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Aviva Investors Funds ACS Prospectus ( 7 September 2026 ) 1
Aviva Investors: Confidential
AVIVA INVESTORS UK FUND SERVICES LIM I TED , a member of the AVIVA GROUP AVIVA INVESTORS FUNDS ACS
PROSPECTUS
AI STEWARDSHIP UK EQUITY FUND
AI STEWARDSHIP INTERNATIONAL EQUITY FUND
AI STEWARDSHIP UK EQUITY INCOME FUND
AI STEWARDSHIP FIXED INTEREST FUND
AI UK LISTED EQUITY FUND
AI UK LISTED EQUITY INCOME FUND
AI EUROPE EQUITY EX UK FUND
AI US LARGE CAP EQUITY FUND AI NORTH AMERICAN EQUITY FUND
AI JAPAN EQUITY FUND
AI ASIA PACIFIC EX JAPAN FUND
AI GLOBAL EQUITY FUND
AI GLOBAL EQUITY GROWTH FUND AI STRATEGIC GLOBAL EQUITY FUND
AI STERLING CORPORATE BOND FUND
AI INDEX LINKED GILT FUND
AI STERLING GILT FUND
AI PRE - ANNUITY FIXED INTEREST FUND
AI MONEY MARKET VNAV FUND
AI BALANCED PENSION FUND
AI BALANCED LIFE FUND
AI CAUTIOUS PENSION FUND AI DISTRIBUTION LIFE FUND AI UK EQUITY ALPHA FUND AI UK EQUITY DIVIDEND FUND AI CONTINENTAL EUROPEAN EQUITY ALPHA FUND (please note that this Sub - Fund is in the process of being terminated and is no longer available for investment) AI UK LISTED EQUITY EX TOBACCO FUND A VIVA INVESTORS UK EQUITY CORE FUND AVIVA INVESTORS EUROPE EQUITY EX UK CORE FUND AVIVA INVESTORS JAPAN EQUITY CORE FUND AVIVA INVESTORS PACIFIC EQUITY EX JAPAN CORE FUND AVIVA INVESTORS NORTH AMERICAN EQUITY CORE FUND AVIVA INVESTORS EMERGING MARKET EQUITY CORE FUND
This Prospectus is dated and is v alid a s a t 7 September 2026
Prepared in accordance with the Collective Investment Schemes Sourcebook and the FUND Sourcebook
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Aviva Investors Funds ACS Prospectus ( 7 September 2026 ) 2
Aviva Investors: Confidential
TABLE OF CONTENTS 1. AVIVA INVESTORS FUNDS ACS 4 2. DISTRIBUTION 4 3. GLOSSARY 4 4. THE ACS MANAGER 8 5. THE DEPOSITARY 8 6. THE INVESTMENT MANAGERS 10 7. THE REGISTRAR 11 8. THE SECURITIES LENDING AGENT 11 9. THE ADMINISTRATOR 11 10. THE AUDITOR 11 11. UNITHOLDER’S RELATIONSHIP WITH THE SCHEME ................................ ...................... 11 12. UNITHOLDER’S RIGHTS AGAINST SERVICE PROVIDERS ................................ .............. 11 13. SUBSCRIPTION AND REDEMPTION OF UNITS ................................ ................................ . 12 14. EXCESSIVE TRADING POLICY 15 15. COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS ................................ ....... 15 16. VALUATION 16 17. PRICES OF UNITS AND HISTORIC PERFORMANCE DATA ................................ ............. 16 18. POLICY ON PRICING 17 19. MINIMUM INVESTMENT 17 20. ACS MANAGER'S BOX 17 21. PUBLICATION OF PRICES AND YIELDS ................................ ................................ ............ 17 22. CLASSES OF UNITS 18 23. EVIDENCE OF TITLE 18 24. INVESTMENT OBJECTIVES AND POLICY, AND INVESTMENT RESTRICTIONS ............ 18 25. LEVERAGE RATIOS 21 26. RISK CONSIDERATIONS 21 27. TAXATION 33 28. CHARGES 35 29. CONFLICTS OF INTEREST 38 30. FAIR TREATMENT 40 31. CHANGES TO THE SCHEME AND MEETINGS OF UNITHOLDERS ................................ . 40 32. WINDING UP 41 33. ALLOCATION OF INCOME 42 34. INFORMATION MADE AVAILABLE TO UNITHOLDERS ................................ ..................... 42 35. TELEPHONE RECORDING 42 36. ADDITIONAL INFORMATION 43 37. CLIENT MONEY 44 38. RESTRICTIONS ON INVESTMENT AND HOLDING OF AVIVA PLC SHARES AND OTHER AVIVA SECURITIES 44 39. FIRM - LEVEL STEWARDSHIP AND ESG INTEGRATION APPROACH .............................. 44 40. BENCHMARK REGULATION 44 41. INDEX DISCLAIMERS 45
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Aviva Investors Funds ACS Prospectus ( 7 September 2026 ) 3
Aviva Investors: Confidential
42. PREFERENTIAL TREATMENT 47
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 4
IMPORTANT: IF YOU ARE IN ANY DOUBT ABOUT THE CONTENTS OF THIS PROSPECTUS YOU SHOULD CONSULT YOUR PROFESSIONAL ADVISER.
1. Aviva Investors Funds ACS The Scheme was authorised by an order made by the FCA with effect from 5 December 201 4 . The FCA product reference number of the Scheme is 658260. This document is the 'Prospectus' of the authorised contractual scheme detailed in this Prospectus valid as at the date specified on the cover of this document . This Prospectus has been prepared solely for and is being made available to investors for the purposes of evaluating an investment in Units in the Sub - F unds. Investors should only consider investing in the Sub F unds if they understand the risks involved including the risk of losing all capital i nvested. T he Scheme is organised as an umbrella C o O wnership S cheme comprising separate Sub - Funds . Further additional Sub - F unds may be established in the future by the AC S Manager from time to time with the approval of the FCA and the agreement of the Depositary. Approval by the FCA in this context does not in any way indicate or suggest endorsement or approval of the Funds as an investment. Each Sub - Fund shall have a segregated portfolio of assets and, accordingly, the assets of a Sub - Fund are allocated exclusively to that Sub - Fund and shall not be used or made available to discharge the liabilities of, or claims against, any other person or body, including any other Sub - Fund and shall not be available for any other purpose. The Scheme is subject to the rules of the FCA as set out in the COLL Sourcebook and the FUND Sourcebook . This Prospectus complies with the requirements of COLL 4.2 of the COLL Sourcebook. Each Sub - Fund belongs to the “Non - UCITS Retail Scheme” category as specified in Chapter 5 of COLL and the property attributable to each such Sub - Fund is managed as such.
2. Distribution 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 Scheme or any Sub - Fund of the Scheme have not changed since the date hereof. This Prospectus does not constitute an offer or solicitation by anyone in any jurisdiction in which an offer or solicitation is not lawful or in which the person making such an offer or solicitation is not qualified to do so or to anyone to whom it is unla wful to make such a solicitation . It is the responsibility of any persons in possession of this Prospectus and any persons wishing to apply for Units in the Sub - Funds of the
Scheme to inform themselves of and to observe all applicable laws and regulations of any relevant jurisdiction . Prospective Unitholder s should inform themselves as to the legal requirements of applying for Units and any applicable exchange control regulations and taxes in the countries of their respective citizenship, residence, domicile or incorporation. The ACS Manager does not benefit from any passports that would enable it to market the Scheme in the EEA and, accordingly, Units may not be marketed to EEA domiciled Professional Investors in any EEA territory. US Persons are not permitted to subscribe for Units in the Sub - Funds of the Scheme . The Units in the Sub Funds have not and will not be registered under the United States Securities Act 1933, the United States Investment Company Act 1940, or the securities laws of any of the States of the United States of America and may not be directly or indirectly offered or sold in the United States of America or for the account or benefit of any US Person, except pursuant to an exemption from, or in a transaction not subject to, th e registration requirements of the United States Securities Act 1933, United States Investment Company Act 1940 and similar requirements of such state securities law. Notwithstanding the above, all Unitholders must meet the eligibility criteria set out in this Prospectus and the ACS Deed. In particular, all Unitholders must: (i) be eligible to invest in an authorised contractual scheme (see section 3 6 (i) below); (ii) be a Professional Investor or an Eligible Counterparty. (iii) meet the tax criteria for investment in the relevant Unit Class (as set out in Appendix 1). All dealing, correspondence and communication in relation to this Prospectus with investors shall take place in English.
3. Glossary Accumulation Units
Means Units (of whatever c lass) issued fro m time to time in respect of a Sub - F und and in respect of which income allocated thereto is credited periodically to capital pursuant to the COLL Sourcebook and the ACS Deed . ACS Deed The instrument constituting the Scheme , as such instrument may be amended , novated, supplemented and/or restated from time to time.
ACS Manager
Aviva Investors UK Fund Services Limited, the manager appointed under the terms of the ACS Deed and its successors as ACS Manager . Administrator The Bank of New York Mellon (International) Limited of 160 Queen Victoria Street, London, England, EC4V 4LA .
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 5
AIFMD Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010 . AIFMD Level 2 Regulation
T he UK version of Commission delegated regulation (EU) No 231/2013 supplementing Directive 2011/ 61 /EU of the European Parliament and of the Council with regard to exemptions, general operating conditions, depositaries, leverage, transparency and supervision, which is part of UK law by virtue of the EUWA . AIFM Regulations
T he Alternative Investment Fund Managers Regulations 2013 as amended or re - enacted from time to time which implements AIFMD in the UK . AIGSL Aviva Investors Global Services Limited.
Auditor The auditor of the Scheme from time to time, as at the date of this Prospectus being Ernst & Young LLP, of 25 Churchill Place, London, E14 5EY.
AUM Assets under management.
Aviva Group The Aviva group of companies, the ultimate holding company of which is Aviva plc . Base Currency
The base currency of a Sub - Fund.
Benchmark Regulation
T he UK version of Regulation (EU) No. 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Direct ives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014, which is part of UK law by virtue of the EUWA . Business Day
A day which is not a Saturday or Sunday, or any other day recognised in England and Wales as a public holiday or any other day on which banks or the London Stock Exchange are not open for normal business in the UK . In addition, where a Sub - Fund of the Scheme invests outside the UK, the ACS Manager may also take into account whether relevant local exchanges are open, and may elect to treat such closures as non - business
days . Where possible, Unitholders will be notified in advance of such cases.
CCP has the meaning ascribed to it in the glossary of definitions to the FCA Handbook . COLL Sourcebook
The C ollective I nvestment S chemes sourcebook which forms part of the FCA Handbook, as amended from time to time. References to rules or guidance in the COLL Sourcebook are prefaced by "COLL".
Co Ownership Scheme
A scheme as defined by section 235A of the Financial Services and Markets Act 2000, as amended from time to time.
Core Funds The Aviva Investors UK Equity Core Fund, Aviva Investors Europe Equity Ex UK Core Fund, Aviva Investors Japan Equity Core Fund, Aviva Investors Pacific Equity Ex Japan Core Fund, A viva I nvestors North A merican E quity Core F und and Aviva Investors Emerging Market Equity Core Fund.
Deal Cut - Off Point
The time by which a subscription or redemption request must be received in order for the subscription or redemption to occur at the Valuation Point for that Dealing Day. The Deal Cut - Off Point for each Sub - Fund is set out in Appendix 1.
Dealing Day A day on which a Sub - Fund processes orders in its Units. The Dealing Day for each Sub - Fund is set out in Appendix 1.
Depositary The Bank of New York Mellon (International) Limited , to whom the Scheme property is entrusted for safekeeping and who is appointed to act as the Depositary of the Scheme and its successors as Depositary.
Depositary Services Agreement
The depositary services agreement between the ACS Manager and the Depositary , as amended, novated, restated, supplemented and/or restated from time to time . EEA European Economic Area.
EEA State A member state of the European Union and any other state which is within the EEA , as defined in the glossary to the FCA Handbook . Eligible Counterparty
A n investor that is considered to be an eligible counterparty or that may, on request, be treated as a n eligible
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 6
counterparty within the meaning of the Financial Services and Markets Act 2000 (Markets in Financial Instruments) Regulations 2017 (SI 2017/701) . Eligible Derivatives Market
A derivatives market which is listed in Schedule 2.
