the next Valuation Point after the purchase or redemption is deemed to be accepted by the ACS Manager.

4.5 Publication of Prices

The prices of Units are available daily on the Investment Manager’s website at ssga.com.

As the ACS Manager deals on a forward pricing basis, the price that appears in these sources will not necessarily be the same as the one at which investors can currently deal. The ACS Manager may also, at its sole discretion, decide to publish certain Unit prices in third party websites or publications but the ACS Manager does not accept responsibility for the accuracy of the prices published in, or for the non - publication of prices by, these sources for reasons bey ond the control of the ACS Manager.

4.6 Fair Value Pricing

The ACS Manager is permitted to use fair value pricing in specific circumstances and pursuant to processes and methodologies that it must have notified to the Depositary if the ACS Manager has reasonable grounds to believe that no reliable price exists for one or more underlying securities at a Valuation Point or the most recent price available does not reflect the ACS Manager’s best estimate of the value of the security at the Valuation Point. Examples of the circumstances in which the ACS Manager might consider using fair value pricing include:

(a) failure of a pricing provider;

(b) closure or failure of a market;

(d) markets closed over national holidays;

(e) stale or unreliable prices; or

(f) listings suspensions or de - listings.

Additionally, the ACS Manager may decide to use fair value pricing when the markets in which the ACS is invested are closed for trading in situations such as (but not limited to):

(g) market movements above a pre - set trigger level in other correlated open markets;

(h) war, natural disaster or terrorism;

(i) government actions or political instability;

(j) currency realignment or devaluation;

(k) changes in interest rates;

(l) corporate activity;

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(m) credit default or distress; or

(n) litigation.

Additionally, the ACS Manager may decide to use fair value pricing if there is a significant event since the most recent closure of the market where the price of the security is taken. A significant event is one that means, in the ACS Manager’s judgement, the most recent price of a security or a basket of securities is materially different to the price that it is reasonably believed would exist at the Valuation Point had the relevant market been open. For this purpose, the ACS Manager may utilise pre - determ ined trigger levels in accordance with the ACS Manager’s fair valuation policy, which take into account the materiality of any variance. For markets that are closed as at the Valuation Point, the ACS Manager may use a regular automated fair value mechanism based on pre - determined trigger levels. The ACS Manager’s decision to use fair value pricing will also depend on the securities involved and the basis and reliability of the alternative price used.

In these circumstances the ACS Manager may in its discretion value an investment at a price which, in its opinion, reflects a fair and reasonable price for that investment.

5. Risk Factors

The risks set out in this Prospectus do not purport to be exhaustive and potential investors should be aware that an investment in the ACS may be exposed to risks of an exceptional nature from time to time.

Potential investors should consider the following risk factors before investing in the ACS (or in the case of specific risks applying to specific Sub - fund(s), in those Sub - fund(s)).

5.1 Basis Risk

A Sub - fund may gain exposure to an underlying asset by investing directly into that asset, or by purchasing a derivative instrument that is expected (but not guaranteed) to provide the same returns as the underlying asset. Basis Risk occurs when the return s provided by the derivative instrument deviate from the returns of the underlying asset.

5.2 Cash Position Risk

A Sub - fund may hold a significant portion of its assets in cash or cash equivalents in the Investment Manager’s discretion. If a Sub - fund holds a significant cash position, its investment returns may be adversely affected, and such Sub - fund may not achieve its investment objective.

5.3 Client Assets – Insolvency of Depositary Risk

The Depositary has a duty to ensure that it safeguards and administers the Scheme Property in compliance with the provisions of the FCA Handbook governing the protection of client assets (“ Client Asset Rules ”). Where investors pass money to the Depositary or its agent for the purpose of creating Units in a Sub - fund, the Depositary or its agent will hold that money on deposit as banker and not as Depositary and therefore will not be under a duty to comply with the provisions of the FCA Handbook on holding mo ney (“ Client Money ”) received in the course of designated investment business (“ Client Money Rules ”). Further, the Depositary will hold money for the purpose of buying investments or the proceeds of the sale of investments (“ Scheme Money ”) as banker and not as Depositary. The Scheme Money will not therefore be protected under the Client Asset Rules. Moreover, with respect to handling the Scheme Property in the course of delivery versus payment transactions through a commercial settlement system (“ CSS ”), the Scheme Property may not be protected under the Client Asset Rules. In the event that the Depositary becomes insolvent or otherwise fails, there is a risk of loss or delay in return of (a) any Client Money; and (b) any Scheme Property.

5.4 Conflicts of Interest Risk

An investment in a Sub - fund may be subject to a number of actual or potential conflicts of interest. Subject to applicable law, a Sub - fund may engage in transactions that may trigger or result in a potential conflict of interest. For example: the ACS Manager or its affiliates may provide services to the Sub - fund, such as securities lending agency services, custodial, administrative, bookkeeping, and accounting services, transfer agency, and unitholder servicing, and other services for which the Sub - fund would compensate the ACS Manager and/or such affiliates.

A Sub - fund may enter into securities transactions with the ACS Manager or an affiliate of the ACS Manager where the ACS Manager or an affiliate acts as agent for a Sub - fund in connection with the purchase or sale of securities, or

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as principal, where the ACS Manager or an affiliate sells securities to a Sub - fund or buys securities from a Sub - fund for its own account.

The ACS Manager or an affiliate on behalf of the Sub - fund may enter into repurchase agreements and derivatives transactions with or through the ACS Manager or one of its affiliates as specified in Appendix I.

A Sub - fund may invest in other pooled investment vehicles sponsored, managed, or otherwise affiliated with the ACS Manager , in which event the Sub - fund may not be charged subscription or redemption fees on account of such investment but will bear a share of the expenses of those other pooled investment vehicles. Those investment vehicles may pay fees and other amounts to the ACS Manager or its affiliates, which might have the effect of increasing the expenses of the Sub - fund. It is possible that other clie nts of the ACS Manager or its affiliates will purchase or sell interests in such other pooled investments at prices and at times more favourable than those at which the Sub - fund does so. Please note, for investments into money market funds managed by the A CS Manager or an affiliate, mandated redemption fees may be imposed under Money Market Fund Regulations.

There is no assurance that the rates at which the Sub - fund pays fees or expenses to the ACS Manager or its affiliates, or the terms on which it enters into transactions with the ACS Manager or its affiliates or on which it invests in any such other investm ent vehicles will be the most favourable available in the market generally or as favourable as the rates the ACS Manager makes available to other clients. There will be no independent oversight of prices, fees or expenses paid to, or services provided by, the ACS Manager or its affiliates. Because of its financial interest, the ACS Manager or its affiliates may have an incentive to enter into transactions or arrangements on behalf of the Sub - fund with itself or its affiliates in circumstances where it might not have done so in the absence of that interest. Transactions and services with or through the ACS Manager or its affiliates will, however, be effected in accordance with the applicable regulatory requirements.

The ACS Manager and its affiliates serve as investment manager to other clients and may make investment decisions for their own accounts and for the accounts of others that may be different from those that will be made by the ACS Manager or its affiliates on behalf of a Sub - fund. For example, the ACS Manager or its affiliates may provide asset allocation advice to some clients that may include a recommendation to invest or redeem from a particular issuer or fund while not providing that same recommendation to all clients invested in the same or similar issuers.

Other conflicts may arise, for example, when clients of the ACS Manager or its affiliates invest in different parts of an issuer’s capital structure, so that one or more clients own senior debt obligations of an issuer and other clients own junior debt of the same issuer, as well as circumstances in which clients invest in different tranches of the same structured financing vehicle. In such circumstances, decisions over whether to trigger an event of default or over the terms of any workout may result in co nflicts of interest. When making investment decisions where a conflict of interest may arise, the ACS Manager will endeavour to act in a fair and equitable manner, in accordance with its conflicts of interest policy, as between the relevant Sub - fund and ot her clients. Subject to the foregoing, (i) the ACS Manager and its affiliates may invest for their own accounts and for the accounts of clients in various securities that are senior, pari passu or junior to, or have interests different from or adverse to, the securities that are owned by a Sub - fund; and (ii) subject to applicable law, the ACS Manager and its affiliates may, at certain times, simultaneously seek to purchase (or sell) investments for the Sub - fund and to sell (or purchase) the same investment for accounts, funds or structured products for which it, or its affiliates, serve as investment manager now or in the future, or for other clients or affiliates and may enter into cross trades in such circumstances.

In addition, the ACS Manager and its affiliates may buy securities from or sell securities to a Sub - fund, if permitted by applicable law. These other relationships may also result in securities laws restrictions on transactions in these instruments by a Su b - fund and otherwise create potential conflicts of interest for the ACS Manager and its affiliates.

The ACS Manager and its affiliates, in connection with its other business activities, may acquire material non - public confidential information that may restrict the ACS Manager or its affiliates from purchasing securities or selling securities for itself o r its clients (including a Sub - fund) or otherwise using such information for the benefit of its clients or itself.

There is no prohibition on the Depositary, the Administrator, the ACS Manager, the Investment Manager or any other party related to a Sub - fund acting as valuer for the purposes of determining the probable realisation value of an asset of the Sub - fund in ac cordance with the valuation provisions outlined in the “ Calculation of the Net Asset Value ” section of this Prospectus. Unitholders should note however, that in circumstances where fees payable by a Sub - fund to such parties are calculated based on the NAV , a conflict of interest may arise as such fees will increase if the NAV increases. Any such party will endeavour to ensure that such conflicts are resolved fairly and in the best interest of the Unitholders.

