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Aviva Investors Funds ACS Prospectus (5 October 2026) 1
Aviva Investors: Confidential
AVIVA INVESTORS UK FUND SERVICES LIMITED, 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 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 AVIVA INVESTORS NORTH AMERICAN EQUITY CORE FUND AVIVA INVESTORS EMERGING MARKET EQUITY CORE FUND
This Prospectus is dated and is valid as at 5 October 2026
Prepared in accordance with the Collective Investment Schemes Sourcebook and the FUND Sourcebook
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Aviva Investors Funds ACS Prospectus (5 October 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 (5 October 2026) 3
Aviva Investors: Confidential
42. PREFERENTIAL TREATMENT 47
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Aviva Investors Funds ACS Prospectus (5 October 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 2014. 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-Funds. Investors should only consider investing in the Sub Funds if they understand the risks involved including the risk of losing all capital invested. The Scheme is organised as an umbrella Co Ownership Scheme comprising separate Sub-Funds. Further additional Sub-Funds may be established in the future by the ACS 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 unlawful 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 Unitholders 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, the 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 36(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 class) issued from time to time in respect of a Sub-Fund 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 Investors Funds ACS Prospectus (5 October 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
The 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
The 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
The 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 Directives 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 Collective Investment Schemes 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, Aviva Investors North American Equity Core Fund 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
An investor that is considered to be an eligible counterparty or that may, on request, be treated as an eligible
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Aviva Investors Funds ACS Prospectus (5 October 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 The 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 The 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 Investment Funds Sourcebook 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 Managers
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
An 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 Investors Funds ACS Prospectus (5 October 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
The 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 Securities 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, including 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
The 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 An alternative investment fund within the scope of the UK AIFM Regime and as defined in the FCA Handbook.
UK AIFM An 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 In 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 authorised 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’ assets, 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 Investors Funds ACS Prospectus (5 October 2026) 8
Unitholder In relation to a Class or Sub-Fund means a person who is on the register as a unitholder in that Class or Sub Fund at that time.
Unitholder Documents
Collectively, the Form, an Investor Agreement, the Power of Attorney, the Prospectus and the ACS Deed.
US Persons Means 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 property for the Sub-Funds for the purpose of determining the price at which Units of a class 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. 01973412) 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 Contracts' 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 registered office of the ACS Manager is 80 Fenchurch Street, London, EC3M 4AE. The issued and paid-up share capital of the ACS Manager is twenty one million five hundred thousand ordinary shares of £1. The ACS Manager also acts as the ACS Manager to another authorised contractual scheme as more fully described in Appendix 5. The directors 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 Speirs 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 depositary of the Scheme and, for the avoidance of doubt, acts 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 address 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 Prudential 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 September 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 Investors Funds ACS Prospectus (5 October 2026) 9
The Depositary is responsible for the safekeeping of the property 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 acts as global custodian and may delegate safekeeping to one or more global sub custodians (such delegation may include the powers of sub-delegation). The Depositary has delegated safekeeping of the assets of the Scheme to The 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 or 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 influence 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 accordance 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 time 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 be 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 Interest
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 between 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 information 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 Investors Funds ACS Prospectus (5 October 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 with 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 the 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 Managers The ACS Manager has delegated certain functions with respect to the investment management of the assets of the Scheme to 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, underwritings 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 Managers report to the ACS Manager on the performance of each Sub-Fund. The Investment Managers' 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. Schroders is authorised and regulated 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 regulated 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, EC4V 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 administration, (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. The 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 obtained 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 regarding 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 claims 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 Section 261P.
12. Unitholder’s Rights Against Service Providers The Scheme is reliant on the performance of the Service Providers. 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 Section 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 believe they may have a claim under Section 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. Unitholders 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 Managers) 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 management 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 Manager or any other method otherwise approved by the ACS Manager. When placing an order to subscribe for Units for the first time, the ACS Manager will request that a Form 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 Form may result in a delay in the ACS Manager processing any subsequent redemption request or may result in the ACS Manager withholding redemption proceeds. All requests to subscribe for Units must be received by the Deal Cut-Off 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 affected 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 by 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), if 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. Unitholders must meet the investment 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 Manager 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), the 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 purposes 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 ACS 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 set 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 Scheme. 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 Points 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 in 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 objectives 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 Unit is in issue in a Sub Fund, the ACS Manager may permit a Unitholder to: (i) convert all or some of the Units held from one class in that Sub-Fund (the " Original Units ") for Units of another class in the same Sub-Fund (" New Units "), subject to Minimum Investment and eligibility requirements. When Units 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 Unit conversion is available on request from the ACS Manager in writing; or (ii) switch all or some of the Units held from one class in that Sub-Fund (the " Original Units ") into Units of another Sub-Fund within the Scheme (the " New Units ") subject to Minimum Investment and eligibility requirements. On a switch of Units, the number of New Units issued will be determined by reference to the respective prices of New Units and Original Units at the Valuation Point applicable 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 Unitholders, must be signed by all joint Unitholders before a conversion or switch is effected. Conversions and switches are subject to the Minimum Investment and eligibility requirements. No conversion or switch will be made during any period when the right of Unitholders to require a redemption of Units 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 Units between Sub-Funds (but not between Unit Classes in the same Sub-Fund) should be treated as a disposal for the purposes of Capital Gains Tax. Conversions between different Unit Classes 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 Unitholder who switches Units in one Sub-Fund for Units in any other Sub-Fund will not be given a right by law to withdraw from or cancel the transaction.