EMIR T he UK version of Regulation (EU) No 648/2012 on OTC derivatives, central counterparties and trade repositories, which is part of UK law by virtue of the EUWA , sometimes referred to as the "European Markets Infrastructure Regulation" as amended by Regulation (EU) 2019/834 of the European Parliament and of the Council of 20 May 2019 . EUWA T he European Union (Withdrawal) Act 2018 . FCA The Financial Conduct Authority or any other relevant successor regulatory body from time to time.
FCA Handbook
The FCA's handbook of rules and guidance, as amended from time to time.
FIL FIL Pensions Management.
Form The application form to subscribe for Units in the Scheme (including appropriate documentation to confirm the tax status of the Unitholder) . FSCS Financial Services Compensation Scheme.
FUND Sourcebook
The I nvestment F unds S ourcebook which forms part of the FCA Handbook, as amended from time to time. References to rules or guidance in the FUND Sourcebook are prefaced by "FUND ".
HMRC or HM Revenue and Customs
His Majesty’s Revenue and Customs .
Income Distribution Units
Units (of whatever class) issued from time to time in respect of a Sub - Fund and in respect of which income is distributed periodically to Unitholders pursuant to the COLL Sourcebook and the ACS Deed . Investment Manager s
Schroders , FIL and AIGSL (each an Investment Manager).
Investor Agreement
An investor agreement containing the indemnities and undertakings required
in connection with a Unitholder’s subscription for Units in the Scheme and (where required by the ACS Manager) governing any investment management charges . Minimum Investment
The minimum investment required for an investor in a Sub - Fund. The Minimum Investment for each Sub Fund is set out in Appendix 1.
MMFR The UK version of Regulation (EU) No 2017/1131 of the European Parliament and the Council of 14 June 2017 on money market funds, which is part of UK law by virtue of the EUWA .
Non - UCITS retail scheme
A scheme complying with the requirements of the COLL Sourcebook for a non - UCITS retail scheme.
Normal Business Hours
The hours between 8.30 a.m. and 5.30 p.m. on any Business Day.
OTC Over - the - counter.
Power of Attorney
A power of attorney in connection with, amongst other things, applications for reductions of withholding tax required to be entered into by Unitholders contemporaneously with and as a condition to completion of the Form . PRA Prudential Regulation Authority.
PRC The People’s Republic of China.
Professional Investor
A n investor that is considered to be a professional client or that may, on request, be treated as a professional client within the meaning of the Financial Services and Markets Act 2000 (Markets in Financial Instruments) Regulations 2017 (SI 2017/701) (which, for the avoidance of doubt, shall include, a person who the ACS Manager has been permitted to treat as an elective professional client in accordance with COBS 3.5.3BR to COBS 3.5.3ER) . Register The register of Unitholders for each of the Sub - Funds.
Registrar The Bank of New York Mellon (International) Limited . Safekeeping Function
The function of safekeeping the assets of the Sub - Funds, which includes : (i) holding in custody all financial instruments that can be registered in a financial instrument account opened in
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 7
the Depositary 's books and all financial instruments that can be physically delivered to the Depositary ; and (ii) for other assets, verifying the ownership of such assets , and maintaining records accordingly.
Scheme Aviva Investors Funds ACS . Schroders Schroder Investment Management Limited . Securities Financing Transactions Regulation
T he UK version of Regulation (EU) 2015/2365 of the European Parliament and of the Council of 25 November 2015 on transparency of securities financing transactions and of reuse and amending Regulation (EU) No 648/2012 as amended by the Transparency of Securi ties Financing Transactions and of Reuse (Amendment) (EU Exit) Regulations 2019, which is part of UK law by virtue of the EUWA . Securities Lending Agent
The Bank of New York Mellon, London Branch.
Securities Lending Authorisation Agreement
As defined in paragraph 24 (b) (i).
Service Providers
The service providers to the Scheme , in cluding the Investment Managers, the Administrator and the Auditor, whose details are set out herein . SFT A securities financing transaction as defined by Article 3(11) of the Securities Financing Transactions Regulation.
Sub - Funds The sub - fund of the Scheme with segregated liability and detailed in Appendix 1 from time to time (each a Sub - Fund).
Stewardship Funds
The AI Stewardship UK Equity Fund, AI Stewardship International Equity Fund, AI Stewardship UK Equity Income Fund, and AI Stewardship Fixed Interest Fund.
TBAs “To Be Announced” securities . TRS A total return swap as defined by Article 3(18) of the Securities Financing Transactions Regulation.
UCITS An undertaking for collective investment in transferable securities which is a UCITS Scheme or an EEA
UCITS scheme, the latter as defined in the FCA Handbook . UCITS Directive
T he European Parliament and Council Directive of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS) (No 2009/65/EC), as amended . UCITS Scheme
A UK UCITS, as defined below.
UK The United Kingdom of Great Britain and Northern Ireland.
UK AIF A n alternative investment fund within the scope of the UK AIFM Regime and as defined in the FCA Handbook . UK AIFM A n alternative investment fund manager established in the UK and with a Part 4A permission to carry on the regulated activity of managing an alternative investment fund . UK AIFM Regime
(i) the FUND Sourcebook, (ii) other rules in the FCA Handbook which when made implemented AIFMD , (iii) the AIFMD Level 2 Regulation and (iv) the AIFM Regulations.
UK UCITS I n accordance with sections 236A and 237 of the Financial Services and Markets Act 2000, a collective investment scheme which may consist of several sub - funds, which is either an authorised unit trust scheme, an authorised contractual scheme, or an authoris ed open - ended investment company with the sole object of collective investment of capital raised from the public in transferable securities or other liquid financial assets , operating on the principle of risk - spreading , with units which are, at the request of holders, repurchased or redeemed, directly or indirectly, out of those undertakings’ asset s, and which has identified itself as a UCITS in its prospectus and has been authorised accordingly by the FCA . Unit (s) A unit or units representing the rights and interests of a Unitholder in a Sub Fund . Unit Class Any class of Units. A Unit Class may have its own cost and fee structure, currency denomination, hedging policy, minimums, holding amounts, investor eligibility criteria, tax characteristics and other features.
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 8
Unitholder I n relation to a Class or Sub - F und means a person who is on the register as a unitholder in that Class or Sub F und at that time . Unitholder Documents
Collectively, the Form, an Investor Agreement , the Power of Attorney , the Prospectus and the ACS Deed.
US Persons M eans any US resident or other person specified in Regulation S under the United States Securities Act 1933, as amended from time to time and as may be further supplemented by the ACS Manager.
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 p roperty for the Sub - Funds for the purpose of determining the price at which Units of a c lass may be issued, cancelled or redeemed . The Valuation Point for each Sub - Fund is set out in Appendix 1.
4. The ACS Manager The ACS Manager (Registered Company No. 0197341 2 ) is a limited company incorporated in England and Wales on 20 December 1985 . It is a subsidiary of Aviva Investors Holdings Limited and forms part of the Aviva Group. The ACS Manager is authorised and regulated by the FCA with permission to carry on the activity of 'managing a UK AIF'. As such, the ACS Manager has been appointed to be the UK AIFM of the Scheme , which is an alternative investment fund, or ' UK AIF', for the purposes of the UK AIFM Regime . The ACS Deed contains provisions governing the responsibilities of the ACS Manager in relation to the management and administration of the Scheme and the issue , cancellation and redemption of the Units . The ACS Manager, as the alternative investment fund manager of the Scheme , is responsible for the portfolio management of the Scheme and exercising the risk management function in respect of the Scheme . In addition, the ACS Manager's duties include to acquire, manage and dispose of the property which is subject to the Scheme from time to time and enter into 'Authorised Cont r acts' which are binding on the Unitholders . As the alternative investment fund manager of the Scheme , the ACS Manager is also responsible for ensuring compliance with the UK AIFM Regime in respect of the Scheme . Professional liability risks resulting from those activities which the ACS Manager carries out pursuant to the UK AIFM Regime , are covered by the ACS Manager through 'own funds' (within the meaning of the UK AIFM Regime ). The ACS Manager may delegate certain of its functions to third parties ; however, these functions remain the responsibility of the ACS Manager . Further
details of the functions currently delegated by the ACS Manager are set out in sections 6 to 9 . The registe red office of the ACS Manager is 80 Fenchurch Street, London, EC3M 4AE . The i ssued and paid - up share capital of the ACS Manager is twenty one million five hundred thousand ordinary share s of £1. The ACS Manager also acts as the ACS Manager to another authorised contractual scheme as more fully described in Appendix 5 . The d irectors of Aviva Investors UK Fund Services Limited , as at the date of this Prospectus, are named below : J Barber M Bell M Kingdon J Lowe K McClellan G Spe i rs All the above directors have various responsibilities within the Aviva Group . None of the directors' main business activities (which are not connected with the business of the ACS Manager or any of its associates) is of significance to the Scheme's business. The ACS Manager maintains a conflicts of interest policy.
5. The Depositary The Bank of New York Mellon (International) Limited is the d epositary of the Scheme and, for the avoidance of doubt, act s as the global custodian to the Scheme. The Depositary is a private company limited by shares incorporated in England and Wales on 9 August 1996. Its ultimate holding company is The Bank of New York Mellon Corporation, a public company incorporated in the United States. The registered office ad dress is at 160 Queen Victoria Street, London, EC4V 4LA . The principal business activity of the Depositary is the provision of custodial, banking and related financial services. The Depositary is authorised by the Prudential Regulation Authority and is dual - regulated by the Financial Conduct Authority and the Pr udential Regulation Authority.
Terms of Appointment
The ACS Manager, acting for and on behalf of the Scheme, is required to enter into a written contract with the Depositary to evidence its appointment. The Depositary was appointed under an agreement that took effect on 7 Septem ber 2026 (the “Depositary Agreement”). Information on the Depositary’s remuneration is set out in Section 28 (“Charges”) of this Prospectus.
Duties of the Depositary
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 9
The Depositary is responsible for the safekeeping of the p roperty of the Scheme , monitoring the cash flows of the Scheme, and must ensure that certain processes carried out by the ACS Manager are performed in accordance with the applicable rules and the constitutive documents of the Scheme.
Delegation of Safekeeping Functions
The Depositary act s as global custodian and may delegate safekee ping to one or more global sub c ustodians (such delegation may include the powers of sub - delegation). T he Depositary has delegated safekeeping of the assets of the Scheme to T he Bank of New York Mellon SA/NV and/or The Bank of New York Mellon (the “Global Sub - Custodians”) . The Global Sub - Custodians may sub - delegate safekeeping of assets in certain markets in which the Scheme may invest to various sub - delegates.
Conflicts of interest
For the purposes of this section, the following definitions shall apply:
“ BNY Mellon Affiliate ” means any entity in which The Bank of New York Mellon Corporation (a Delaware corporation with registered office at 240 Greenwich St, New York, New York 10286, U.S.A) controls (directly or indirectly) an interest of no less than 30% in the voting stock o r interests in such entity.
“ Link ” means a situation in which two or more natural or legal persons are either linked by a direct or indirect holding in an undertaking which represents 10% or more of the capital or of the voting rights or which makes it possible to exercise a significant i nfluence over the management of the undertaking in which that holding subsists.
“ Group Link ” means a situation in which two or more undertakings or entities belong to the same group within the meaning of Article 2(11) of Directive 2013/34/EU, as implemented or given direct effect in the UK, or international accounting standards adopted in accord ance with Regulation (EC) No. 1606/2002, as it forms part of the law of the UK by virtue of the EU Withdrawal Act 2018, as amended, modified and reinstated from time to time, and any succeeding UK law or regulation which becomes enforceable by law from tim e to time.
Depositary, Scheme and ACS Manager
The following conflicts of interests exist between the Depositary, the Scheme and the ACS Manager: A Group Link where the ACS Manager has delegated certain administrative functions, including but not limited to Registrar, Transfer Agency, and Fund Accounting, to The Bank of New York Mellon (International) Limited or a BNY Mellon Affiliate.
The Depositary shall ensure that policies and procedures are in place to identify all conflicts of interests arising from such Group Links and shall take all reasonable steps to avoid such conflicts of interests. Where such conflicts of interests cannot b e avoided, the Depositary and the ACS Manager will ensure that such conflicts of interests are managed, monitored and disclosed in order to prevent adverse effects on the interests of the Scheme and its investors.
If a Link exists between the Depositary and any investors in the Scheme, the Depositary shall take all reasonable steps to avoid conflicts of interests arising from such Link . Delegation
The following conflicts of interests exist as a result of the Depositary’s delegation arrangements relating to safekeeping outlined above:
A Group Link where the Depositary has delegated, or where any Global Sub - Custodian has sub - delegated, the safekeeping of the Scheme Property to a BNY Mellon Affiliate.