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The Sub - fund will require the Investment Manager to provide best execution when executing orders or transmitting orders on behalf of the Sub - fund. The Investment Manager will take all sufficient steps to obtain, when executing orders or transmitting orders on the Sub - fund’s behalf, the best possible result for the Sub - fund, taking int o account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to execution of the order. In determining what constitutes best execution, the Investment Manager may consider additional factors they d eem relevant, including but not limited to, the breadth of the market in the security, the financial condition and execution capability of the broker or dealer and the reasonableness of the commission, if any, for the specific transaction, on a continuing basis. When executing or transmitting orders on behalf of the Sub fund, the Investment Manager will take into account any specific instruction from the ACS Manager regarding execution of the order.

A director of the ACS Manager (a “ Director ”) may be a party to, or otherwise interested in, any transaction or arrangement with a Sub - fund or in which a Sub - fund is interested, provided that she/he has disclosed to the other Directors prior to the conclusion of any such transaction or arrangement the nature and extent of any material interest of his therein. The Directors shall endeavour to ensure that any conflict of interest is resolved fairly.

The foregoing does not purport to be a comprehensive list or complete explanation of all potential conflicts of interests which may affect the Sub - fund. A Sub - fund may encounter circumstances, or enter into transactions, in which conflicts of interest that are not listed or discussed above may arise.

5.5 Counterparty Risk

Each Sub - fund will be subject to credit risk with respect to the counterparties with which such Sub - fund enters into derivatives contracts foreign exchange, currency forward contracts and other transactions such as repurchase agreements or reverse repurcha se agreements. The Sub - fund’s ability to profit from these types of investments and transactions will depend on the willingness and ability of its counterparty to perform its obligations. If a counterparty fails to meet its contractual obligations, the Sub - fund may be unable to terminate or realize any gain on the investment or transaction, resulting in a loss to the Sub - fund. The Sub - fund may experience significant delays and expenses in obtaining any recovery in an insolvency, bankruptcy, or other reorgan ization proceeding involving its counterparty (including recovery of any collateral posted by it) and may obtain only a limited recovery or may obtain no recovery in such circumstances. If the Sub - fund holds collateral posted by its counterparty, it may be delayed or prevented from realizing on the collateral in the event of a bankruptcy or insolvency proceeding relating to the counterparty. Contractual provisions and applicable law may prevent or delay the Sub - fund from exercising its rights to terminate a n investment or transaction with a financial institution experiencing financial difficulties, or to realize on collateral, and another institution may be substituted for that financial institution without the consent of the Sub - fund. If the credit rating o f a derivatives counterparty declines, the Sub - fund may nonetheless choose or be required to keep existing transactions in place with the counterparty, in which event the Sub - fund would be subject to any increased credit risk associated with those transactions.

Under applicable law or contractual provisions, including if a Sub - fund enters into an investment or transaction with a financial institution and such financial institution (or an affiliate of the financial institution) experiences financial difficulties, the Sub - fund may in certain situations be prevented or delayed from exercising its rights to terminate the investment or transaction, or to realise on any collateral and may result in the suspension of payment and delivery obligations of the parties under such investment or transactions or in another institution being substituted for that financial institution without the consent of the Sub - fund. Further, the Sub - fund may be subject to “bail - in” risk under applicable law whereby, if required by the financia l institution’s authority, the financial institution’s liabilities could be written down, eliminated or converted into equity or an alternative instrument of ownership. A bail - in of a financial institution may result in a reduction in value of some or all of its securities and a Sub - fund that holds such securities or has entered into a transaction with such a financial security when a bail - in occurs may also be similarly impacted.

OTC derivatives have similar risks as described above and may also be subject to the risk that a contract will be cancelled, e.g. due to bankruptcy, subsequent illegality or a change in the tax or accounting regulations since the conclusion of the OTC deri vative contract.

5.6 Currency Hedging Risk

The ACS may offer Hedged Unit Classes in a Sub - fund which seek to reduce the impact of exchange rate fluctuations between the currency of the Hedged Unit Class and the currency in which Sub - fund’s underlying assets are denominated.

When a derivative is used as a hedge against a position that a Sub - fund holds, any gain generated by the derivative generally should be substantially offset by losses on the hedged investment, and vice versa. While hedging can reduce or eliminate losses, it can also reduce or eliminate gains. Hedges are sometimes subject to imperfect

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matching between a derivative and its reference asset. While a Sub - fund is designed to hedge against currency fluctuations, it is possible that a degree of currency exposure may remain even at the time a hedging transaction is implemented. As a result, the Sub - fund may not be able to structure its hedging transactions as anticipated or its hedging transactions may not successfully reduce the currency risk included in the Sub - fund's portfolio. The effectiveness of the Sub - fund's currency hedging strategy wil l also generally be affected by the volatility of both the securities included in the Sub - fund, and the volatility of the base currency of the Sub - fund relative to the currencies to be hedged. Increased volatility may reduce the effectiveness of the Sub - fu nd's currency hedging strategy and may impact the costs associated with hedging transactions. The effectiveness of the Sub - fund's currency hedging strategy and the costs associated with hedging transactions may also in general be affected by interest rates . There can be no assurance that the Sub - fund's hedging transactions will be effective. Significant differences between a Sub - fund’s base currency interest rates and foreign currency interest rates may further impact the effectiveness of the Sub - fund's cur rency hedging strategy. The Sub - fund will bear the costs associated with any such hedging transaction, regardless of any gain or loss experienced on the hedging transaction.

Where Classes denominated in different currencies are created within a Sub - fund and currency hedging transactions are entered into to hedge any relevant currency exposure, each such transaction will be clearly attributable to the specific Class and any cos ts shall be for the account of that Class only. It is intended that all gains/losses and expenses arising from such hedging transactions will be borne separately by the Unitholders of the respective Hedged Unit Classes and accordingly, all such gains/losse s and expenses will be reflected in the NAV per Unit of the applicable Hedged Unit Class; however, as there is no segregation of liabilities between Classes of a Sub fund, there is a risk that, under certain circumstances, currency hedging transactions in relation to Hedged Unit Classes of a Sub - fund could ultimately result in liabilities which might affect the Sub - fund as a whole.

As there is no segregation of liabilities between Classes of a Sub - fund, there is a risk that, under certain limited circumstances, the liabilities of a particular Class might affect the NAV of other Classes. In particular, while the Investment Manager wil l seek to ensure that gains/losses on and the costs of the relevant financial derivative instruments associated with any currency hedging strategy used for the benefit of particular Hedged Unit Class will accrue solely to this class and will not be combine d with or offset with that of any other Class, there can be no guarantee that the Investment Manager will be successful in this. In addition, over - hedged or under - hedged positions may arise unintentionally due to factors outside the control of the Investme nt Manager. To the extent that hedging is successful, the performance of the relevant Hedged Unit Class is likely to move in line with the performance of the underlying assets. The use of currency hedging may substantially limit holders of the Hedged Unit Class from benefiting if the Unit currency falls against the base currency of the relevant Sub - fund and/or the currency in which the assets of the Sub - fund are dominated.

There can be no guarantee that the Investment Manager will be successful in such hedging activities and unsuccessful hedging activities may have a material impact on Unitholder’s returns. Recent regulatory changes in a number of jurisdictions require that certain currency transactions be subject to collateral requirements. These changes could increase the costs to a Sub - fund of entering into currency transactions.

5.7 Currency Risk

Investments in issuers in different countries are often denominated in currencies different from a Sub - fund’s base currency. Changes in the values of those currencies relative to the Sub - fund’s base currency may have a positive or negative effect on the va lues of the Sub - fund’s investments denominated in those currencies. The values of other currencies relative to the Sub - fund’s base currency may fluctuate in response to, among other factors, interest rate changes, intervention (or failure to intervene) by national governments, central banks, or supranational entities such as the International Monetary Fund, the imposition of currency or capital controls, and other political or regulatory developments. Currency values can decrease significantly both in the s hort term and over the long term in response to these and other developments.

5.8 Cybersecurity Risk

With the increased use of technologies such as the Internet and the dependence on computer systems to perform business and operational functions, funds (such as the ACS) and its service providers (including the ACS Manager and the Investment Manager) may be prone to operational and information security risks resulting from cyber attacks and/or technological malfunctions. In general, cyber - attacks are deliberate, but unintentional events may have similar effects. Cyber - attacks include, among o thers, stealing or corrupting data maintained online or digitally, preventing legitimate users from accessing information or services on a website, releasing confidential information without authorization, and causing operational disruption. Successful cyb er - attacks against, or security breakdowns of, the ACS, ACS Manager, the Investment Manager or the Depositary, a sub - custodian, Administrator, or other affiliated or third - party service providers may adversely affect the ACS or its Unitholders. For instanc e, cyber - attacks or technical malfunctions may interfere with the processing of Unitholders’ or other transactions, affect a Sub fund’s ability to calculate its Net Asset Value, cause the release of private Unitholder information or confidential

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ACS and/or Sub - fund information, impede trading, cause reputational damage, and subject the ACS to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and additional compliance costs. Cyber - attacks or technical malfu nctions may render records of ACS assets and transactions, Unitholder ownership of ACS Units, and other data integral to the functioning of the ACS and each Sub - fund inaccessible or inaccurate or incomplete. The ACS may also incur substantial costs for cyb ersecurity risk management in order to prevent cyber incidents in the future. The ACS and its Unitholders could be negatively impacted as a result. While the ACS Manager, Investment Manager, Depositary and Administrator have established business continuity plans and systems designed to minimize the risk of cyber - attacks through the use of technology, processes and controls, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified given the evolving nature of this threat. The ACS relies on third - party service providers for many of its day - to - day operations, and will be subject to the risk that the protections and protocols implemented by those service providers will be ineffective to protect the ACS from cyber - attack. Similar types of cybersecurity risks or technical malfunctions also a re present for issuers of securities in which a Sub - fund invests, which could result in material adverse consequences for such issuers, and may cause the Sub - fund’s investment in such securities to lose value.

5.9 Depositary and Custodial Risk

There are risks involved in dealing with the Depositary, sub - custodians or brokers who hold a Sub - fund’s investments or settle a Sub - fund’s trades. The Depositary will hold assets in compliance with applicable laws (including but not limited to the UK UCIT S Requirements and such specific provisions as agreed in the Depositary Services Agreement. Such requirements are designed to safe keep the assets and provide certain protections against losses including losses from the insolvency of the Depositary or any - sub - custodian but there is no guarantee they will successfully do so.

In certain circumstances, it is possible that, in the event of the insolvency or bankruptcy of a sub - custodian or broker, the Sub - fund would be delayed or prevented from recovering its assets from the sub - custodian or broker, or its estate, and may have on ly a general unsecured claim against the sub - custodian or broker for those assets.

5.10 Depositary Receipts Risk

A Sub - fund may invest in American Depositary Receipts (“ADRs”), Global Depositary Receipts (“GDRs”) and European Depositary Receipts (“EDRs”). ADRs are typically trust receipts issued by a U.S. bank or trust company that evidence an indirect interest in underlying securities issued by a foreign entity. GDRs, EDRs, and other types of depositary receipts are t ypically issued by international banks or financial institutions to evidence an interest in underlying securities issued by either a U.S. or a non - U.S. entity. Investments in depositary receipts may be less liquid and more volatile than the underlying secu rities in their primary trading market. If a depositary receipt is denominated in a different currency than its underlying securities, an investing Sub - fund will be subject to the currency risk of both the investment in the depositary receipt and the under lying security. There may be less publicly available information regarding the issuer of the securities underlying a depositary receipt than if those securities were traded directly. Depositary receipts may or may not be sponsored by the issuers of the und erlying securities, and information regarding issuers of securities underlying unsponsored depositary receipts may be more limited than for sponsored depositary receipts. The values of depository receipts may decline for a number of reasons relating to the issuers or sponsors of the depository receipts, including, but not limited to, insolvency of the issuer or sponsor. Holders of depositary receipts may have limited or no rights to take action with respect to the underlying securities or to compel the issu er of the receipts to take action.

5.11 Derivatives Risk

The Sub - funds may use derivative instruments for both efficient portfolio management and for investment purposes. Appendix I will indicate if and how each Sub - fund intends to use derivative instruments. A Sub - fund’s use of derivative instruments involves risks different from, and possibly greater than, the ri sks associated with investing directly in securities.

A derivative is a financial contract the value of which depends on, or is derived from, the value of an underlying asset, interest rate, or index. Derivative transactions typically involve leverage and may have significant volatility. It is possible that a derivative transaction will result in a loss greater than the principal amount invested, and the Sub fund may not be able to close out a derivative transaction at a favourable time or price. Risks associated with derivative instruments include potential changes in value in response to interest rate changes or other market developments or as a result of the counterparty’s credit quality; the potential for the derivative transaction not to have the effect the Investment Manager anticipated or a different or less favourable effect than the Investment Manager anticipated; the f ailure of the counterparty to the derivative transaction to perform its obligations under the transaction or to settle a trade; possible mispricing or improper valuation of the derivative instrument; imperfect correlation in the value of a derivative with the asset, currency, rate, or index underlying the derivative;

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the risk that the Sub - fund may be required to post collateral or margin with its counterparty, and will not be able to recover the collateral or margin in the event of the counterparty’s insolvency or bankruptcy; the risk that the Sub fund will experience losses on its derivatives investments and on its other portfolio investments, even when the derivatives investments may be intended in part or entirely to hedge those portfolio investments; the risks specific to the asset underlying the derivative instrum ent; lack of liquidity for the derivative instrument, including without limitation absence of a secondary trading market; the potential for reduced returns to the Sub - fund due to losses on the transaction and an increase in volatility; the potential for th e derivative transaction to have the effect of accelerating the recognition of gain; and legal risks arising from the documentation relating to the derivative transaction.

5.12 Effect of Initial, Conversion or Switching

Charge Risk Where an initial, Conversion or Switching charge is imposed, an investor who realises his Units may not (even in the absence of a fall in the value of the relevant investments) realise the amount originally invested. The Units therefore should be viewed as medium to long - term investments.

5.13 EMIR and OTC Derivatives contract risk

As a result of the European regulation commonly referred to as the European Market Infrastructure Regulation or “EMIR”, including as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of the European Union (Withdrawal) A ct 2018, over the counter (OTC) Derivatives markets have been and will be subject to significant regulation, potentially including, without limitation, increased margin requirements, mandatory reporting, centralised clearing and execution of transactions. These regulations may result in increased costs, reduced profit margins and reduced investment opportunities, all of which may negatively impact the performance of the Sub - funds.

EMIR imposes certain requirements to collateralise derivative transactions that are not cleared through a clearing house or traded on an exchange, including FX forward transactions and certain OTC Derivatives. As a result, collateral may need to be exchanged between a Sub - fund and trading counterparties t o cover daily mark - to - market exposures of either party under an FX forward transaction and certain OTC derivatives. This may necessitate the amendment of the Sub - fund’s existing OTC derivative contracts which would result in additional costs. The variation margin rules will also require certain haircuts to be applied to collateral received for OTC derivative contracts, which will vary depending on the issuer, credit rating, currency and residual maturity of the collateral. As the variation margin r ules are likely to result in an increase in the level of its assets which a Sub - fund will be required to retain in cash or very liquid assets in order to have available for use as collateral, this could result in a reduced proportion of the Sub - fund’s asse ts being available for allocation to the Sub - fund’s investment policy and, consequently, an increase in the potential Tracking Error for the Sub - fund.

While some of the obligations under EMIR have come into force, a number of the requirements are subject to phase - in periods. As a consequence, it is as yet unclear how the derivatives markets will adapt to the new regulatory regime. Accordingly, it is diff icult to predict the full impact of EMIR on the ACS, although this may include an increase in the overall costs of entering into and maintaining OTC derivative contracts.

5.14 Equity Investing Risk

The market prices of equity securities owned by the Sub - fund may go up or down, sometimes rapidly or unpredictably. The value of a security may decline for a number of reasons that may directly relate to the issuer, such as management performance, financia l leverage, non - compliance with regulatory requirements, and reduced demand for the issuer’s goods or services. The values of equity securities also may decline due to general industry or market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates, or adverse investor sentiment generally. In addition, equity markets tend to move in cycles, which may cause stock prices to fall over short or extended periods of time. A Sub - fund may continue to accept new subscriptions and to make additional investments in equity securities even under general market conditions that the Investment Manager views as un favourable for equity securities.

5.15 Errors, Error Correction Policies and Unitholder Notification

The ACS Manager , in consultation with the Depositary, will consider any breaches of investment objective, policies or restrictions and any errors in the calculation of the NAV of the Sub - funds or the processing of subscriptions and redemptions in order to determine whether corrective action is necessary or compensation is payable to the ACS or the Unitholders.

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The ACS Manager, may, in consultation with the Depositary, authorise the correction of errors, which may impact the processing of subscriptions for and redemptions of Units. The ACS Manager and Depositary may follow materiality policies with respect to the resolution of errors that may limit or restrict when corrective action would be taken or when compensation to the ACS or Unitholders will be paid. In addition, subject to policies approved by the ACS Manager and Depositary consistent with applicable law, not all mistakes will result in compensatable errors. Accordingly, Unitholders who purchase or redeem Units during periods in which compensatable errors or other mistakes accrue or occur may not be recompensed in connection with the resolution of a compens atable error or other mistake.

Unitholders may not be notified of the occurrence of any error or the resolution thereof unless the correction of the error requires an adjustment to the number of Units they hold or NAV at which such Units were issued, or to the redemption monies paid to such Unitholder.

5.16 ESG Criteria in Index Methodology Risk

If a Sub - fund is managed against an index that incorporates any environmental, social and governance (ESG) criteria in the methodology for determining the index constituents (a “Reference Index”), this may cause the Sub fund to make different investments to funds that are not managed against such an index. A Sub - fund that is managed against a Reference Index m ay forgo higher returning investments as a result of the application of the relevant ESG criteria in determining the index constituents. A Sub‐Fund which is managed against a Reference Index may invest in companies that do not reflect the beliefs and value s of any particular investor. ESG screens and standards are a developing area and the ESG screens applied by the index provider may evolve and change over time.

5.17 Frequent Trading/Portfolio Turnover Risk

A Sub - Fund may engage in active and frequent trading of its portfolio securities. Sub - Fund turnover generally involves a number of direct and indirect costs and expenses to the Sub - Fund, including, for example, brokerage dealing commissions, dealer mark - up s and bid/asked spreads, and transaction costs on the sale of securities and reinvestment in other securities. The costs related to increased portfolio turnover have the effect of reducing the Sub - Fund’s investment return and the sale of securities by a Su b - Fund may result in the realisation of taxable capital gains, including short term capital gains. Frequent trading can also result in increased tax liability for the trading Sub - Fund.

5.18 Inflation Risk

Inflation risk is the risk that the value of assets or income from investments will be less in the future as inflation decreases the value of money. As inflation increases, the values of a Sub - Fund’s assets can decline

5.19 Index Licensing Risk

It is possible that the license under which the Investment Manager or the applicable Sub - Fund is permitted to replicate or otherwise use an index will be terminated or may be disputed, impaired or cease to remain in effect. In such a case, the Investment M anager may be required to replace the index with another index which it considers to be appropriate in light of the investment strategy of the applicable Sub - Fund. The use of and/or transition to any such substitute index may have an adverse impact on such Sub - Fund’s performance. In the event that the Investment Manager is unable to identify a suitable replacement for the relevant index, the Sub - Fund may be closed.