The Depositary shall ensure that policies and procedures are in place to identify all conflicts of interests arising from such Group Links and shall take all reasonable steps to avoid such conflicts of interests.
Where such conflicts of interests cannot be avoided, the Depositary will ensure that such conflicts of interests are managed, monitored and disclosed in order to prevent adverse effects on the interests of the Scheme and its investors.
The Depositary may, from time to time, act as the depositary of other open - ended investment companies with variable capital and as trustee or custodian of other collective investment schemes.
Depositary Conflicts of I nterest
The Depositary or any BNY Mellon Affiliates may have an interest, relationship or arrangement that is in conflict with or otherwise material in relation to the services it provides to the ACS Manager and the Scheme. Conflicts of interest may also arise bet ween the Depositary’s different clients.
As a global financial services provider, one of the Depositary’s fundamental obligations is to manage conflicts of interest fairly and transparently. As a regulated business, the Depositary is required to prevent, manage and, where required, disclose infor mation regarding any actual or potential conflict of interest incidents to relevant clients.
The Depositary is required to and does maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps designed to prevent conflicts of interest from adversely affecting the interests of its clients.
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 10
The Depositary maintains a Conflicts of Interest Policy (the “Conflicts Policy”). The Conflicts Policy (in conjunction with associated policies):
(a) identifies the circumstances which constitute or may give rise to a conflict of interest entailing a risk of damage to the interests of one or more clients; (b) specifies the procedures or measures which should be followed or adopted by the Depositary in order to prevent or manage and report those conflicts of interest; (c) sets out effective procedures to prevent or control the exchange of information between persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients; (d) includes procedures to ensure the separate supervision of persons whose principal functions involve carrying out activities with or for clients and whose interests may conflict, or who otherwise represent different interests that may conflict, including wi th the interests of the Depositary; (e) includes procedures to remove any direct link between the remuneration of individuals principally engaged in one activity and the remuneration of, or revenues generated by, different individuals principally engaged in another activity, where a conflict of interest may arise in relation to those activities; (f) specifies measures to prevent or limit any person from exercising inappropriate influence over the way in which an individual carries out investment or ancillary services or activities; and (g) sets out measures to prevent or control the simultaneous or sequential involvement of an individual in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest.
The Conflicts Policy clarifies that disclosure of conflicts of interest to clients is a measure of last resort to be used by the Depositary to address its regulatory obligations only where the organisational and administrative arrangements established by t he Depositary (and any BNY Mellon Affiliates where applicable) to prevent or manage its conflicts of interest are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of clients will be prevented.
The Depositary must assess and review the Conflicts Policy at least once per year and take all appropriate measures to address any deficiencies.
The Depositary shall make available to its competent authorities, on request, all information which it has obtained while performing its services and which may be required by the competent authorities of the Scheme .
6. The Investment Manager s The ACS Manager has delegated certain functions with respect to the investment management of the assets of the Scheme t o Schroder Investment Management Limited , FIL Pensions Management and Aviva Investors Global Services Limited . The Investment Managers referred to below have been granted the authority to manage and make purchases and sales of investments for the appropriate Sub - Funds on the ACS Manager's behalf and as the ACS Manager's agent, within the investment policies of the relevant Sub - Fund of the Scheme. The Investment Managers have discretion to buy, sell, retain , exchange or otherwise deal in investments (including derivatives) , subscribe for new issues, and accept placings, underwr itings or sub underwritings for the relevant Sub - Funds. The Investment Managers may sub - delegate all or part of their functions to a third party and shall seek the consent of the ACS Manager prior to any such sub delegation. Further details as to whether an Investment Manager has exercised this right are set out below . The Investment Manager s report to the ACS Manager on the performance of each Sub - Fund . The Investment Manager s ' fees for acting as an investment manager of the relevant Sub - Fund are paid by the ACS Manager.
(a) Schroder Investment Management Limited The registered office of Schroders is 1 London Wall Place, London, England, EC2Y 5AU . Schroder s is authorised and regulate d by the FCA. Schroder's principal activity is acting as an investment manager . The ACS Manager may terminate its investment management agreement with Schroders on giving six months' notice to Schroders, however in certain limited circumstances the ACS Manager may terminate its investment management agreement with Schroders upon notice with immediate effect. Schroders may terminate its investment management agreement on giving twelve months' notice to the ACS Manager, however, in certain limited circumstances ; Schroders may terminate its investment management agreement with the ACS Manager upon notice with immediate effect . At the date of this Prospectus, there was no sub delegation of the functions performed by Schroders.
(b) Aviva Investors Global Services Limited The registered office of AIGSL is 80 Fenchurch Street, London, EC3M 4AE . AIGSL is authorised and regulated by the FCA. AIGSL 's principal activity is acting as an investment manager. AIGSL is part of the Aviva Group.
The ACS Manager may terminate its investment management agreement with AIGSL on giving six months' notice to AIGSL , however in certain limited circumstances the ACS Manager may terminate its investment management agreement with AIGSL upon
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notice with immediate effect. AIGSL may terminate its investment management agreement on giving six months' notice to the ACS Manager, however, in certain limited circumstances; AIGSL may terminate its investment management agreement with the ACS Manager upon notice with immediate effect (however in certain circumstances where AIGSL may terminate with immediate effect, the ACS Manager may require AIGSL to continue to provide the investment management services for up to six months, notwithstanding the shorter notice period ) .
At the date of this Prospectus, there was no sub delegation of the functions performed by AIGSL.
(c) FIL Pensions Management The registered office of FIL is Beech Gate, Millfield Lane, Lower Kingswood, Tadworth, Surrey KT20 6RP. FIL is authorised and regulate d by the FCA. FIL's principal activity is providing pensions and investment management services . The ACS Manager may terminate its investment management agreement with FIL on giving one months' notice to FIL, however in certain limited circumstances the ACS Manager may terminate its investment management agreement with FIL upon notice with immediate effect. FIL may also terminate its investment management agreement on giving one months' notice to the ACS Manager, however, in certain limited circumstances , FIL may terminate its investment management agreement with the ACS Manager upon notice with immediate effect . At the date of this Prospectus, FIL has sub - delegated its portfolio management duties to another company within its Group, FIL Investments International.
7. The Registrar The Registrar , as the ACS Manager’s delegate, is the person responsible for maintaining the Register under the terms of the ACS Deed for the Scheme. The Register may be inspected at 160 Queen Victoria Street, London, EC 4V 4LA by or on behalf of the Unitholders , on any Business Day during Normal Business Hours. The Register is conclusive evidence of the title to Units except in the case of any default in payment or transfer to a Scheme of cash or other property due and the Depositary and the ACS Manager are not obliged to take notice of any trust or equity or other interest affecting the title to any of the Units . 8. The Securities Lending Agent The Bank of New York Mellon, London Branch, of 160 Queen Victoria Street, London, EC4V 4LA has been appointed to act as securities lending agent for the Sub - Funds . The Securities Lending Agent has the discretion to arrange securities loans and repo contracts with approved counterparties . Further details are provided in section 24 (b) below.
9. The Administrator The Administrator will act as the ACS Manager’s delegate, performing a number of fund administration services, including fund accounting (amongst other things assisting the ACS Manager in calculating the Unit price of a Sub - Fund), and client and fund admin istration, (amongst other things assisting the ACS Manager with its requirement to process requests for subscriptions and redemptions for Units in a Sub Fund and maintenance of the Register).
10. The Auditor The Auditor ’ s responsibility is to audit and express an opinion on the financial statements of the Scheme in accordance with applicable law and auditing standards.
11. Unitholder ’ s Relationship with the Scheme In order to subscribe for Units , Unitholders must complete an appropriate Form , Power of Attorney and Investor Agreement . By doing so, Unitholders agree to subscribe for Units and to be bound by the terms of this Prospectus and the ACS Deed. All Unitholders are entitled to the benefit of, are bound by, and are deemed to have notice of, the provisions of the ACS Deed, copies of which are available as described in section 36 (vi) below. The provisions of the ACS Deed are binding on the Depositary , the ACS Manager and the Unitholders and all persons claiming through them respectively as if all such Unitholders and persons had been party to such ACS Deed. The Unitholder Documents are governed by and at all times subject to English law . T he courts of England shall have jurisdiction in relation to claims made under them . Unitholders should note that the Scheme and the Sub Funds may be adversely affected by the ability to recognise and enforce a foreign judgment in England. There are a number of legal instruments providing for the recognition and enforcement of judgments ob tained from certain jurisdictions relating to certain matters in England. Judgments obtained in jurisdictions or relating to matters not covered by such legal instruments may be enforceable in England at common law. Nevertheless, there is uncertainty regar ding the ability to enforce foreign judgments in England, which may adversely affect the Scheme and the Sub - Funds and the value of a Unitholder’s Units. Section 261P of the Financial Services and Markets Act 2000 provides for segregated liability between Sub - Funds . The concept of segregated liability is relatively new . Accordingly, where c laims are brought by local creditors in foreign courts or under foreign law contracts, it is not yet known how those foreign courts will react to S ection 261P.
12. Unitholder’s Rights Against Service Providers The Scheme is reliant on the performance of the S ervice P roviders. No Unitholder will have any direct contractual claim against any Service Provider with respect to such Service Provider ’ s default . This is without prejudice to
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any right a Unitholder may have to bring a claim against an FCA authorised Service Provider , the ACS Manager or the Depositary under S ection 138D of the Financial Services and Markets Act 2000 (which provides that breach of an FCA rule by such Service Provider , the ACS Manager or the Depositary is actionable by a private person who suffers loss as a result), or any tortious or contractual cause of action. Unitholders who belie ve they may have a claim under S ection 138D of the Financial Services and Markets Act 2000, or in tort or contract , against any Service Provider , the ACS Manager or the Depositary in connection with their investment in the Scheme , should consult their legal adviser. U nitholders may be eligible for compensation under the FSCS if they have claims against the ACS Manager, Depositary or another FCA authorised Service Provider (including the Investment Manager s ) which is in default. As set out in section 36 (v) , there are limits on the amount of compensation available. Further information about the FSCS is at www.fscs.org.uk . To determine eligibility in relation to the FSCS, Unitholders should consult the website above and speak to their legal advisers. See section 5 above for a summary of the Depositary’s liability to the Scheme.
13. Subscription and Redemption of Units
(a) Liquidity m anagement The ACS Manager maintains a liquidity management policy to monitor the liquidity risk of the Scheme , which includes, among other tools and methods of measurement, the use of stress tests under both normal and exceptional circumstances. The liquidity management systems and procedures employed by the ACS Manager enable it to measure the liquidity of a Sub - Fund ’ s portfolio against thresholds set by reference to each Sub - Fund ’ s redemption policy. The ACS Manager seeks to ensure that the Scheme and each Sub - Fund will remain within the liquidity limits set for it. The ACS Manager is also able to apply various tools and arrangements necessary to respond appropriately to redemption requests. In normal circumstances, redemption requests will be processed as set out below in section 13 (d) . Other arrangements may also be used in response to redemption requests, including the use of the power of deferral or similar arrangements (as set out in this document, for example in section 13 (f) ) which, if activated, will restrict the redemption rights Unitholders benefit from in the ordinary course. The ACS Manager may also temporarily suspend redemptions in certain circumstances as set out in section 13 (h) . (b) Subscription for Units Subject to the policy on pricing (see section 18 ), an application to subscribe for Units in the Scheme for the first time must be made in writing to the ACS Manager . For all Sub - Funds there will be an initial offer period of one day . During the initial offer period, the initial offer
price of the Units will be £1.00 . Any subsequent subscription for Units by an existing Unitholder may be made, during Normal Business Hours , by such forms of electronic communication as may be approved by the ACS Man ager or any other method otherwise approved by the ACS Manager. W hen placing an order to subscribe for Units for the first time , the ACS Manager will request that a F orm be completed and returned to the ACS Manager. The ACS Manager reserves the right to reject, on reasonable grounds, any application for Units in whole or in part . Failure to return a fully completed F orm may result in a delay in the ACS Manager processing any subsequent redemption request or may result in the ACS Manager withholding redemption proceeds. A ll requests to subscribe for Units must be received by the D eal C ut - O ff Point for the relevant Sub - Fund as set out in Appendix 1 otherwise they will be held over to the Valuation Point on the next Dealing Day for that Sub - Fund . Purchase orders made by approved electronic communication and received outside of Normal Business Hours will be a ffected as soon as possible on the next Business Day. Please note , to the extent being provided in advance of the associated subscription for Units, that monies received on a Business Day when there is not a Valuation Point and/or which is not a Dealing Day will not be invested in the relevant Sub - Fund until the Valuation Point on the next Dealing Day . A contract note will be sent to the applicant b y electronic communication on the next Business Day after the Valuation Point applicable to the deal. The contract note will show the price of the relevant Units (per Unit and the total cost), shown to at least four significant figures . Except in the case of in specie subscriptions (see section 13 ( g ) below), i f a Unitholder has not already paid, it must ensure that the ACS Manager receives payment by close of business on the third Business Day after the Valuation Point applicable to the deal. The ACS Manager may however, subject to notifying the relevant Unitholder prior to accepting a subscription request, require earlier payment. If timely settlement is not made, the ACS Manager may, at its sole discretion, cancel the relevant subscription of Units and/or an applicant may be required to pay an administration charge to the ACS Manager to cover any costs and resultant losses incurred by the ACS Manager and/or the Scheme . Payment for the subscription of Units is by electronic payment. No certificates are issued for Units in the Scheme . In accordance with the COLL Sourcebook the ACS Manager reserves the right to refuse to issue Units in certain circumstances, in particular where it has reasonable grounds to refuse the sale. U nitholders must meet the inves tment criteria for any Unit Class in which they intend to invest . If a subscription request is processed for Units in a class in which a Unitholder does not meet the investment criteria then the ACS Manager reserves the right to switch the Unitholder into a more appropriate class in the Scheme (where available) or redeem the
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Unitholder 's Units . In such a scenario the ACS Manager is not obliged to give the Unitholder prior notice of its actions and the Unitholder bears any consequential risk including that of market movement.