5.20 Index Error Risk

If a Sub - Fund has the investment objective to seek to track the performance of index as published by the relevant index provider, there is a risk that the index provider will not compile or calculate the index accurately. Although the index provider provides descriptions of what the index is designed to achieve, the index provider does not provide any warranty or accept any liability in relation to any error relat ing to the index, including any error in respect of the quality, accuracy or completeness of index data, and does not guarantee that the index will be in line with the described index methodology. The ACS Manager does not provide any warranty or guarantee for index provider errors and does not have any responsibility for the identification or correction of such errors. Errors in respect of the quality, accuracy and/or completeness of index data may occur from time to time and may not be identified and corre cted for a period of time. Gains, losses or costs associated with index provider errors will be borne by the Sub - Fund and its investors. For example, during a period where the index contains incorrect constituents, a Sub - Fund tracking such published index would have market exposure to such constituents and would be underexposed to the constituents that should have been included in the index. Therefore, such errors

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may result in a negative or positive performance impact to the Sub - Fund and its investors. Any gains from index provider errors affecting the Sub - Fund will be kept by the Sub - Fund and its investors and any losses resulting from such index provider errors w ill be borne by the Sub - Fund and its investors.

5.21 Index Tracking Risk

The investment objective of certain Sub - Funds will be to track the performance of a specified index. While the Investment Manager seeks to track the performance of the index (i.e., achieve a high degree of correlation with the index), a Sub - Fund’s return m ay not match the return of the specified index for a number of reasons. For example, the return on the sample of securities purchased by the Sub - Fund) to replicate the performance of the index may not correlate precisely with the return of the index. The S ub - Fund incurs a number of operating expenses not applicable to the index, and incurs costs in buying and selling securities. In addition, the Sub - Fund may not be fully invested at times, either as a result of cash flows into or out of the Sub - Fund or rese rves of cash held by the Sub Fund to meet redemptions. Changes in the composition of the index and regulatory requirements also may impact the Sub - Fund’s ability to match the return of the specified index. The Investment Manager may apply one or more “scr eens” or investment techniques to refine or limit the number or types of issuers included in the index in which the Sub - Fund may invest. Application of such screens or techniques may result in investment performance below that of the index and may not prod uce results expected by the Investment Manager. Index tracking risk may be heightened during times of increased market volatility or other unusual market conditions.

5.22 Index Risk/Passive Strategy

Certain Sub - Funds are managed with an indexed investment strategy, attempting to track the performance of an unmanaged index of securities. Such Sub - Fund will seek to replicate index returns regardless of the current or projected performance of the index o r of the actual securities comprising the index. The Sub - Fund generally will buy and will not sell a security included in the index as long as the security is part of the index regardless of any sudden or material decline in value or foreseeable material d ecline in value of the security, even though the Investment Manager may make a different investment decision for other managed accounts or portfolios that hold the security. As a result, an index managed Sub - Fund’s performance may be less favourable than t hat of a portfolio managed using an active investment strategy. The structure and composition of the index will affect the performance, volatility and risk of the Index (in absolute terms and by comparison with other indices) and, consequently, the perform ance, volatility and risk of the relevant Sub - Fund. Such Sub - Fund’s performance may not match that of the index. This differs from an actively - managed fund, which typically seeks to outperform an Index.

5.23 Index Risk

It is possible that an index referenced by the Investment Manager in relation to any Sub - fund or underlying asset will be terminated or may be disputed, impaired or cease to remain in effect. In such a case, the Investment Manager may be required to replace the referenced index with another index which it considers to be appropriate in light of the in vestment strategy of the applicable Sub - fund and the purpose of such referencing. The transition to any such substitute index may be effected over a period of time, during which the Sub - fund will not fully track the old or new index. The use of and/or tran sition to any such substitute index may generate additional costs for the Sub - fund and/or have an adverse impact on such Sub - fund’s performance. In the event that the Investment Manager is unable to identify a suitable replacement for the relevant index, t he Sub -- fundmay be closed.

5.24 Investments in Multiple Countries Risk

Investments in securities of companies from multiple countries and/or securities of companies with significant exposure to multiple countries, and exposure to various currencies can involve additional risks relating to market, economic, political, or regul atory conditions and developments as well as additional costs. Political, social, and economic instability, the imposition of currency or capital controls, or the expropriation or nationalisation of assets in a particular country can cause dramatic decline s in that country’s economy and affect a Sub - Fund’s investments exposed to such country. Investing in multiple countries creates operational risks due to different systems, procedures and requirements in a particular country, different accounting, auditing , financial reporting, legal standards and practices and varying laws regarding withholding and other taxes. Enforcing legal rights can be difficult, costly, and slow in some countries, and can be particularly difficult against governments. Additional risks of investing in various countries include trading, settlement, custodial, and other operational risks, and withholding and other taxes. These factors can make investments in multiple countries, especially those in emerging markets, more volatile and less liquid than investments in a single country. In addition, markets in various countries can each react differently to market, economic, political, or regulatory developments.

Markets in different countries have different clearance and settlement procedures and in certain markets there have been times when settlements have been unable to keep pace with the volume of transactions. Delays in settlement may increase credit risk to a Sub - Fund, limit the ability of the Sub - Fund to reinvest the proceeds of a sale of securities,

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hinder the ability of the Sub - Fund to lend its portfolio securities and potentially subject the Sub - Fund to penalties for its failure to deliver to on - purchasers of securities whose delivery to the Sub - Fund was delayed. Delays in the settlement of securities purchased by the Sub - Fund may limit the ability of the Sub - Fund to sell those securities at times and prices it considers desirable and may subject the Sub - Fund to losses and costs due to its own inability to settle with subsequent purchasers of the securities from it. The Sub - Fund may be required to borrow monies it had otherwise expected to receive in connection with the settlement of securities sold by it, in order to meet its obligations to ot hers. Limits on the ability of the Sub - Fund to purchase or sell securities due to settlement delays could increase any variance between the Sub - Fund’s performance and that of its index.

In some countries transaction costs such as brokerage commissions and custody costs may be high.

A Sub - Fund invested in multiple countries will be exposed to such risks in more than one country.

5.25 Investment in Other Undertakings in Collective Investments (UCIs) Risk

When a Sub - fund invests in another UCI, it is exposed to the risk that such UCI will not perform as expected. The Sub - fund is exposed indirectly to all of the risks applicable to an investment in such UCI. In addition, lack of liquidity in the underlying U CI could result in its value being more volatile than the underlying portfolio of securities, and may limit the ability of the Sub - fund to sell or redeem its interest in the UCI at a time or at a price it might consider desirable and the Sub - fund may achie ve a reduced investment return. The investment policies and limitations of the other UCI may not be the same as those of the Sub - fund; as a result, the Sub - fund may be subject to additional or different risks, or may achieve a reduced investment return, as a result of its investment in such UCI.

If a UCI is an exchange - traded fund or other product traded on a securities exchange or otherwise actively traded, its shares may trade at a premium or discount to their net asset value, an effect that might be more pronounced in less liquid markets. The S ub - fund bears its proportionate share of the fees and expenses of any UCI in which it invests. The Investment Manager or an affiliate may serve as investment adviser to a UCI in which the Sub - fund may invest, leading to potential conflicts of interest. For example, the Investment Manager or its affiliates may receive fees based on the amount of assets invested in the UCI. Investment by the Sub - fund in the UCI may be beneficial to the Investment Manager or an affiliate in the management of the UCI, by helpin g to achieve economies of scale or enhancing cash flows. Due to this and other factors, the Investment Manager may have an incentive to invest the Sub - fund’s assets in a UCI sponsored or managed by the Investment Manager or its affiliates in lieu of invest ments by the Sub - fund directly in portfolio securities, or may have an incentive to invest in such UCI over a different UCI sponsored or managed by others. Similarly, the Investment Manager may have an incentive to delay or decide against the sale of inter ests held by the Sub - fund in a UCI sponsored or managed by the Investment Manager or its affiliates. It is possible that other clients of the Investment Manager or its affiliates will purchase or sell interests in a UCI sponsored or managed by the Investme nt Manager or its affiliates at prices and at times more favourable than those at which the Sub - fund does so.

5.26 Investment Style Risk – Large Cap Companies

Securities issued by large - capitalization companies may present risks not present in smaller companies. For example, larger companies may be unable to respond as quickly as smaller and mid - sized companies to competitive challenges or to changes in business, product, financial, or other market conditions. Larger companies may not be able to maintain growth at the high rates that may be achieved by well - managed smaller and mid - sized companies, especially during strong economic periods. Returns on investments in securities of large companies could trail the returns on investments in securities of smaller and mid - siz ed companies.

5.27 Investment Style Risk – Small, Mid and Micro – Cap Companies

The securities of small - , mid - and micro - capitalization companies may be more volatile and may involve more risk than the securities of larger companies. These companies may have limited product lines, markets or financial resources, may lack the competiti ve strength of larger companies, and may depend on a few key employees. These companies, particularly micro - capitalisation companies, may be in the early stages of development of product lines. In addition, these companies may have been recently organized and may have little or no track record of success. The securities of smaller companies may trade less frequently and in smaller volumes than more widely held securities. The prices of the se securities may fluctuate more sharply than those of other securities, and a Sub - fund may experience some difficulty in establishing or closing out positions in these securities at prevailing market prices. There may be less public ly available information about the issuers of these securities or less market interest in these securities than in the case of larger companies, both of which can cause significant price volatility. Some securities of smaller issuers may be illiquid or may be restricted as to resale. The Sub - fund may be unable to liquidate its positions in such securities at any time, or at a favourable price, in order to meet a Sub - fund’s obligations. Returns on investments in securities of small - or micro - capitalization c ompanies could trail the returns on investments in securities of larger companies.

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5.28 Investment Risk

Investment risk includes the possible loss of the entire amount of capital that a Unitholder invests. The value of securities and other investments held by a Sub - fund may increase or decrease, at times rapidly and unexpectedly. Unitholders investments in a Sub - fund may at any point in the future be worth less than their original investments. Accordingly, it is important that Unitholders periodically evaluate their investments in a Sub - fund.

5.29 IPO Risk Factor

A Sub - Fund may at times have the opportunity to invest in securities offered in initial public offerings (“IPOs”). IPOs involve companies that have no public operating history and therefore entail more risk than established public companies. The prices of securities offered in IPOs can have significant volatility and a Sub - Fund may lose money on an investment in such securities. IPOs may not be available to the Sub - Funds at all times and a Sub - Fund may not always invest in IPOs offered to it. Investments in IPOs may have a substantial beneficial effect on a Sub - Fund’s investment performance. A Sub - Fund’s investment return earned during a period of substantial investment in IPOs may not be sustained during other periods when the Sub - Fund makes more - limited, o r no investments in IPOs. There can be no assurance that the Sub - Funds will have the opportunity to invest in IPOs that are made available to other clients of the Investment Manager.

5.30 Issuer Risk

The value of securities may decline for a number of reasons which directly relate to the issuers, such as, for example, management performance, financial leverage, and reduced demand for the issuer’s goods and services as well as the historical and prospective earnings of the issuer and the value of its assets.

5.31 Large Unitholder Risk

To the extent a large proportion of the Units of a Sub - fund are held by a small number of Unitholders (or a single Unitholder), including funds or accounts over which the Investment Manager has investment discretion, a Sub - fund is subject to the risk that these Unitholders will purchase or redeem their Units in large amounts rapidly or unexpectedly, including as a result of an asset allocation decision made by the Investment Manager. These transactions could adversely affect the ability of a Sub - fund to con duct its investment program and may result in the impositions of redemption fees, suspensions and gates.

5.32 Law or Regulation Risk

A Sub - fund will be affected by law or regulations that are applicable to that Sub - fund. Applicable law and regulations may increase the costs and expenses of the Sub - fund, or result in certain investment techniques or investments being prohibited, which ma y adversely affect the Sub - fund’s performance.

5.33 Leveraging Risk

Certain transactions, including, for example, borrowing transactions, reverse repurchase agreements, certain derivatives transactions, securities lending transactions and other investment transactions, such as when - issued, delayed - delivery, or forward comm itment transactions, may create investment leverage. When a Sub - fund engages in transactions that have a leveraging effect on the Sub - fund’s investment portfolio, the value of the Sub - fund will be potentially more volatile and all other risks will tend to be compounded. This is because leverage generally creates investment risk with respect to a larger base of assets than the Sub - fund would otherwise have and so magnifies the effect of any increase or decrease in the value of the Sub - fund’s underlying asset s. The use of leverage is considered to be a speculative investment practice and may result in losses to the Sub - fund. In transactions involving leverage, a relatively small market movement or change in other underlying indicator can lead to significantly larger losses to the Sub - fund. Certain derivatives have the potential for unlimited loss, regardless of the size of the initial investment. The use of leverage may cause the Sub - fund to liquidate positions when it may not be advantageous to do so to satisf y repayment, interest payment, or margin obligations or to meet asset segregation or coverage requirements.

5.34 Limited Investment Program Risk

An investment in any Sub - fund, or even in a combination of Sub - funds, is not intended to be a complete investment program, but rather is intended for investment as part of a diversified investment portfolio. Prospective Investors and Unitholders should con sult their own advisors as to the role of an investment in any of the Sub - funds in their overall investment program.

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5.35 Liquidity Risk

Liquidity risk is the risk that a Sub - fund may not be able to acquire or dispose of securities or close out derivatives transactions readily at a favourable time or prices (or at all) or at prices approximating those at which the Sub - fund currently values them. In large - scale transactions or when markets are partially illiquid (e.g. where there are numerous individually agreed instruments) it may not be possible to execute a transaction or close out a position at an advantageous price.

Illiquid securities that may be held in accordance with applicable law (“Permitted Illiquid Securities”) may be subject to restrictions on resale, may trade in the over - the - counter market or in limited volume, or may not have an active trading market. In a ddition, Permitted Illiquid Securities may trade at a discount from comparable, more liquid investments and may be subject to wide fluctuations in market value. It may be difficult for a Sub - fund to value Permitted Illiquid Securities accurately. The marke t for certain investments held by a Sub - fund may become illiquid under adverse market or economic conditions independent of any specific adverse changes in the conditions of a particular issuer. Disposal of Permitted Illiquid Securities may entail registra tion expenses and other transaction costs that are higher than those for liquid securities. To the extent permitted under applicable, law, a Sub - fund may seek to borrow money to meet its obligations (including among other things redemption obligations) if it is unable to dispose of Permitted Illiquid Investments, resulting in borrowing expenses and possible leveraging of the Sub fund.

A Sub - fund may hold securities which, while still compliant with the UK UCITS Requirements may be subject to restrictions on resale, may trade in the over - the - counter market or in limited volume, or may not have an active trading market (“Less Liquid Securities”). In addition, Less Liquid Securities may trade at a discount from comparable, more liquid investments and may be subject to wide fluctuations in market value. It may be difficult for a Sub - fund to value Less Liquid Securities accurately. The market for certain investments held by a Sub - fund may become illiquid under adverse market or economic conditions independent of any specific adverse changes in the conditions of a particular i ssuer. Disposal of Less Liquid Securities may entail registration expenses and other transaction costs that are higher than those for liquid securities.

From time to time, the counterparties with which a Sub - fund effects transactions might cease making markets or quoting prices in certain of the instruments in which a Sub - fund has invested. In such instances, a Sub - fund might be unable to enter into a desi red transaction or to enter into any offsetting transaction with respect to an open position, which might adversely affect its performance.

The ACS Manager employs an appropriate liquidity risk management process, which takes into account repurchase or reverse repurchase transactions employed by the Sub - funds, in order to ensure that each Sub - fund is able to comply with its stated redemption o bligations. However, it is possible that in the type of circumstances described above, a Sub - fund may not be able to realise sufficient assets to meet all redemption requests that it receives or the ACS Manager may determine that the circumstances are such that meeting some or all of such requests is not in the best interests of the Unitholders in a Sub - fund as a whole. In such circumstances, the ACS Manager may take the decision to apply the deferred redemption provisions described in the “ Deferred Redemption ” sections of this Prospectus or suspend dealings in the relevant Sub - fund as described in the “ Suspension of dealings in the ACS or a Sub - fund ”” section of this Prospectus.

5.36 Liquidity, Settlement and Derivatives Risks

A Sub - fund may be exposed to credit risk on parties with whom it trades and may also bear the risk of settlement default. For example, although the seller under a repurchase agreement will be required to maintain the value of the securities subject to the agreement in an amount exceeding the repurchase price, default by the seller would expose a Sub - fund to possible loss due to adverse market action or delay in connection with the disposal of the underlying obligations.

Derivatives are subject to a number of risks, such as potential changes in value in response to interest rate changes or other market developments or as a result of the counterparty’s credit quality and the risk that a derivative transaction may not have the effect the Investment Manager anticipated. Derivatives also involve the risk of mispricing or improper valuation and the risk that changes in the value of a derivative may not correlate perfectly with the asset, rate , or index underlying the derivative. Derivative transactions can create investment leverage and may be highly volatile. Use of derivatives other than for hedging purposes may be considered speculative.

When the Sub - funds invest in a derivative instrument, it could lose more than the principal amount invested. Further, when a Sub - fund invests in a derivative instrument, it generally is not required to post collateral equal to the amount of the notional va lue of the derivative instrument. Consequently, the cash held by the Sub - fund (generally equal to the unfunded amount of the derivative) will typically be invested in money market instruments.

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It is possible that returns on the investment of this cash may have a negative impact on the performance and/or returns of the Sub - fund.

Many derivative transactions are entered into “over the counter” (not on an exchange or contract market); as a result, the value of such a derivative transaction will depend on the ability and the willingness of the Sub - funds’ counterparty to perform its o bligations under the transaction. A liquid secondary market may not always exist for the Sub - funds’ derivative positions at any time. Use of derivatives may increase the amount and timing of taxes payable by shareholders. There is no guarantee that investm ents in derivative instruments will work as intended. Derivatives are subject to a number of risks such as described in the risk warnings headed “ Market Risk ” and “ Counterparty Risk ”.

5.37 Management Risk

Each Sub - fund is subject to a degree of management risk. The Investment Manager’s judgments about the implementation of a strategy or the attractiveness, relative value or potential appreciation of a particular sector, security or investment strategy or he dging strategy may prove incorrect and may cause such Sub - fund to incur losses. There can be no assurance that the Investment Manager’s investment techniques and decisions will produce the desired results.

Derivatives and other special investment techniques and financial instruments are specialized products which require different investment techniques and risk analyses than equities or bonds. The use of derivatives requires not only knowledge of the underly ing instruments, but also of the derivative itself, although the performance of the derivative cannot be monitored under all the possible market conditions. The complexity of such products and their use in particular requires suitable control mechanisms to monitor the transactions and have the ability to assess the risks of such products for a Sub - fund and estimate the developments of prices, interest rates and exchange rates.