(c) Cancellation rights Any Unitholder who is a consumer (as defined in the FCA Handbook) may have 14 days in which to cancel the relevant purchase if advised to subscribe for Units by an authorised person through whom a Unitholder 's business is placed with the ACS Manager unless an appropriate customer agreement exists between such authorised person and the Unitholder . The 14 days commences upon receipt of the contract note by the Unitholder . A Unitholder will need to notify the ACS Manager in writing that it wishes to exercise a right to cancel . Unitholders should note that exercising a right to cancel does not necessarily mean that a Unitholder will receive back the amount invested . Unitholders will receive back an amount based on the subscription price next calculated following the ACS Manager's receipt of a valid cancellation notice in writing. A Unitholder which has not yet paid for the investment will be liable to make up any shortfall. Proceeds from cancellation will be retained until the purchase payment has cleared . This may be for a period of up to 21 calendar days from the date of subscription . No interest will be paid on cancellation monies.
(d) Redemption of Units Subject to the policy on pricing (see section 18 ) and the timing of each Sub - Fund’s Valuation Points for the purposes of dealing (as set out in Appendix 1) , Units in any Sub - Fund may normally be redeemed during Normal Business Hours . All requests for redemption must be received by the Deal Cut - Off Point on a Dealing Day for the relevant Sub - Fund as set out in Appendix 1 otherwise they will be held over to the next following Dealing Day.
− Redeeming Unitholders must complete a redemption request by such forms of electronic communication as may be approved by the ACS Man ager or any other method otherwise approved by the ACS Manager . − The ACS Manager will send Unitholders a contract note for the redeemed Units by electronic communication by close of business on the Business Day after the Valuation Point on which the redemption request is accepted by the ACS Manager . − Except in the case of in specie redemptions (see section 13 ( g ) below) or deferred redemptions (see section 13 ( f ) below), t he proceeds will be sent to Unitholders by electronic payment by the close of business on the third Business Day after the later of the following times: (i) the Valuation Point at which the redemption instructions were processed; or (ii) the date of receipt of the instructions to redeem .
(e) Delivery Versus Payment (“DvP”) Exemption The ACS Manager may make use of the Delivery versus Payment (“DvP”) exemption for Unitholders that consent, as set out in the FCA Client Asset Rules (“CASS Rules”), which provides for a one business day window during which Unitholders’ money held by the ACS Manager for the p urposes of settling a transaction in Units is not treated as “client money” within the meaning of the CASS Rules. Specifically, under the DvP exemption, money received by the ACS Manager from an Unitholder, or money due to be paid to a Unitholder by the AC S Manager, need not be treated as client money if: (i) the ACS Manager receives the money from a Unitholder in relation to the ACS Manager’s obligation to issue Units in the ACS and the money is passed to the Depositary for the purpose of this obligation in the relevant Sub - Fund within the timeframes set out in the FCA Rules; or (ii) the ACS Manager holds the money in the course of redeeming Units provided that the proceeds of that redemption are paid to a Unitholder within the timeframes s et out in the FCA Rules . (f) Deferred redemption At times of excessive redemptions the ACS Manager may decide to defer redemptions at any Valuation Point to the next Valuation Point where the requested aggregate redemptions exceed 10 % of the Scheme' s value . This will therefore allow the ACS Manager to protect the interests of continuing Unitholders by allowing the ACS Manager to match the sale of scheme property to the level of redemptions . This should reduce the impact of dilution on the Schem e . All Unitholders who have sought to redeem Units at any Valuation Point at which redemptions are deferred will be treated consistently and any redemption requests received following the decision to defer redemptions will not be processed until the redemption requests that have been deferred to subsequent Valuation Point s have been processed.
(g) In specie subscriptions and redemptions The ACS Manager may, at its discretion, arrange for the Depositary to issue Units in exchange for assets other than cash. The Depositary may, on the instruction of the ACS Manager, pay out of the relevant Sub - Fund assets other than cash as payment for the redemption of Units . An i n specie subscription or in specie redemption will only take place where the Depositary has taken reasonable care to determine that it is not likely to result in any material prejudice to the interests of Unitholders in the relevant Sub - Fund . 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 s or policy of that Sub - Fund. Where the ACS Manager elects to carry out an in specie redemption, it must notify the Unitholder of this in writing no later than the close of business on the second Business Day after the day on which it received selling instructions from the Unitholder
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Where there is an in specie redemption, the Depositary will, in accordance with the rules of the COLL Sourcebook, cancel the Units and transfer a proportionate share of the assets of the relevant Sub Fund or such selection from the property of the Scheme as the Depositary , after consultation with the ACS Manager, decides is reasonable to the Unitholder , in either case having regard to the need to be fair both to the Unitholder taking the in specie redemption and to continuing Unitholders . Irrespective of the value of the Units , where a Unitholder wishes to redeem and the ACS Manager has elected to provide an in specie transfer, the Unitholder is entitled to instruct the ACS Manager not to transfer assets, but to sell those assets (other than those in cash in the relevant currency) and pay to the Unitholder the net proceeds of sale (and cash). However, instruction must be given by the Unitholder in writing to the ACS Manager by the close of business on the fourth Business Day after receipt of the ACS Manager's notice of election to provide an in specie redemption. The value raised will not necessarily correspond with the applicable published bid price. The ACS Manager may, in its sole discretion, agree to a request from a Unitholder for an in specie redemption where it receives such request in advance of the redemption request. Where the ACS Manager does agree, the Depositary will transfer assets to the Unitholder of the relevant Sub - Fund in the manner set out above.
(h) Suspension The ACS Manager may, with the prior agreement of the Depositary , and must without delay, if the Depositary so requires, temporarily suspend the issue and redemption of Units for a period of time where due to exceptional circumstances it is in the interest of all Unitholders in the relevant Sub - Fund. The ACS Manager and Depositary must ensure that the period of suspension is only allowed to continue for as long as it is justified having regard to the interest of Unitholders and that dealing resumes as soon as practicable after the circumstances triggering a suspension have ceased . Upon suspension the ACS Manager or the Depositary will immediately inform the FCA giving reasons for the suspension and notify any home state regulator in jurisdictions where Units in the relevant Sub - Fund are available for sale. The ACS Manager will notify Unitholders of the suspension as soon as practicable after the suspension commences and will formally review the suspension with the Depositary at least every 28 days, keeping the FCA informed. The ACS Manager will resume issue and redemption in Units after giving the requisite notice in accordance with the COLL Sourcebook. The ACS Manager will publish sufficient details on its website to keep Unitholders appropriately informed about the suspension including, if known, its likely duration. In addition to the above, the ACS Manager may be required to suspend dealings in a Sub - Fund where
dealings in any underlying funds in which that Sub Fund invests have also been suspended . (i) Conversion and switching rights Where more than one class of U nit is in issue in a Sub Fund , the ACS Manager may permit a U nitholder to: (i) convert all or some of the U nits held from one class in that Sub - Fund (the " Original Units ") for U nits of another class in the same Sub - Fund (" New Units "), subject to M inimum I nvestment and eligibility requirements. When U nits are converted, the number of New Units to be issued will be determined by applying a 'conversion factor' to the value of the Original Units held to determine the number of New Units to be issued. The conversion factor applicable to such U nit conversion is available on request from the ACS Manager in writing ; or (ii) switch all or some of the U nits held from one class in that Sub - Fund (the " Original Units ") into U nits of another Sub - Fund within the Scheme (the " New Units ") subject to M inimum I nvestment and eligibility requirements . On a switch of U nits, the number of New Units issued will be determined by reference to the respective prices of New Units and Original Units at the V aluation P oint applicable when the Original Units are redeemed and the New Units are issued. Any such exchange is treated as a redemption and sale. Unitholders must provide written instructions to convert or switch holdings to the ACS Manager which, in the case of joint U nitholders, must be signed by all joint U nitholders before a conversion or switch is e ffected . Conversions and switches are subject to the M inimum I nvestment and eligibility requirements. No conversion or switch will be made during any period when the right of U nitholders to require a redemption of U nits is suspended. A switch between the relevant Sub - Fund and another Sub - Fund of the Scheme will only be effected on a Business Day when both Sub - Funds have Valuation Points and such Business Day is a Dealing Day . Unitholders subject to UK tax should note that a switch of U nits between Sub - Funds (but not between Unit Class es in the same Sub - Fund) should be treated as a disposal for the purposes of Capital Gains Tax. Conversions between different Unit Class es in the same Sub - Fund should not give rise to a disposal for UK Capital Gains Tax purposes. Conversions between different Unit Classes in the same Sub - Fund may , however, be treated as a disposal for UK capital gains tax purposes if the Unit Classes have different hedging arrangements . Unitholders should seek their own professional tax advice in this regard. A U nitholder who switches U nits in one Sub - Fund for U nits in any other Sub - Fund will not be given a right by law to withdraw from or cancel the transaction.
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(j) Mandatory redemption or cancellation of Units The ACS Manager may from time to time take such action and impose such restrictions as it thinks necessary for the purpose of ensuring that no Units in any Sub - Fund are acquired or held by any person in circumstances (" relevant circumstances ") which constitute a breach of the law or governmental regulation (or any interpretation of a law or regulation by a competent authority) of any country or territory; or which would (or would if other Units were acquired or held in like circumstances) result in any Sub - Fund incurring any liability to taxation 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); and, in this connection, th e ACS Manager may reject at its discretion any subscription, redemption , switch or conversion of Units . In particular, all Unitholders must meet the eligibilit y criteria set out in section 2 . All US residents and citizens should note the requirements of the Foreign Account Tax Compliance Act ('FATCA'), please see section 27(f) . If it comes to the notice of the ACS Manager that any Units (" affected Units ") have been acquired or are being held in each case whether beneficially or otherwise in any of the relevant circumstances referred to above or if it reasonably believes this to be the case the ACS Manager may give notice to the relevant Unitholder to convert or switch their holding to another Unit Class or Sub - Fund if a suitable Unit Class or Sub Fund is available (and, in the case of a switch, subject to the basis on which switching rights are offered) or give notice to the relevant holder of the affected Units requiring the Unitholder to provide a request in writing for the redemption or cancellation of such Units . If any person upon whom such a notice is served does not within thirty days after the date of such notice request the conversion or switch of their holding of affected Units to another Unit Class or Sub - Fund if a suitable Unit Class or Sub - Fund is available (and, in the case of a switch, subject to the basis on which switching rights are offered) , or submit such request for redemption or cancellation of the affected Units, or establish to the satisfaction of the ACS Manager (whose judgement shall be final and binding) that he and any person on whose behalf he holds the affected Units are qualified and entitled to hold the Units, he shall be deemed upon the expiration of that thirty day period to have given a request in writing for the redemption or cancellation (at the discretion of the ACS Manager) of the affected Units.