5.38 Market Disruption and Geopolitical Risk

Each Sub - fund is subject to the risk that geopolitical events will disrupt securities markets and adversely affect global economies and markets. War, terrorism, the spread of infectious illness or other public health issues, and related geopolitical events have led, and in the future may lead, to increased short - term market volatility and may have adve rse long - term effects on global economies and markets generally. Likewise, natural and environmental disasters and systemic market dislocations may be highly disruptive to economies and markets. Those events as well as other changes in economic and politic al conditions also could adversely affect individual issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation, investor sentiment, and other factors affecting the value of a Sub - fund’s investments.

Given the increasing interdependence among global economies and markets, conditions in one country, market, or region might adversely affect markets, issuers, and/or foreign exchange rates in other countries, including the countries in which the Sub - fund i nvests. Any partial or complete dissolution of the European Union or the European Monetary Union due to the withdrawal of one or more member states or any increased uncertainty as to each of their status, could have significant adverse effects on currency and financial markets, and on the values of a Sub - fund’s investments.

Securities and financial markets may be susceptible to market manipulation or other fraudulent trade practices, which could disrupt the orderly functioning of these markets or adversely affect the values of investments traded in these markets, including in vestments held by the Company.

To the extent a Sub - fund has focused its investments in the market or index of a particular region, adverse geopolitical and other events could have a disproportionate impact on the Sub - fund.

5.39 Market Risk

Market prices of investments held by a Sub - fund may increase or decrease, at times rapidly or unpredictably. A Sub fund’s investments are subject to changes in general economic conditions, general market fluctuations and the risks inherent in investment i n international securities markets. Investment markets can be volatile and prices of investments can change substantially due to various factors including, but not limited to, economic growth or recession, changes in interest rates, changes in actual or pe rceived creditworthiness of issuers and general market liquidity or adverse investor sentiment generally. Even if general economic conditions do not change, the value of an investment in the Sub - fund could decline and be worth less than your original inves tment if the particular industries, sectors or companies in which the Sub - fund invests do not perform well or are adversely affected by events. Further, legal, political, regulatory and tax changes also may cause fluctuations in markets and securities pric es. Local, regional or global events such as war, acts of terrorism, the spread of infectious illness or other public health issues, or other events could have a significant impact on a Sub - fund and its investments. An outbreak of a

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respiratory disease caused by a novel coronavirus (known as COVID - 19) first detected in China in December 2019 has resulted in a global pandemic and major disruptions to economies and markets around the world. Financial markets have experienced extreme vol atility and severe losses, and trading in many instruments has been disrupted. Liquidity for many instruments has been greatly reduced for periods of time. Some interest rates are very low and in some cases yields are negative. Governments and central bank s, , have taken extraordinary and unprecedented actions to support local and global economies and the financial markets. The impact of these measures, and whether they will be effective to mitigate the economic and market disruption, will not be known for some time. In addition, the outbreak of COVID - 19, and measures taken to mitigate its effects, could result in disruptions to the services provided to Sub - fund by its service providers.

The magnitude of these price fluctuations will be greater when the maturity of the outstanding securities is longer. Since a Sub - fund may make investments in currencies other than its base currency, the value of a Sub - fund’s assets may also be affected by changes in currency rates and imposition of currency or capital controls.

5.40 OTC Clearing Risk

Certain derivatives transactions entered into by a Sub - fund will be required to be centrally cleared. In a cleared derivatives transaction, a Sub - fund’s counterparty to the transaction is a central derivatives clearing organisation or clearing house rather than a bank or dealer. A Sub - fund will typically clear derivatives transactions through clearing members that are futures commission merchants and members of the clearing houses. A Sub - fund will make and receive payments owed under cleared derivatives tra nsactions (including margin payments) through its accounts at clearing members. A Sub - fund’s clearing members guarantee a Sub - fund’s performance of its obligations to the clearing house. In contrast to bilateral derivatives transactions, clearing members c an generally require termination of existing cleared derivatives transactions at any time or increase the amount of margin required to be provided by a Sub - fund to the clearing member for any new or existing cleared derivatives transaction above the amount of margin required by the clearing house or clearing member. Any such termination or increase could result in losses to a Sub - fund on its cleared derivatives position. Also, a Sub - fund is subject to execution risk in respect of cleared derivatives transac tions, because it is possible that no clearing member will be willing to clear a particular transaction on a Sub - fund’s behalf. In that case, the transaction might have to be terminated and a Sub - fund could lose some or all of the benefit of any increase i n the value of the transaction after the time of the trade. In addition, the documentation governing the relationship between a Sub - fund and a clearing member that is drafted by the clearing members is generally not negotiable and therefore less favourable to a Sub - fund than typical bilateral derivatives documentation. These and other new rules and regulations could, among other things, restrict a Sub fund’s ability to engage in or increase the cost to a Sub - fund of derivatives transactions and could make the use of derivatives by a Sub - fund impractical or generally undesirable. These regulations are new and evolving so their potential impact on a Sub - fund and the financial system are not yet known. While the new regulations and central clearing of some der ivatives transactions are designed to reduce systemic risk, there is no assurance that the new clearing mechanisms will achieve that result and in the meantime, as noted above, central clearing exposes Sub funds to new kinds of risks and costs.

5.41 Preferred Securities Risk

Generally, preferred security holders have no or limited voting rights with respect to the issuer. In addition, preferred securities are subordinated to bonds and other debt instruments in an issuer’s capital structure and therefore will be subject to grea ter credit risk than those debt instruments. Unlike debt securities, dividend payments on a preferred security typically must be declared by the issuer’s board of directors. An issuer’s board of directors is generally not under any obligation to pay a dividend (even if such dividends have accrued) and may suspend payment of dividend s on preferred securities at any time. Therefore, in the event an issuer of preferred securities experiences economic difficulties, the issuer’s preferred securities may lose substantial value due to the reduced likelihood that the issuer’s board of direct ors will declare a dividend and the fact that the preferred security may be subordinated to other securities of the same issuer. Further, because many preferred securities pay dividends at a fixed rate, their market price can be sensitive to changes in interest rates in a manner similar to bonds — that is, as interes t rates rise, the value of the preferred securities held by a Sub - fund are likely to decline. Therefore, to the extent that a Sub - fund invests a substantial portion of its assets in fixed rate preferred securities, rising interest rates may cause the value of the Sub - fund’s investments to decline significantly. In addition, because many preferred s ecurities allow holders to convert the preferred securities into common stock of the issuer, their market price can be sensitive to changes in the value of the issuer’s common stock and, therefore, declining common stock values may also cause the value of the Sub - fund’s investments to decline. Preferred securities often have call features which allow the issuer to redeem the security at its discretion. The redemption of a preferred security, having a higher than average yield, may cause a decrease in a Sub - fund’s yield.

The value of a preferred security held by a Sub - fund may decline due to a number of factors affecting or perceived to affect the issuer of the security, such as, for example, management performance, financial leverage and reduced demand for the issuer’s go ods or services as well as the historical and prospective earnings of the issuer and the

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value of its assets. In addition, there may be political changes that impact the ability of issuers to repay principal and to make interest payments on securities. Changes to the financial condition or credit rating of issuers may also adversely affect the value of the securities issued.

5.42 Provisional Allotment Risk

As the ACS Manager may provisionally allot Units to proposed investors prior to receipt of the requisite subscription monies for those Units, a Sub - fund] may suffer losses as a result of the non - payment of such subscription monies.

5.43 Proxy Voting Program Risk

Investors in certain Sub - funds may, from time to time, enter into arrangements with the ACS Manager pursuant to which such investors have the ability to select a proxy voting policy that will apply in relation to a pro - rata proportion of the shares (that a re available for voting) held by the applicable Sub - fund(s) in which they invest. Such investors owe no fiduciary duty to the Sub - funds. An investor’s choice of voting policy and the voting of shares in accordance with such policy may not reflect, and may in fact conflict with, the concerns and values of one or more other investors in the Sub - funds.

To the extent that shares held by a Sub - fund are voted pursuant to such a proxy voting program there is the risk that such shares may be voted in a way that is different to how other equivalent shares held by the Sub - fund are being voted.

The availability of the proxy voting program is subject to any applicable regulatory, operational (including in respect of fractional voting rights), local market (including any applicable local restrictions on split voting), tax, cost or other constraints of the third party proxy voting or State Street Global Advisors.

No warranty or acceptance of any liability is provided by the ACS Manager, Investment Manager, the third party proxy voting administrator or any other party in relation to the implementation of the proxy voting program, and no guarantee is provided that vo ting will be in line with the proxy voting program.

There is also the risk that the third party proxy voting administrator’s interpretation of how a voting policy should be applied in respect of a vote may be different to an Investor’s interpretation as to how the policy should be interpreted in respect of that vote.

Depending on the Investor’s corporate structure, there is the risk that, pursuant to the proxy voting program, shares may be voted of a company which is in the Investor’s group of companies.

The ACS Manager reserves the right to suspend or cancel, in full or in part, the proxy voting program (in any one instance or more broadly), including with immediate effect, if required by applicable law or regulation or if the ACS Manager otherwise considers that this is appropriate. This may result in shares being voted in accordance with the ACS’ proxy voting policy rather than in accordance with the proxy voting program.

5.44 REIT Risk

In addition to the risks associated with investing in the securities of real property companies, REITs are subject to certain additional risks. REITs may be affected by changes in the values of the underlying properties that they own or operate. Further, R EITs are dependent upon specialised management skills, and their investments may be concentrated in relatively few properties, or in a small geographic area or a single property type. REITs are also subject to heavy cash flow dependency and, as a result, a re particularly reliant on the proper functioning of capital markets, as well as defaults by borrowers and self - liquidation. A variety of economic and other factors may adversely affect a lessee’s ability to meet its obligations to a REIT. In the event of a default by a lessee, the REIT may experience delays in enforcing its rights as a lessor and may incur substantial costs associated in protecting its investments. REITs are also subject to heavy cash flow dependency and, as a result, are particularly reliant on capital markets. Investments in REITs are also subject to the risks affecting equity markets generally.