(k) Transfers of Units A transfer of Units is not permitted . 14. Excessive Trading Policy The Sub - Funds do not knowingly allow investments that are associated with excessive trading practices as such practices may adversely affect the interests of all Unitholders . Excessive trading includes individuals or
groups of individuals whose securities transactions seem to follow a timing pattern or are characterised by excessively frequent or large trades. Unitholders should, however, be aware that the Sub Funds may be utilised by certain Unitholder s for asset allocation purposes or by structured product providers, which may require the periodic re - allocation of assets between Sub - Funds. This activity will not normally be classed as excessive trading unless the activity becomes, in the opinion of the ACS Manager, too frequent or appears to follow a timing pattern. As well as the general power of the ACS Manager to refuse subscriptions , switches or conversions at their discretion, powers exist in other sections of this Prospectus to ensure that Unitholder interests are protected against excessive trading. These include in specie redemptions (see section 13(g) ) and conversion and switching rights (see section 13 ( i ) ) . In addition, where excessive trading is suspected, the Sub - Funds may : combine Units that are under common ownership or control for the purposes of ascertaining whether an individual or a group of individuals can be deemed to be involved in excessive trading practices. Accordingly, the ACS Manager reserves the right to reject any applicat ion for switches, conversions, and subscription of Units from Unitholder s whom they consider to be excessive traders; and (i) levy a redemption charge o n the redemption proceeds to Unitholders whom the ACS Manager, in its reasonable opinion, suspects of excessive trading. This charge will be made for the benefit of the relevant Sub - Fund, and affected Unitholders will be notified in their contract notes if such a fee has been charged. T he charge will be calculated by using the trading costs including the asset spread cost . 15. Compliance with applicable laws and regulations As a result of any applicable laws and regulations, including but not limited to, relevant anti - money laundering legislation, tax laws and regulatory requirements, Unitholders may be required, in certain circumstances, to provide additional documentation to confirm their identity, or provide other relevant information pursuant to such laws and regulations, as may be required from time to time, even if an existing Unitholder . Any information provided by Unitholders will be used only for the purposes of compliance with these requirements and all documentation will be duly returned to the relevant Unitholder . Until the ACS Manager receives the requested documentation or additional information, there may be a delay in processing any subsequent redemption request and the ACS Manager reserves the right in all cases to withhold redemption proceeds until such a time as the required documentation or additional information is received.
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Alternatively, the ACS Manager may employ a search of electronic data reference sources in order to access information held electronically concerning the identity of a Unitholder , including information held by certain government and consumer agencies . By completing the F orm , Power of Attorney or Investor Agreement or entering into a contract with the ACS Manager or one of its affiliates, U nitholders acknowledge that the ACS Manager may at any time initiate a search of information held electronically in order to verify identity.
16. Valuation The ACS Manager calculates the value of the Units in accordance with Appendix 4, as permitted by the COLL Sourcebook . The basis of the calculation is the value of the underlying assets of the Scheme . Assets are valued on a single mid - market basis in accordance with the COLL Sourcebook. The valuation is performed at the Valuation Point and the function is performed by the ACS Manager in accordance with the COLL Sourcebook and the FUND Sourcebook . The Valuation Point of each Sub - Fund is set out in Appendix 1 . Details and description of the applicable valuation procedures are contained in Appendix 7 . T he ACS Manager may at its discretion implement fair value pricing policies in respect of any of the Sub Funds . Fair value pricing will only apply where the ACS Manager deems it to be appropriate and in the interests of Unitholders and 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 a security at the Valuation Point . In these circumstances the ACS Manager may at its discretion value an investment at a price which, in its opinion, reflects a fair and reasonable price for that investment . Circumstances which may give rise to a fair value price being used include instances where there is no recent trade in the investment concerned; or the occurrence of a significant event since the most recent price has been determined . A significant event is one that means, in the ACS Manager's judgement, it no longer has confidence in the most recent price of an investment, including in the case of a security or a basket of securities , that price 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 determined trigger levels which take into account the materiality of any variance . When determining such fair value, one or more of a variety of fair valuation methodologies may be used (depending on factors including the asset type). For example, the asset may be priced on the basis of the original cost of the investment or, alternative ly, using proprietary or third party models (including models that rely upon direct portfolio management pricing inputs and which reflect the significance attributed to the various factors and assumptions being considered). Prices of actual, executed or hi storical transactions in
the relevant asset and/or liability (or related or comparable assets and/or liabilities) or, where appropriate, an appraisal by a third party experienced in the valuation of similar assets and/or liabilities, may also be used as a basis for establishing th e fair value of an asset or liability. Where an adjustment is made as per the foregoing, it will be applied consistently to all class es of Units within the same Sub - Fund. At a Valuation Point the ACS Manager will calculate Unit prices, using the most recent prices of the underlying securities that it can reasonably obtain . The objective is to give an accurate value of the Sub - Fund as at the Valuation Point . The Base Currency of each Sub - Fund is sterling with the exception of the Aviva Investors Emerging Market Equity Core Fund which has a base currency of USD . In respect of the AI Money Market VNAV Fund (the “VNAV Fund”) only: The assets of the VNAV Fund shall be valued on a daily basis using mark - to market wherever possible. When using mark - to market : (a) the asset of the VNAV Fund shall be valued at the more prudent side of bid and offer unless the asset can be closed out at mid market; (b) only good quality market data shall be used; such data shall be assessed on the basis of all of the following factors: (i) the number and quali ty of the counterparties; (ii) the volume and turnover in the market of the asset of the VNAV Fund ; (iii) the issue size and the portion of the issue that the VNAV Fund plans to buy or sell. Where use of mark - to - market is not possible , or the market data is not of suffic ient quality, an asset of the VNAV Fund shall be valued conservatively by using mark - to - model. The model shall accurately estimate the in trinsic value of the asset of the VNAV Fund , based on all of the following up - to - date key factors: (a) the volume and turnover in the market of that asset; (b) the issue size and the portion of the issue that the VNAV Fund plans to buy or sell; (c) market risk, interest rate risk, credit risk attached to the asset. When using mark - to - model, the amortised c ost method shall not be used. V aluation s shall be communicated to the FCA . The VNAV Fund shall calculate the value of the assets of the VNAV Fund per unit as the difference between the sum of all assets of the VNAV Fund and the sum of all liabilities of the VNAV Fund valued in accordance with mark - to - market or mark - to - model, or both, divided by the number of outstanding units or shares of the VNAV Fund. The value of the assets of the VNAV Fund per unit or share shall be rounded to the nearest basis poin t.
17. Prices of Units and Historic Performance Data The ACS Manager will, on the completion of each valuation under section 16 , advise the Depositary of the subscription and redemption price s . These are the prices which the ACS Manager has to pay to the Depositary for the issue of Units or , the prices which
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the ACS Manager will receive from the Depositary upon the cancellation of Units . The actual cost of subscribing for or redeeming Units in a Sub - Fund may be higher or lower than the mid market value used in calculating the Unit price . The ACS Manager may swing the price up (or down) to protect Unitholders from the costs incurred by the Sub Fund as a result of issuing or cancelling Units . This particular method of arriving at the daily unit price is known as the swinging price method and it is this method which will be used by the ACS Manager. Further details are set out in Appendix 7 under the heading Determination of Unit Price . The ACS Manager may make an adjustment to the price for the purpose of reducing dilution in the S cheme or to recover any amount which it had already paid or reasonably expects to pay in the future in relation to the issue or cancellation of Units . Where the ACS Manager decides to make or not to make a dilution adjustment, it will not do so for the purpose of creating a profit or avoiding a loss for the account of an affected person. A dilution adjustment can be made when there is a net flow in or out of the S cheme. The rate of adjustment will not exceed the price of the Scheme valuation calculation based on either the buying prices or selling prices of the underlying securities. It is not possible to predict accurately whether dilution is likely to occur. However, the nature of the Unitholder base means that Unitholder purchases or redemptions are likely to be significant and it is therefore probable that there will be a dilution adjustment made to protect the remaining Unitholders in affected Sub - Funds. Historic performance data (where available) is shown in the individual Sub - Fund information in Appendix 1 of this Prospectus , Key Investor Information Document and fact sheet s that may be available from time to time . For up to date information visit the ACS Manager's website https://www.avivainvestors.com/en gb/institutional/fund - centre/tax - transparent.html or speak to its Client Relationship Management Team on 0207 809 8135 . Please do not take past performance as a guide to future performance. The value of your investment and any income you receive from it can go down as well as up. You may get back less than the amount you originally invested. The performance figures in Appendix 1 may not be the most up to date available. Please telephone the Client Relationship Management Team on 0207 809 8135 between 8:30am and 5: 30pm on any Dealing Day for the most recent information. * The performance of an index or other benchmark, where referred to in a Sub - Fund’s investment objective and policy is also shown in Appendix 1 . Source for all data for the period 1 January 202 4 to 31 December 202 4 is the ACS Manager. This is based on index provider data where applicable. Performance figures are based on net asset value, per the published accounts and are shown after charges.
Source for all data in subsequent periods: Aviva Investors/Lipper, Refinitiv Company, subject to the following: Copyright 2025 © Refinitiv. All rights reserved. Lipper shall not be liable for any errors or delays in the content, or for any actions taken in reliance thereon . This is based on index provider data where applicable. All performance figures are calculated based on the published price, with net income reinvested in GBP, net of fees. Further information in respect of income returns, tracking error and volatility (where applicable) is available on request from the ACS Manager. * Telephone calls may be recorded by the ACS Manager , its delegates, their duly appointed agents and any of their respective related, associated or affiliated companies for records keeping, security and/or training purposes, please see the paragraph “Telephone Recording” below for further information.
18. Policy on Pricing When Units are subscribed for , they will be issued on a forward pricing basis . The forward price will be calculated at the next Valuation Point after receipt of purchase instructions so long as these were received and accepted prior to the relevant Sub - Fund's D eal C ut - O ff Point (where applicable). When Units are redeemed , Units will be redeemed on a forward pricing basis . T he forward price will be calculated at the next Valuation Point following receipt of a redemption instruction so long as these were received and accepted prior to the relevant Sub - Fund's D eal C ut - O ff Point (where applicable).
19. Minimum Investment If following a redemption or switch a holding in any class of Unit should fall below the M inimum Investment for that class, as detailed in Appendix 1, the ACS Manager has the discretion to effect a redemption of a Unitholder ’ s entire holding in that class of Unit . The ACS Manager will not be obliged to redeem Units if the number or value of the Units sought to be sold would result in the Unit holder holding less than any Minimum Investment stated in Appendix 1 as the minimum number or value of Units of the Unit C lass concerned that may be held. Minimum I nvestment s may be waived at the ACS Manager's discretion.
20. ACS Manager's B ox I t is not the ACS Manager's policy as at the date of this Prospectus to run a "box" (i.e. hold Units in the Sub Funds in its own accounts) . 21. Publication of Prices and Y ields Daily prices for each Sub - Fund will be made publicly available through the ACS Manager's website, https://www.avivainvestors.com/en gb/institutional/fund - centre/tax - transparent.html ,
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or by calling its Client Relationship Management Team on 0207 809 8135 . Please note that the published prices are for information only and these prices may not be the prices obtained when Units are dealt . Please refer to section 16 for additional information. Telephone calls may be recorded by the ACS Manager , its delegates, their duly appointed agents and any of their respective related, associated or affiliated companies for records keeping, security and/or training purposes, please see the paragraph “Telephone Recording” below for further information. The Units in the Sub - Funds of the Scheme are not listed or dealt in or on any investment exchange.
22. Classes of Units The classes of Units currently available in each Sub Fund are set out in Appendix 1 . Each type of Unit represents a beneficial interest in undivided shares in the property of the Scheme as detailed below . Each Unit represents one undivided share in the property of the relevant Sub - Fund . Each undivided Unit ranks pari passu with other undivided Units in a Sub - Fund . The nature of the rights represented by Units is that of a beneficial interest as tenants in common on the terms of the ACS Deed . Unitholders are not liable for the debts of a Sub - Fund . The property of a Sub - Fund must not be used to discharge any liabilities of, or meet any claims against, any person other than the Unitholders in that Sub - Fund. Where Accumulation Units are held, any income arising in respect of an Accumulation Unit is automatically accumulated and is reflected in the price of each Accumulation Unit . Allocation of income in respect of Accumulation Units will be transferred to the capital property of the relevant Sub - Fund within 2 months of the end of the Annual Accounting Period to which that income relates, but will be reflected in the capital value o f Accumulation Units on the first business day following the end of that Annual Accounting Period . Where Income Distribution Units are held, relevant Unitholders will receive a net distribution payable according to the distribution details of the relevant Sub Fund , which are set out in Appendix 1 . This distribution will be automatically reinvested into the relevant Sub Fund and additional Units will be allocated to each relevant Unitholder unless the Unitholder agrees with the ACS Manager that the distribution is paid directly into its bank account . This net distribution is calculate d for each Unitholder as a proportion of the income, less expenses and any taxation due, received by the Sub Fund on behalf of each Unitholder . After a period of six years from the date of payment, any unclaimed distribution will be added to the capital property of the Sub - Fund and may be forfeited. No interest will be paid on unclaimed distribution monies. Where both Income Distribution Units and Accumulation Units are in existence in relation to a Sub - Fund, the relevant Unitholders’ proportionate interests in the S cheme p roperty of the Sub - Fund represented by each Accumulation Unit increases as income is accumulated. Further, in these
circumstances, the income of the Sub - Fund is allocated between Income Distribution Units and Accumulation Units according to the relevant Unitholders’ proportionate interests in the S cheme p roperty of the Sub - Fund represented by the Accumulation Units and Income Distribution Units in existence at the end of the relevant d istribution p eriod. The ACS Deed of the Scheme also permits further classes of Units to be made available other than those currently available . Any such class of Unit may vary according to whether it accumulates or distributes income or attracts different fees and expenses, and as a result of this, monies may be deducted from classes in unequal proportions . In these circumstances, the proportionate interests of the classes of Units within a Sub - Fund will be adjusted in accordance with the provisions of the ACS Deed relating to proportion accounts . The Depositary may create one or more classes of Units as instructed from time to time by the ACS Manager . The creation of additional Unit Class es will not result in any material prejudice to the interests of holders of Units in existing Unit Class es.
23. Evidence of Title No certificates are issued in respect of the Units . Should any Unitholder , for any reason, require evidence of his title to Units , the ACS Manager shall, upon such Unitholder proof of identity as it shall reasonably require, supply the relevant Unitholder with a certified copy of the relevant entry in the Register relating to their holding of Units . 24. Investment Objective s and Policy, and Investment Restrictions
(a) General The investment objective s and policy of each Sub Fund is set out in Appendix 1 . In pursuing its investment objective and policy, each Sub - Fund may use the techniques referenced in Appendix 1 , Appendix 6 and in the risk factors set out in section 26 . Other techniques, however, may be developed or determined to be suitable for use by a Sub - Fund and the ACS Manager may (subject to applicable law) employ such techniques in accordance with that Sub - Fund's investment objective s and policy. The definitions ‘primarily’ and ‘predominantly’ used in Appendix 1 of this Prospectus follow the guidelines provided by the Depositary and Trustee Association research paper of March 2009 and as such indicate that at least a certain percentage of the assets of the Sub - Fund will be invested in the specified securities . Reference to ‘primarily’ is 70%, and ‘ predominantly ’ is 80% . These percentages have been discussed and agreed with the Investment Managers. For those investment objectives in which the term ‘listed in the UK’ is stated, this means investments in companies which are domiciled in the UK , or that have a significant proportion of their business in the UK . Such companies may not necessarily form pa rt of the FTSE All Share Index.
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The investment objectives and/ or policy of a Sub - Fund may be amended in accordance with the change classification process set out in the COLL Sourcebook. See sectio n 31 for further details. The investment restrictions applicable to a particular Sub - Fund are set out in Appendix 1 . The investment restrictions set out in Appendix 6 apply to all Sub Funds . (b) Securities Financing Transactions and TRS (i) Securities lending Securities lending is an arrangement where the Scheme or the Depositary delivers securities which are the subject of the transaction in return for which it is agreed that securities of the same kind and amount be redelivered to the Scheme or the Depositary at a later date. The Scheme or the Depositary at the time of delivery receives collateral to cover against the risk of the future redelivery not being completed. With the exception of the AI Money Market VNAV Fund , all Sub - Funds participate in securities lending, consequently, the disclosures made below, under Article 14 of the Securities Financing Transaction Regulations, have been made only in relation to those Sub - Funds participating in securities lending . With the exception of the AI Money Market VNAV Fund, t he Sub - Fund s are permitted to enter into securities lending arrangements for the purposes of efficient portfolio management . Appendix 1 sets out for each Sub - Fund participating in securities lending:
• the types of asset that will be subject to securities lending . • the maximum proportion of assets which may be subject to securities lending . • the expected proportion of assets which may be subject to securities lending . All counterparties must meet the requirements of the COLL Sourcebook in respect of their authorisation, supervision or registration. Counterparties must also meet certain criteria bas ed upon the Securities Lending Agent’s Credit Evaluation and Approval process . There are no requirements based on legal status or country of origin but the counterparty must be domiciled in jurisdictions where the relevant legal documentation is enforceable. Collateral will meet the requirements of the COLL Sourcebook and will be limited to c ash, g overnment and supranational issued collateral restricted to issuers located in certain jurisdictions , equities listed on certain indices or markets (agreed between the ACS Manager, the Depositary and the Securities Lending Agent and set out in the s ecurities l ending a uthorisation a greement entered into between them (“ Securities Lending Authorisation Agreement ”)) (including depositary receipts) and exchange traded
funds listed on major global regulated markets or a multilateral trading facility. Collateral must be liquid (as set out in the COLL Sourcebook ). No additional liquidity or maturity limits (beyond limits on the type of collateral accepted) are applied in relation to collateral received . Collateral will be issued by the counterparty in line with the requirements of the COLL Sourcebook . The Securities Lending Agent will not accept any securities issued by Aviva Plc or the Securities Lending Agent, or their respective affiliated companies, and will also not accept collateral where the issuer is a related party of the counterparty . Collateral will adequately cover securities lent under any Securities Lending Transactions and will continue to be adequate only if its value is at all times at least equal to the value of the securities transferred by the Securities Lending Agent. The collateral received is valued daily on a mark - to market basis. As the types of collater al accepted are liquid with publicly available prices, a mark - to - market basis gives the best valuation. A haircut (a deduction to the valuation) is applied to the value of the collateral depending on the type of collateral received and positions will be su bject to daily variation margin requirements. All transactions are governed by industry standard documentation. The assets that may be subject to securities lending and a ll collateral received is held under the control of the Depositary for the benefit of the underlying Sub - Fund. Collateral may not be re - used , sold, re - invested or pledged by the Securities Lending Agent unless agreed by the ACS Manager. C ash collateral investment or reinvestment is not permitted , save that cash collateral can be re - invested by way of a repo contract . Any income generated from stock lending will be allocated between the relevant Sub - Fund and the Securities Lending Agent . For each Sub - Fund operating securities lending, the Securities Lending agent is permitted to deduct a monthly fee equating to 20 per cent of the Securities Lending income generated for that Sub - F und. The fee will be charged to the relevant Sub - Fund each month in respect of the Securities Lending activity from the preceding month. No Securities Lending Agent fee will be deducted from the Scheme Property if no revenue from securities lending activity has been generated in the preceding month. No additional fee will be charged by the AC S Manager . (ii) TRS A TRS is a swap agreement in which one party makes payments based on a set rate, either fixed or variable, while the other party makes payments based on the return of an underlying asset. T he AI Balanced Pension Fund, AI Balanced Life Fund and AI Cautious Pension Fund are permitted to use TRS for investment purposes, or for efficient portfolio management, or to reduce risk. The Core Funds are permitted to use TRS
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for efficient portfolio management , or to reduce risk . TRS may be used to gain exposure to asset class sectors or strategies that the Investment Manager believes that they cannot access effectively through physical securities or exchange - traded derivatives such as futures contracts. Please refer to Appendix 1 which sets out for each of these Sub - Funds:
• The types of assets which may be subject to TRS
• the maximum proportion of assets which may be subject to TRS
• the expected proportion of assets which may be subject to TRS Accordingly , the disclosures made below under Article 14 of the Securities Financing Transaction Regulations have been made only in respect of the Sub - Funds permitted to use TRS as listed above . All counterparties must meet certain criteria based upon their credit rating , and Schroders usually transacts TRS with counterparties with a minimum rating of BBB or equivalent. There are no requirements based on legal status or country of origin , but the counterparty must be domiciled in jurisdictions where the relevant legal documentation is enforceable. Collateral is limited to UK Government debt and cash. No liquidity limits (beyond limits on the type of collateral accepted) are applied in relation to collateral received . H owever , maturity limits are applied in relation to the collateral received across the selection of counterparties available, this will range from 50 years to no maturity . Collateral will be issued by an entity independent from the counterparty and is not expected to display a high correlation with the performance of the counterparty. Collateral will be sufficiently diversified in terms of UK Government Debt issues . The collateral received is valued daily on a mark - to market basis. As the types of collater al accepted are liquid with publicly available prices, a mark - to - market basis gives the best valuation. A haircut (a deduction to the valuation) is applied to the value of the collateral depending on the type of collateral received and positions will be su bject to daily variation margin requirements. All transactions are governed by industry standard documentation, which currently provides for the title transfer of collateral securities. The assets that may be subject to TRS and a ll collatera l received is held under the control of the Depositary for the benefit of the underlying Sub - Fund.
Neither security or cash collateral will be reused or reinvested.
The whole of any returns generated are credited to the relevant Sub - Fund and no costs or fees are assigned to the ACS Manager or third parties. (iii) Repo contracts
A repo contract is an agreement between a seller and a buyer for the purchase or sale of securities, in exchange for cash , where the buyer agrees to resell the securities or equivalent securities, at an agreed date and, usually, at a stated price. With the exception of the AI Money Market VNAV Fund, all Sub - Funds may enter in repo contracts , consequently, the disclosures made below, under Article 14 of the Securities Financing Transaction Regulations, have been made only in relation to those Sub - Funds entering in to repo contracts. With the exception of the AI Money Market VNAV Fund, t he Sub - Fund s are permitted to enter into repo contracts for the purposes of efficient portfolio management . Appendix 1 sets out for each Sub - Fund entering in to repo contracts :
• the types of asset that will be the subject of a repo contract . • the maximum proportion of assets which may be the subject of a repo contract . • the expected proportion of assets which may be the subject of a repo contract . All counterparties must meet the requirements of the COLL Sourcebook in respect of their authorisation, supervision or registration. Counterparties must also meet certain criteria based upon the Securities Lending Agent ’ s Credit Evaluation and Approval process . There are no requirements based on legal status or country of origin but the counterparty must be domiciled in jurisdictions where the relevant legal documentation is enforceable. Any c ollateral received in relation to a Sub - Fund will meet the requirements of the COLL Sourcebook and will be limited to government and supranational issued collateral restricted to issuers located in certain jurisdictions , equities listed on certain indices or markets (agreed between the ACS Manager, the Depositary and the Securities Lending Agent and set out in the S ecurities L ending A uthorisation A greement ) (including depositary receipts) and exchange traded funds listed on major global regulated markets or a multilateral trading facility . Collateral received must be liquid (as set out in the COLL Sourcebook ). No additional liquidity or maturity limits (beyond limits on the type of collateral accepted) are applied in relation to collateral received . Collateral received on behalf of the Sub - Funds will be issued by the counterparty in line with the requirements of the COLL Sourcebook . The Securities Lending Agent will not accept any securities issued by Aviva Plc or the Securities Lending Agent, or their respective affiliated companies , and will also not accept collateral where the issuer is a related party of the counterparty . Collateral will need to be adequate in accordance with the COLL Sourcebook .