5.45 Repurchase Agreements Risk

Repurchase agreements may be viewed as loans made by a Sub - fund which are collateralised by the securities subject to repurchase. A Sub - fund’s investment return on such transactions will depend on the counterparty’s willingness and ability to perform its o bligations under a repurchase agreement. If a Sub - fund’s counterparty should default on its obligations and a Sub - fund is delayed or prevented from recovering the collateral or if the value of the collateral is insufficient, a Sub - fund may realise a loss.

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5.46 Risks Related to Screening

Certain Sub - funds use a screen (either within an index or which is applied outside of an index) based on criteria which may include certain sustainability - related or other characteristics of a company or other issuer of securities (for the purposes of this disclosure, each, an “issuer” ). The screen may be fully or partially designed and/or implemented by the index provider, the Investment Manager, an affiliate of the Investment Manager or by another party (each referred to as the “screen provider” ). Any ass essment of the screen criteria by a screen provider is based on data provided by third parties. Such data may be incomplete, inaccurate or unavailable, which could cause incorrect assessment of an issuer’s sustainability or other characteristics. For certa in markets and types of issuer or securities (including, but not limited to, certain government or corporate fixed income securities) there may be significant limitations in the amount of screening data that is available or no screening data may be availab le such that no screening is performed. In certain situations where screening data is not available for an issuer, the screen provider may, as a proxy, use data relating to a different entity to the issuer, which presents a risk this data may not accuratel y reflect the sustainability or other characteristics of the issuer. In certain situations, even where screening data is available it may not be used as part of the screen provider’s screening process. The screens used for a Sub - fund may not be adequate for their intended purpose which could result in the improper inclusion or exclusion of issuers in the investment decision - making process used for the Sub - fund. There is a risk that errors may be made in the screening process. Errors may include, but are not limited to, inclusion of incorrect constituents/exclusion o f correct constituents, incorrect interpretation of issuer characteristics, transcription errors and incorrect assessment and application of the relevant screening criteria. There is an additional risk that a screen provider may amend or discontinue its sc reening services or screening process and that the data sources used by a screen provider may change or be discontinued. These circumstances could result in the improper inclusion or exclusion of issuers in the investment decision - making process used for t he Sub - fund. In general, screening occurs at the level of the issuer rather than at the level of the securities issued by the issuer. Accordingly, there is a risk that the sustainability or other characteristics of the issuer of a security held by the Sub - fund are different to the characteristics of the security. The foregoing risks associated with screens, screening providers and data sources may result in a Sub - fund holding securities that it seeks not to hold or excluding securities it seeks to include w ithin its portfolio, and may limit the ability of the Sub - fund to achieve its investment objective.

5.47 Russia Sanctions Risk

Sanctions threatened or imposed by a number of jurisdictions, including the United States, the European Union and the United Kingdom, and other intergovernmental actions that have been or may be undertaken in the future, against Russia, Russian entities or Russian individuals, may result in the devaluation of Russian currency, a downgrade in the country’s credit rating, an immediate freeze of Russian assets, a decline in the value and liquidity of Russian securities, property or interest, and/or other adverse consequences to the Russian economy or a Sub fund. The scope and scale of sanctions in place at a particular time may be expanded or otherwise modified in a way that have negative effects on a Sub - fund. Sanctions, or the threat of new or modified sanctions, could impair the ability of a Sub - fund to buy, sell, hold, receive, d eliver or otherwise transact in certain affected securities or other investment instruments. Sanctions could also result in Russia taking counter measures or other actions in response, which may further impair the value and liquidity of Russian securities. These sanctions and the resulting disruption of the Russian economy, may cause volatility in other regional and global markets and may negatively impact the performance of various sectors and industries, as well as companies in other countries, which coul d have a negative effect on the performance of a Sub - fund, even if a Sub - fund does not have direct exposure to securities of Russian issuers. As a collective result of the imposition of sanctions, Russian government countermeasures and the impact that they have had on the trading markets for Russian securities, certain Sub funds have used, and may in the future use fair valuation procedures approved by the Sub - fund’s Board to value certain Russian securities, which could result in such securities being dee med to have a zero value.

5.48 Securities Lending Risk

A Sub - fund may participate in a securities lending program sponsored by an affiliate of the Investment Manager for the purpose of lending the Sub - fund’s securities.

If a Sub - fund engages in securities lending, there is a risk that the borrower may become insolvent or otherwise become unable to meet or refuse to honour its obligations to return equivalent securities to the loaned securities. In this event, the Sub - fund could experience delays in recovering the securities and may incur a capital loss. There is the risk that, when lending portfolio securities, the securities may not be available to the Sub - fund on a timely basis and the Sub - fund may, therefore, lose the o pportunity to sell the securities at a desirable price.

If a counterparty defaults and fails to return equivalent securities to those loaned, the Sub - fund may suffer a loss equal to the shortfall between the value of the realised collateral and the market value of the replacement securities. To the extent that any securities lending is not fully collateralised (for example, due to timing lags associated with the posting of collateral), the Sub - fund will have a credit risk exposure to the counterparty of a

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securities lending contract. Prospective investors and Unitholders should also read the risk warning headed “ Counterparty Risk ” in the “ Risk Information ” section. The Sub - fund could also lose money if the value of collateral falls. These events could trigger adverse tax consequences for the Sub - fund.

5.49 Settlement Time Misalignment Risk

In certain countries, the settlement time for securities in which a Sub - fund invests may be shorter than the settlement time applicable for subscriptions and redemptions when an Unitholder subscribes into or redeems from the Sub - fund. The ACS Manager may agree with the trading counterparty to extend the settlement time for securities with a shorter settlement time than the Sub - fund to align with the Sub fund subscription and redemption cycle. This may result in increased brok erage charges, which may be charged to the transacting Unitholder via the dilution adjustment. If the settlement time for securities being bought by the Sub - fund in connection with a subscription is not extended, this may result in the Sub - fund being overd rawn or being required to borrow from a lender, both of which may result in additional cost. In addition, the Sub - fund may incur charges in connection with having a loan facility in place to enable the Sub - fund to borrow in such situations. Any, costs asso ciated with the loan facility will be charged to the Sub - fund. The ACS Manager may also make use of alternative portfolio management tools, for example exchange traded futures (where permitted) or maintain an increased cash buffer to manage the misalignmen t being the settlement time of underlying securities and the Sub fund subscription and redemption cycle.

5.50 Suitability Risk

Unless otherwise separately agreed in writing, neither the ACS Manager nor any affiliate of the ACS Manager will assess the individual suitability of any Eligible Investor’s investment into or allocation to the Sub - fund(s)to meet cashflow liabilities speci fic to that Unitholder.

Each prospective investor should consult a stockbroker, bank manager, lawyer, accountant, investment consultant or other financial adviser for independent advice in relation to: (a) the suitability of an investment into the Sub funds for the prospective i nvestor (b) the suitability of the allocation to the Sub - funds in order to meet the prospective investor’s underlying cash flow liabilities (c) the legal requirements within their own countries for the purchase, holding, exchanging, redeeming or disposing of units; (d) any foreign exchange restrictions to which they are subject in their o wn countries in relation to the purchase, holding, exchanging, redeeming or disposing of units; (e) the legal, tax, financial or other consequences of subscribing for, purchasing, holding, exchanging, redeeming or disposing of Units; and (f) the provisions of this Prospectus. unless otherwise agreed in writing, none of the ACS Manager, the Investment Manager or any of their affiliates undertakes to give advice in a fiduciary capacity in connection with the offer and sale of units in the ACS or any Sub - fund.

5.51 Taxation Risk

The tax information provided in the “Taxation” section is based, to the best knowledge of the ACS Manager, upon tax law and practice as at the date of this Prospectus. Tax legislation, the tax status of the ACS Manager and the Sub - fund(s), the taxation of Unitholders and any tax reliefs, and the consequences of such tax status and tax reliefs, may change from time to time. Any change in the taxation legislation or practice in the UK or in any jurisdiction where a Sub - fund is registered, marketed or invested could affect the tax status of the Sub - fund, affect the value of the relevant Sub - fund’s investments in the affected jurisdiction, affect the relevant Sub - fund’s ability to achieve its investment objective, and/or alter the post - tax returns to Unitholders . Where a Sub - fund invests in derivatives, the preceding sentence may also extend to the jurisdiction of the governing law of the derivative contract and/or the derivative counterparty and/or to the market(s) comprising the underlying exposure(s) of the de rivative. The availability and value of any tax reliefs depend on the individual circumstances of Unitholders. The information in the “Taxation” section is not exhaustive and does not constitute legal or tax advice. Prospective investors are urged to consult their tax advisers with respect to their particular tax situations and the tax effects of an investment in the Sub - funds. Where a Sub - fund invests in a jurisdiction where the tax regime is not fully developed or is not sufficiently certain, the relevant Sub - fund, the ACS Manager, the Investment Manager, the Custodian and the Administrator shall not be liable to account to any Unitholder for any payment made or suffered by the relevant Sub - fund in good faith to a fiscal authority for taxes or othe r charges of that Sub - fund notwithstanding that it is later found that such payments need not or ought not have been made or suffered. Conversely, where through fundamental uncertainty as to the tax liability, adherence to best or common market practice (t o the extent that there is no established best practice) that is subsequently challenged or the lack of a developed mechanism for practical and timely payment of taxes, the relevant Sub - fund pays taxes relating to previous years, any related interest or la te filing penalties will likewise be chargeable to that Sub - fund. Such late paid taxes will normally be debited from a Sub - fund at the point the decision to accrue the liability in that Sub - fund’s accounts is made.