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Any collateral received is valued daily on a mark - to market basis. As the types of collater al accepted are liquid with publicly available prices, a mark - to - market basis gives the best valuation. A haircut (a deduction to the valuation) is applied to the value of the collateral depending on the type of collateral received and positions will be su bject to daily variation margin requirements. All transactions are governed by industry standard documentation. The assets (including cash) that may be the subject of repo contracts are held under the control of the Depositary for the benefit of the underlying Sub - Fund. Collateral may not be re - used , sold, re - invested or pledged by the Securities Lending Agent unless agreed by the ACS Manager. The Securities Lending Agent shall retain 20% of any income and earnings from the investment and reinvestment of any cash c ollateral minus broker rebate fees paid by the Securities Lending Agent to the relevant counterparty . 25. Leverage Ratios The maximum level of leverage which a Sub - Fund, or the ACS Manager on that Sub - Fund’s behalf, is permitted to use as part of such Sub - Fund’s in vestment strategy is set out in Appendix 1 . As required by the UK AIFM Regime , leverage is expressed as a ratio between a Sub - Fund’s total exposure and its net asset value. The generic example s below d emonstrate the UK AIFM Regime prescribed methodologies that must be used for calculating such leverage ratios. If a Sub - F und were to have 8 0% physical holding in direct investments , 20% exposure to index futures, 3 0% forward FX (used to hedge) and 2 0% cash, in accordance with the UK AIFM Regime such Sub F und’s leverage would be expressed as follows:
• using the c ommitment methodology, a ratio of 1.2:1 , w here 1.2 represents this Sub - F und ’s exposure to direct investments , index futures and cash; pursuant to the UK AIFM Regime forward FX used for hedging can be netted against a fund’s foreign currency exposure; • using the gross methodology, a ratio of 1 .3 :1, where 1 .3 represents this Sub - F und ’s exposure to direct investments , index futures and forward FX; pursuant to the UK AIFM Regime cash is excluded from the gross method of calculation whereas forward FX used for hedging cannot be netted . As demonstrated above, the expression of 1 .2 :1 does comprise “Incremental Exposure” through the use of derivatives , and the Sub - F und ’s holdings in direct investments are also included . The exposure is calculated in accordance with the methodologies expressly set out in the UK AIFM Regime . If a Sub - F und were to have 100% in collective investment schemes, in accordance with the UK AIFM Regime such Sub - F und ’s leverage would be expressed as follows:
• using the commitment m ethodology , a ratio of 1:1, where 1 represents this Sub - F und ’s exposure to direct investments ; and • u sing the g ross m ethodology , a ratio of 1:1, where 1 represents this Sub - F und ’s exposure to direct investments . In this example , although the Sub - F und is not subject to Incremental Exposure , the leverage ratios are above zero due to the exposure calculation being performed in accordance with the methodologies expressly set out in the UK AIFM Regime . 26. Risk Considerations Potential Unitholder s should consider the risk factors below before investing in the Scheme (or, in the case of specific risks applying to specific Sub - Funds, in those Sub - Funds). This list must not be taken to be comprehensive. It should also be noted that there may be new risks that arise in the future which could not have been anticipated in advance. Also, risk factors listed will apply to different Sub - Funds to different degrees, and for a given Sub - Fund this degree could increase or reduce through time. Unitholders will need to decide whether or not an investment in a Sub - Fund is appropriate for their requirements. Some of the risk factors below relate to the underlying collective investment schemes (" underlying fund ") in which the Sub - Funds invest but for that reason are also relevant to the Sub - Funds themselves.
(a) General Investment Risks T he Sub - Funds are subject to fluctuations in capital value of their underlying investments which can be influenced by factors such as political and economic news, corporate earnings reports, demographic trends and catastrophic events . The ACS Manager cannot guarantee that it will achieve the objectives set out for any Sub - Fund and in any particular period losses may be suffered . It is important for Unitholders to note that past performance is not a guide to future performance or growth . Unitholders should always bear in mind that the price of Units in any Sub - Fund and the income from them can go down as well as up and are not guaranteed. Unitholders may receive back less than the original amount invested . An investment in a Sub - Fund is not intended to be a complete investment programme. Where cancellation rights apply to a contract any Unitholder exercising such cancellation rights will not obtain a full refun d of the money paid on the making of the contract if the value of the investment falls before the cancellation notice is received by the ACS Manager as an amount equal to that fall will be deducted from any refund made to the Unitholder . An investment in a Sub - Fund is not protected against the effects of inflation. Inflation will reduce the purchasing power of the money when an investment is redeemed. (i) Accumulation of Fees/Expenses
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As the Sub - Funds of the Scheme may invest in underlying funds, the Unitholders may incur a duplication of fees (such as management fees, custody and transaction fees, other administration fees and audit fees). To the extent these underlying funds are permitted to invest in turn in other funds, Unitholders may incur additional fees. (ii) Charges from C apital Fees, costs and duties which are charged to each Sub Fund may be treated as a capital expense . Whilst this might allow more income to be distributed, it may also result in capital erosion or constrain capital growth . Please note that the ACS Manager does not consider that Unitholders seeking capital growth w ill be affected by such a policy, as the income distributed will be automatic ally reinvested on their behalf . (iii) Counterparty Risk See also ‘Credit Risk’. The bankruptcy or default of any counterparty could result in losses to any Sub - Fund. In addition, a Sub - Fund may bear the risk of loss because a counterparty does not have the legal capacity to enter into a transaction, or if the transaction becomes unenforceable due to relevant legislation or regulation (see ‘Legal and Regulatory Risk’). In the case of any insolvency or failure of any such party, a Sub - Fund might recover only a pro rata share of all property available for distribution to all of such party’s creditors and/or customers. Such an amount may be less than the amounts owed to that Sub - Fund. Trading in financial derivative instruments which have not been collateralised gives rise to direct counterparty exposure. A Sub - Fund might mitigate much of this risk by receiving collateral with a value at least equal to the exposure to each counterparty but, to the extent that any financial derivative instrument is not fully collateralised or, to the extent the Sub - Fund has provided collateral to the counterparty under a SFT in excess of the termination value of the underlying contract , a default by the counterparty may result in a reduction in the value of a Sub - Fund. In the event of the insolvency of the counterparty to a derivative, the Sub - Fund of the Scheme will be treated as a general creditor of such counterparty and will not have any claim with respect to the underlying indebtedness. Consequently, that Sub - Fund of the Scheme will be subject to the credit risk of the counterparty as well as that of the issuer of the indebtedness. As a result, concentrations of derivatives in any one counterparty may subject a Sub - Fund to an additional degree of risk with respect to defaults by such counterparty as well as by the issuer of the underlying indebtedness. To mitigate counterparty risk the Scheme will only use preferred counterparties which it believes to be creditworthy and may reduce the exposure incurred in connection with such transactions through the use of letter of credit or collateral. A formal review of each new counterparty is completed and all approved counterparties regularly assessed . However there can be no guarantee that a counterparty will not default or that a Sub - Fund of the Scheme will not sustain losses as a result.
The ACS Manager is free to use one or more separate counterparties for derivative investments . Some or all of these counterparties may be associates of the Aviva Group . (iv) Credit Risk See also ‘Counterparty Risk’. Credit risk is the risk that the counterparty to a financial instrument will fail to discharge an obligation. Each Sub - Fund will be exposed to a credit risk for the parties with whom it trades. Investing in sovereign debt, any other debt guaranteed by a sovereign government, or corporate debt entails risks related to the issuer’s ability and willingness to repay principal and pay interest. A default by the issuer of the bond may impact the value of a Sub - Fund. Short - term cash equivalent investments, such as commercial paper, bankers’ acceptances, certificates of deposit, and repurchase transactions, are not guaranteed by any government and are subject to some risk of default. Credit risk may also arise through a default by one or several large institutions that are dependent on one another to meet their liquidity or operational needs, so that a default by one institution causes a series of defaults by the other institutions. Th is is sometimes referred to as a "systemic risk" and may adversely affect financial intermediaries, such as clearing agencies, clearing houses, banks, securities firms and exchanges, with which the Scheme interacts on a daily basis. (v) Determination of Unit Prices Where a Sub - Fund invests all or a proportion of its assets in underlying funds, an equivalent proportion of the value of the Sub - Fund and hence the issue and redemption price of the Units , will be based on the latest prices that are available for the investments held by the underlying funds. These latest prices may be estimated prices due to either the frequency or the timing of dealing in the investment vehicles in which the underlying fu nds are invested or the time that is required by the administrators of such investment vehicles to calculate final prices. Consequently, the value of the Sub - Fund and hence the issue and redemption prices of the Units , may not accurately reflect the value that would have been received by the Sub - Fund had that holding been realised on that day. The underlying funds may invest in investment vehicles which do not permit holdings to be redeemed on either as frequent a basis as that applying to the Sub - Funds or on the same day as the Sub - Funds. In the absence of published current redemption prices or net asset values the ACS Manager may have to determine valuations in respect of such investments. Adequate information may not always be available to the ACS Manager or the Investment Manager s from underlying funds or other sources for that purpose and consequently such valuations may not accurately reflect the realisable value of the Sub - Funds’ holdings on the next dealing day of the underlying fund concerned or the value that would have been received by the Sub - Funds had those holdings been realised on that day.
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 23
(vi) Fund Liability Risk The Scheme is structured as an umbrella co ownership Scheme with segregated liability between its Sub - Funds. The assets of one Sub - Fund will not be available to meet the liabilities of another. However, the S cheme (through the ACS Manager) may operate or have assets held on its behalf or be subject to claims in the UK, or in other jurisdictions, whose courts may not necessarily recognise such segregation of liability. Therefore, it is not possible to be certain that the assets of a Sub - Fund will always be completely isolated from the liabilities of another Sub - Fund of the Scheme in every circumstance. (vii) Currency Risk and Interest Rate Risk The n et a sset v alue per Unit of a Sub - Fund will be co mputed in the Base Currency of the relevant Sub Fund whereas the investments held for the account of that Sub - Fund may be acquired in other currencies. The value in terms of the Base Currency of a Sub Fund, where designated in a currency different to that of the currencies of the underlying investments , may rise and fall due to currency exchange rate fluctuations of individual currencies, such that the net asset value of a Sub - Fund will change in response to such fluctuations. Adverse movements in currency exchange rates can result in a decrease in return and a loss of capital separately from gains or losses otherwise made by such investments . The performance of investments in securities denominated in a specific currency will also depend on the interest rate environment in the country issuing the security . Except to the extent that values are independently affected by currency exchange rate fluctuations, when interest rates decline, the value of fixed income securities generally can be expected to rise. Conversely, when interest rates rise, the value of fixe d income securities generally can be expected to decline. (viii) Leverage A Sub - Fund may be able to use leverage, including through use of derivative instruments, in accordance with its investment objective and strategy as set out in Appendix 1 and subject to the investment restrictions set out in Appendix 6 . Leverage will generally be generated by using derivatives that are inherently leveraged due to the relatively small amount of deposit required to open a position, including among others, forward contracts, futures contracts , options and swaps. A relatively small market movement may therefore have a potentially larger impact on derivatives than on standard bonds or equities, with the result that leveraged derivative positions may increase Sub - Fund volatility. The Sub - Funds may have higher levels of leverage in atypical or volatile market conditions, for example when there are sudden movements in investment prices due to difficult economic conditions in a sector or region. In such circumstances, the ACS Manager or its delegate may increase its use of derivatives in a Sub - Fund in order to reduce the market risk to which
that Sub - Fund is exposed, this, in turn, would have the effect of increasing its levels of leverage. Leverage may also take the fo rm of trading on margin, which will result in interest charges and, depending on the amount of trading activity, such charges could be substantial. The level of interest rates generally, and the rates at which a Sub - Fund can borrow in particular, will affect the operating results of that Sub - Fund. In general, the anticipated use of short - term margin borrowings may result in certain additional risks to the Sub - Funds. For example, should the securities pledged to brokers to secure a Sub - Fund's margin accounts decline in value, a Sub - Fund could be subject to a “margin call”, pursuant to which a Sub Fund must either deposit additional funds or securities with the broker, or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. In the event of a sudden drop in the value of a Sub - Fund's assets, a Sub - Fund might not be able to liquidate assets quickly enough to pay off its margin debt. Whether any margin deposit will be required for OTC options and other OTC instruments, such as currency forwards, swaps and certain other derivative instruments, will depend on the credit determinations and specific agreements of the parties to the transaction, which are individually negotiated. Low margin deposits are indicative of the fact that any trading in certain derivatives markets is typically accompanied by a high degree of leverage. Low margin deposits mean that a relatively small adverse price movement in a contract may result in immediate and su bstantial losses to the Unitholder . For example, if at the time of purchase 10% of the price of a futures contract is deposited as margin, a 10% decrease in the price of the futures contract would, if the contract is then closed out, result in a total loss of the value of margin deposit before any deduction for the brokerage commission. Thus, like other leveraged investments, any purchase or sale of a futures contract, forward or other derivatives may result in losses in excess of the amount invested. Any investment income and gains earned on investments made through the use of leverage that are in excess of the interest costs associated therewith may cause the n et asset value of the Units in a Sub Fund to increase more rapidly than would otherwise be the case. Conversely, where the associated interest costs are greater than such income and gains, the n et a sset value of the Units in a Sub - Fund may decrease more rapidly than would otherwise be the case. Any event which adversely affects the value of an investment made by a Sub - Fund would be magnified to the extent that Sub - Fund is leveraged. (ix) Liquidity Risk Liquidity risk exists when the sale of assets or exit of trading positions is impaired by such factors as decreased trading volume, increased price volatility, industry and government regulations, and overall position size and complexity. It may be impossi ble or costly for a Sub - Fund to liquidate positions rapidly particularly if there are other market participants seeking to dispose of similar assets at the same time
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 24
or the relevant market is otherwise moving against a position or in the event of trading halts or daily price movement limits on the market or otherwise. Derivative transactions that are particularly large or traded off market (i.e. over the counter) and b onds traded in the secondary market or collateral or securities which has been received by a Sub - Fund under a SFT may be less liquid and it may be difficult to achieve fair value on transactions (see ‘Valuation Risk’). Closing positions held in the secondary markets prematurely, for instance to meet client redemption requests, can result in increased transaction costs which will be reflected in the investment returns. (x) Legal and Regulatory Risk Legal, tax and regulatory changes could occur during the term of a Sub - Fund. Over recent years global financial markets have undergone pervasive and fundamental disruption and regulators in many jurisdictions have implemented or proposed a number of regulatory measures and may continue to do so. For example, the regulatory and tax environment for derivative instruments is evolving, and changes in the regulation or taxation of derivative instruments may adversely affect the value of derivative instruments held by a Sub - Fund and the ability of a Sub - Fund to pursue its trading strategies. Further, legislation and regulation may render a transaction, to which a Sub - Fund is a party, void or unenforceable. These interventions have sometimes been unclear in scope and application, resulting in confusion and uncertainty which in itself has been detrimental to the efficient functioning of financial markets. It is impossible to predict with certainty what additio nal interim or permanent governmental restrictions may be imposed in the future and/or the effect of such restrictions on global markets and the ACS Manager's ability to implement a Sub - Fund’s investment objectives . (xi) Market Risk The price of a Sub - Fund’s investments, including, without limitation, fixed income securities, equities and all derivative instruments, can be highly volatile. Price movements of fixed income securities, equities, forward contracts, derivatives contracts and other instrument s in which a Sub - Fund’s assets may be invested are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies (see ‘Legal and Regulatory Risk’). Such intervention often is intended directly to influence prices and may, together with other factors , cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations (see ‘Currency Risk and Interest Rate Risk ’). (xii) New Issues Sub - Funds may invest indirectly via an underlying fund or directly in initial public offerings or new debt issues.
The prices of securities involved in initial public offerings or new debt issues are often subject to greater and more unpredictable price changes than more established securities. (xiii) Settlement Risk Settlement risk is the risk that a counterparty fails to deliver the terms of a contract (i.e. defaults at settlement) and of any timing differences in settlement between the two parties. Each Sub - Fund bears the risk of settlement default due to exposure to the risk of default of certain counterparties (see ‘Credit Risk’ and ‘Counterparty Risk’). In addition, market practices in relation to the settlement of transactions and the custody of assets co uld provide increased risks (see also ‘Market Risk’ and ‘Legal and Regulatory Risk’). (xiv) Tax The information provided in section 27 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 - Funds, 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 in UK or in any jurisdiction where a Sub - Fund is registered, marketed or invested could affect the tax status of the Sub - Funds, 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 o bjective, and/or alter the post - tax returns to Unitholders . Where the 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 derivative. The availability and value of any tax reliefs available to Unitholders depend on the individual circumstances of Unitholders . The information in section 27 is not exhaustive and does not constitute legal or tax advice . Prospective Unitholder s are urged to consult their tax advisors 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, for example jurisdictions in the Middle East, the relevant Sub - Fund, the ACS Manager, the Investment Manager s , the Depositary and the A dministrator 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 other charges of the 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 (to the extent that there is no established best practice) 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 late filing penalties will likewise be chargeable to the Sub - Fund. Such late paid taxes will normally be
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 25
debited to the Sub - Fund at the point the decision to accrue the liability in the Sub - Fund accounts is made. (xv) Valuation Risk Financial instruments that are illiquid and/or not publicly traded may not have readily available prices and may therefore be difficult to value. Dealer supplied quotations or pricing models developed by third parties, the ACS Manager , its a ffiliates and/or delegates, may be utilised in valuations and the calculation of the net asset value of each Sub - Fund. Such methodologies may be based upon assumptions and estimates that are subject to error. Unitholder s should be aware that in these circumstances a possible conflict of interest may arise, as the higher the estimated valuation of the securities the higher the fees payable to the ACS Manager, Investment Manager s or the A dministrator. Any party providing valuation services may, in the absence of its negligence, be indemnified out of the property of the relevant Sub - Fund from all claims and losses which such party may incur directly or indirectly arising out of or in connection with the performance of such valuation services. In addition, given the nature of such investment, determinations as to their fair value may n ot represent the actual amount that will be realised upon the eventual disposal of such investments. (xvi) Suspension and Deferral of dealings In certain circumstances the right to redeem Units may be deferred or suspended (see the sections 13 ( f ) and 13 ( h ) ) . The Sub - Funds are open - ended; therefore , there may be a large amount of subscriptions or redemptions of Units during a short period of time. Large levels of redemption requests may cause a Sub - Fund to liquidate its investments over a shorter period than it would otherwise have taken in order to meet such redemption requests. This may affect the Net Asset Value of the Scheme Property and consequently the Net Asset Value per Unit may fall. (xvii) Delivery Versus Payment (“DvP”) Exemption The ACS Manager may apply the Delivery versus Payment (“DvP”) exemption for Unitholders that consent, as set out in the FCA Client Asset Rules (“CASS Rules”) governing the protection of client assets. Usually, when the ACS Manager receives Unitholders’ mon ey in the course of settling transactions the ACS Manager is obliged to handle money received or held in the course of or in connection with the issue or redemption of Units (“Client Money”) in accordance with the CASS Rules, which amongst other provisions require the ACS Manager to segregate Client Money from the assets of the ACS M anager. The DvP exemption provides for a one business day window during which Unitholders’ money held by the ACS Manager for the purposes of settling a transaction in Units is not treated as Client Money. In the event that the ACS Manager becomes insolvent or otherwise fails, there is a risk of loss or delay in the return of any Unitholders’ money held by th e ACS Manager which
is not treated as Client Money. Money which is not treated as Client Money is not protected on the insolvency of the ACS Manager and will form part of the ACS Manager’s insolvent estate. (xviii) Exclusion Policies Where a Sub - Fund applies an exclusion policy (for example, the Aviva Investors’ baseline exclusion policy ) or ESG - based exclusionary criteria in its investment selection process, this may result in the relevant Sub - Fund foregoing opportunities to buy certain investments when it might otherwise be advantageous to do so, and/or selling investments when it might be disadvantageous to do so.
(b) Risks Associated with Investment Techniques (i) Delayed Delivery Transactions Each Sub - Fund that invests in fixed income transferable securities may purchase TBAs , for example US mortgages. This generally refers to a forward contract on a pool of mortgages in which the specific mortgages are not announced and allocated prior to a specified delivery date. TBAs are not settled at the time of purchase, which may lead to leveraged positions within a Sub - Fund. Purchasing a TBA involves a risk of loss if the value of the security to be purchased declines prior to the settlement date and exposes a Sub - Fund to additional counterparty default risk. A Sub - Fund may dispose of a commitment prior to settlement if it is deemed appropriate to do so. Proceeds of TBA sales are not received until the contractual settlement date . TBAs will be treated as derivative instruments. (ii) Derivatives (General) In accordance with the investment restrictions set out in Appendix 6 , each of the Sub - Funds may use d erivatives for the purposes of “ efficient portfolio management ” ( in order to reduce risk and/or costs ) and/or to achieve the investment objective (to generate additional income or capital ) , as further described in Appendix 6 . The use of derivatives may expose a ny Sub - Fund to a certain degree of risk . These risks may include credit risk with regard to counterparties with whom a Sub Fund trades, the risk of settlement default, lack of liquidity of the derivative, imperfect tracking between the change in value of the derivative and the change in value of the underlying asset that the relevant Sub Fund is seeking to track and greater transaction costs than investing in the underlying assets directly. In accordance with standard industry practice when purchasing derivatives, a Sub - Fund may be required to secure its obligations to its counterparty. For non fully funded derivatives, this may involve the placing of initial and/or variation margin assets with the counterparty. For derivatives which require a Sub Fund to place initial margin assets with a counterparty, such assets may not be segregated from the counterparty's own assets and, being freely exchangeable and replaceable, th at Sub - Fund may have a right to the return of equivalent assets rather
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Aviva I nvestors Funds ACS Prospectus (7 September 2026) 26
than the original margin assets deposited with the counterparty. These deposits or assets may exceed the value of the relevant Sub - Fund's obligations to the counterparty in the event that the counterparty requires excess margin or collateral. In addition, as the terms of a derivative may provide for one counterparty to provide collateral to the other counterparty to cover the variatio n margin exposure arising under the derivative only if a minimum transfer amount is triggered, a Sub - Fund may have an uncollateralised risk exposure to a counterparty under a derivative up to such minimum transfer amount. Derivative contracts can be highly volatile, and the amount of initial margin is generally small relative to the size of the contract so that transactions may be leverage d in terms of market exposure. A relatively small market movement may have a potentially larger impact on derivatives than on standard bonds or equities and leveraged positions can therefore increase Sub - Fund volatility . Whilst the Sub - Funds will not borrow money to leverage they may for example take synthetic short positions through derivatives to adjust their exposure, always within the restrictions provided for in Appendi x 6 . Certain Sub - Funds may enter into long positions executed using derivatives such as futures positions including currency forwards. Additional risks associated with investing in derivatives may include a counterparty breaching its obligations to provide collateral, or d ue to operational issues (such as time gaps between the calculation of risk exposure to a counterparty's provision of additional collateral or substitutions of collateral or the sale of collateral in the event of a default by a counterparty), there may be instances where a Sub - Fund's credit exposure to its counterparty under a derivative contract is not fully collateralised but each Sub - Fund will continue to observe the limits set out in Appendix 6 . The use of derivatives may also expose a Sub - Fund to legal risk, which is the risk of loss resulting from changing laws or from the unexpected application of a law or regulation, or because a court declares a contract not legally enforceable. Sub - Funds may use derivatives to facilitate complex management techniques. T his may involve: (i) using swap contracts to hedge interest rate risk; (ii) using currency derivatives to buy or sell currency risk; (iii) buying and selling options for investment purposes; (iv) using credit default swaps to buy or sell credit risk; (v) using volatility derivatives to adjust volatility risk; (vi) using contracts for difference to gain market exposure; (vii) using synthetic short positions to take advantage of any negative investment views; and
(viii) using synthetic long positions to gain market exposure. Market leverage obtained through derivatives is expressed through a Sub - Fund's gross market exposure to the underlying reference assets of the derivatives contracts. Gross market exposure may vary although, a Sub - Fund's global exposure, which is the aggregate sum of its obligations under the derivative contracts, shall not exceed the total net value of the Sub - Fund. Furthermore, a Sub - Fund's overall risk exposure will remain within the limits imposed by the COLL Sourcebook, as further described in Appendix 6 . The ACS Manager's current policy concerning the use of derivatives to gain market leverage is disclosed within the relevant product literature which is available on request. Where derivative instruments are used in this manner the overall risk profile of a Sub - Fund may be increased . The ACS Manager uses a risk management process, to monitor and measure as frequently as appropriate the risk of a Sub - Fund's portfolio and contribution of the underlying investments to the overall risk profile of the Sub - Fund. Where consistent with its investment objectives and policy a Sub - Fund may utilise, directly or indirectly (for example through investment in another fund) a variety of exchange traded and OTC derivative instruments including, call options, put options, stock index options, credit default swaps, credit linked notes, equity default swaps, SFTs, TRSs , asset swaps, interest rate swaps, contracts for difference , swaptions, warrants, forward contracts and future contracts, for hedging purposes and to reduce risk. Please see Appendix 1 for the derivative instruments utilised by each Sub - Fund. Losses in excess of the amount invested may be incurred from investment in such derivative instruments due to low margin deposits creating leverage which is typically associated with investment in such instruments. These instruments may be sensitive to sma ll price movements, may be considered illiquid and could be difficult to price under certain market conditions. (iii) Derivative Strategies A Sub - Fund’ s exposure to derivative strategies will mainly be obtained directly or indirectly through related : (i) transferable securiti es and money market instruments; (ii) u nits of cl osed - ended investment companies; (iii) financial instruments linked or backed to the performance of u nderlying financial instruments; (iv) UCITS and/or other undertakings for collective investment investing in these strategies and financial
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