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5.52 Tax Status of the Scheme Risk

The ACS is a type of UK fund structure developed to be tax transparent in the UK and elsewhere. While it is expected that non - UK tax authorities will also recognise it as being tax transparent, this may not prove to be the case in all relevant jurisdiction s. If so, depending on the particular circumstances of the investor and/or the investments, this could have adverse tax consequences for the investor. A relevant change in the tax status of the ACS either in the UK or in the country of residence or domicil e of the Unitholder or of any of the underlying investments could lead to Taxation being due. Investors should seek professional advice in relation to such matters and the ACS Manager shall not be liable for any unexpected Taxation being due.

5.53 Umbrella Fund Structure Risk

As explained in paragraph 2.2.1, under section 261P of FSMA, each Sub - fund is a segregated portfolio of assets and those assets can only be used to meet the liabilities of, or claims against, that Sub - fund. Whilst the provisions of section 261P of FSMA pro vide for segregated liability between the Sub - funds, the concept of segregated liability is relatively new. Accordingly, where claims are brought by local creditors in foreign courts or under foreign law contracts, it is not yet known whether a foreign cou rt would give effect to the segregated liability and cross investment provisions contained in section 261P of FSMA. Therefore, it is not possible to be certain that the assets of a Sub - fund will always be completely insulated from the liabilities of anothe r Sub - fund of the ACS in every circumstance.

Notwithstanding the above, however, Unitholders are not liable for the debts of the ACS. A Unitholder is not liable to make any further payment to the ACS after he has paid the price on purchase of the Units (please also refer to Unitholder Indemnity Risk) .

5.54 Unitholder Indemnity Risk

Each Unitholder will be required to provide an indemnity in the form set out in the Certificate of Eligibility as set out at Appendix V, which will be triggered in the event that the Depositary, the Custodian, the ACS Manager, the Investment Manager, the A dministrator, any other provider of services to or in relation to the ACS, any Sub - fund, any underlying investment, any Unitholder or former Unitholder and any of their respective delegates or agents is liable to pay any Taxation because of the indemnifyin g Unitholder’s ownership (including its previous ownership) in the relevant Sub - fund unless payment arises because of the negligence, fraud or wilful default of the party being indemnified. Unitholders may therefore be liable to pay the amount of any such Taxation to the relevant Sub - fund or as the ACS Manager may direct. The indemnity is also intended to provide protection where the amount paid out on the redemption of Units takes into account any income that is not subsequently received by the Sub - fund or any reclaimed amounts of tax which are in the event received by the former Unitholder and not paid to the relevant Sub - fund and any tax which was 23 taken into account in the amount paid out on the redemption of Units, on the basis that it was reclaimable from a tax authority but which is not in fact received by the relevant Sub - fund.

5.55 Valuation Risk

In certain circumstances, a portion of a Sub - fund’s assets may be valued by the ACS Manager or its delegates at fair value using prices provided by broker - dealers or other market intermediaries (and at times may be a single broker dealer or other market intermediary) when other reliable pricing sources may not be available. If relevant information is not available from any of those sources or the ACS Manager considers it unreliable, the ACS Manager may value a Sub - fund’s assets based on such other information as the ACS Manager (or its delegate) may in its discretion consider appropriate. The value established for any portfolio holding at a point in time might differ from what would be produced using a different methodology or if it had been priced using market quotations. Portfolio holdings that are valued using techniques other than market quotations, including fair valued securities, may be subject to greater fluctuation in their valuations from one day to the next than if market quotations were used. There can be no assurance that such prices will accurately reflect the price a Sub - fund would receive upon sale of a security and to the extent a Sub - fund sells a security at a price lower than the price it has been using to value the security, its NAV wil l be adversely affected. When a Sub - fund invests in other funds or investment pools, it will generally value its investments in those funds or pools based on the valuations determined by the funds or pools, which may not be the same as if the net assets of the funds or pools had been valued using the procedures employed by the Sub - fund to value its own assets.

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6. Management and Administration

6.1 Regulatory Status

The ACS Manager and the Investment Manager are authorised and regulated by the FCA of 12 Endeavour Square, London, E20 1JN. The Depositary is authorised by the Prudential Regulation Authority and dual regulated by the FCA and the Prudential Regulation Auth ority.

6.2 ACS Manager

6.2.1 General

The ACS Manager is State Street Unit Trust Management Limited which is a private company limited by shares incorporated in England and Wales on 10 December 1991 with registered number 2669933.

The directors of the ACS Manager are:

Victoria Parry Colin Fernandes Nigel Wightman Rebecca Bridger

The directors’ principal business activities include acting as directors of other schemes managed by investment companies within the State Street group of companies, which includes the Investment Manager.

Registered Office and Head Office: 20 Churchill Place, Canary Wharf, London E14 5HJ.

Share Capital: An issued share capital of £500,000 (which is fully paid up).

Ultimate Holding Company: State Street Corporation.

The ACS Manager is responsible for managing and administering the ACS’s affairs in compliance with the COLL Sourcebook. The ACS Manager may delegate its management and administration functions, but not responsibility, to third parties, including Associates subject to the rules in the COLL Sourcebook.

The ACS Manager has authority to enter into contracts on behalf of the Unitholders for the purposes of, or in connection with, the acquisition, management and/or disposal of Scheme Property. The ACS may on behalf of Unitholders exercise rights under an Aut horised Contract, bring and defend proceedings for the resolution of any matter relating to an Authorised Contract, and take action in relation to the enforcement of any judgment given in such proceedings.

The ACS Manager is also the authorised fund manager of certain authorised unit trusts details of which are set out in Appendix VII.

The ACS Manager has delegated its activities relating to investment management, fund promotion, registration and transfer agency to State Street Global Advisors Limited, which also has the power to sub - delegate and appoint sub distributors. The ACS Manage r has delegated the ACS’s accounting and pricing functions to State Street Bank and Trust Company Limited.

The ACS Manager has appointed State Street Global Advisors Limited as the distributor of the ACS pursuant to a distribution agreement. Under the terms of the distribution agreement, State Street Global Advisors Limited may appoint other distributors, sub - d istributors or dealers for distribution of the ACS. The distributors and sub distributors may (where permitted by the FCA Handbook) receive a referral fee, commission, rebate or other similar amount or otherwise be authorised to retain a selling fee for p rocuring investment into the ACS.

6.3 The Depositary

6.3.1 General

Pursuant to the agreement dated 12th October 2016 between the Manager and the Depositary (the “ Depositary Services Agreement ”) and for the purposes of and in compliance with The Financial Services and Markets Act 2000 (Regulated Activities) (Amendment) Order 2015 and the UK UCITS Requirements (including without limitation, Commission Delegated Regulation (EU) of 17.12.2015 supp lementing Directive 2009/65/EC of the European

Page 45

Parliament and of the Council, as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of the European Union (Withdrawal) Act 2018) with regard to obligations of depositaries, the Depositary has been appointed as depositar y to the ACS and its Sub - Funds.

The Depositary is a public limited company incorporated in England and Wales with company registration number 00014259. HSBC Bank plc is a wholly owned subsidiary of HSBC Holdings plc. The Depositary’s registered and head office is located at 8 Canada Squa re, London E14 5HQ and the principal business activity of the Depositary is the provision of financial services, including trustee and depositary services. HSBC Bank plc is authorised by the Prudential Regulation Authority and regulated by the Prudential R egulation Authority and the Financial Conduct Authority.

6.3.2 Duties

The Depositary provides services to the ACS and its Sub - Funds as set out in the Depositary Services Agreement and, in doing so, shall comply with the UK UCITS Requirements, the relevant FCA Rules and the terms of the ACS Deed.

The Depositary’s duties include the following: -

(i) Ensuring that the Sub - Fund’s cash flows are properly monitored and that all payments made by or on behalf of applicants upon the subscription to Units of the Sub - Funds have been received.

(ii) Safekeeping the assets of the Sub - Fund, which includes (i) holding in custody all financial instruments that can be physically delivered to the Depositary; and (ii) verifying the ownership of other assets and maintaining records accordingly.

(iii) Ensuring that issues, redemptions and cancellations of the Units of each Sub - Fund are carried out in accordance with applicable law and the relevant FCA Rules and ACS Deed.

(iv) Ensuring that the value of the Sub - Fund is calculated in accordance with applicable law and the relevant FCA Rules and the ACS Deed.

(v) Carrying out the instructions of the Manager, unless they conflict with applicable law and the relevant FCA Rules or the ACS Deed.

(vi) Ensuring that in transactions involving a Sub - Fund’s assets any consideration is remitted to the relevant Sub - Fund within the usual time limits.

(vii) Ensuring that a Sub - Fund’s income is applied in accordance with applicable law and the relevant FCA Rules and the ACS Deed.

(viii) Ensuring that the income of each Sub - Fund is received in line with the tax status of each Unitholder.

The appointment of the Depositary under the Depositary Services Agreement may be terminated without cause by not less than 6 months written notice provided that the Depositary Services Agreement does not terminate until a replacement Depositary has been ap pointed.

The Depositary may delegate its safekeeping functions in relation to safekeeping of the assets of the ACS or the Sub - Funds, subject to the terms of the Depositary Services Agreement and with agreement of the ACS Manager.

Unitholders have no personal right to directly enforce any rights or obligations under the Depositary Services Agreement.

In general, the Depositary is liable for losses suffered by the Sub - Funds as a result of its negligence or wilful default to properly fulfil its obligations. Subject to the paragraph below, and pursuant to the Depositary Services Agreement, the Depositary will be liable to the Sub - Fund for the loss of financial instruments of the Sub - Funds which are held in its custody. The Depositary will not be indemnified out of the ACS Property for the loss of financial instruments where it is not so liable.

The liability of the Depositary will not be

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