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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, the ACS Manager may reject at its discretion any subscription, redemption, switch or conversion of Units. In particular, all Unitholders must meet the eligibility 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 Unitholders 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 application for switches, conversions, and subscription of Units from Unitholders whom they consider to be excessive traders; and (i) levy a redemption charge on 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. The 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 Form, Power of Attorney or Investor Agreement or entering into a contract with the ACS Manager or one of its affiliates, Unitholders 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. The 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, alternatively, 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 historical 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 the fair value of an asset or liability. Where an adjustment is made as per the foregoing, it will be applied consistently to all classes 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 quality 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 sufficient quality, an asset of the VNAV Fund shall be valued conservatively by using mark-to-model. The model shall accurately estimate the intrinsic 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 cost method shall not be used. Valuations 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 point.
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 prices. 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 Scheme 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 Scheme. 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 sheets 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 2024 to 31 December 2024 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 Deal Cut-Off Point (where applicable). When Units are redeemed, Units will be redeemed on a forward pricing basis. The 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 Deal Cut-Off Point (where applicable).
19. Minimum Investment If following a redemption or switch a holding in any class of Unit should fall below the Minimum 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 Unitholder holding less than any Minimum Investment stated in Appendix 1 as the minimum number or value of Units of the Unit Class concerned that may be held. Minimum Investments may be waived at the ACS Manager's discretion.
20. ACS Manager's Box It 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 Yields 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 of 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 calculated 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 Scheme property 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 Scheme property of the Sub-Fund represented by the Accumulation Units and Income Distribution Units in existence at the end of the relevant distribution period. 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 Classes will not result in any material prejudice to the interests of holders of Units in existing Unit Classes.
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 Objectives and Policy, and Investment Restrictions
(a) General The investment objectives 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 objectives 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 part 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 section 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, the Sub-Funds 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 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. Collateral will meet the requirements of the COLL Sourcebook and will be limited to cash, 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 securities lending authorisation agreement 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 collateral 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 subject to daily variation margin requirements. All transactions are governed by industry standard documentation. The assets that may be subject to securities lending and all 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. Cash 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-Fund. 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 ACS 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. The 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. However, 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 collateral 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 subject 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 all collateral 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 into repo contracts. With the exception of the AI Money Market VNAV Fund, the Sub-Funds are permitted to enter into repo contracts for the purposes of efficient portfolio management. Appendix 1 sets out for each Sub-Fund entering into 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 collateral 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 Securities Lending Authorisation Agreement) (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 collateral 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 subject 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 collateral 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 investment 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 examples below demonstrate the UK AIFM Regime prescribed methodologies that must be used for calculating such leverage ratios. If a Sub-Fund were to have 80% physical holding in direct investments, 20% exposure to index futures, 30% forward FX (used to hedge) and 20% cash, in accordance with the UK AIFM Regime such Sub Fund’s leverage would be expressed as follows:
using the commitment methodology, a ratio of 1.2:1, where 1.2 represents this Sub-Fund’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-Fund’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-Fund’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-Fund were to have 100% in collective investment schemes, in accordance with the UK AIFM Regime such Sub-Fund’s leverage would be expressed as follows:
using the commitment methodology, a ratio of 1:1, where 1 represents this Sub-Fund’s exposure to direct investments; and using the gross methodology, a ratio of 1:1, where 1 represents this Sub-Fund’s exposure to direct investments. In this example, although the Sub-Fund 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 Unitholders 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 The 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 refund 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 Capital 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 will be affected by such a policy, as the income distributed will be automatically 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. This 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 funds 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 Managers 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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(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 Scheme (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 net asset value per Unit of a Sub-Fund will be computed 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 fixed 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 form 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 substantial 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 net 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 net asset 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 impossible 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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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 bonds 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 additional 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 instruments 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 could 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 objective, 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 Unitholders 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 Managers, the Depositary and the Administrator shall not be liable to account to any Unitholder for any payment made or suffered by the relevant Sub-Fund in good faith to a fiscal authority for taxes or 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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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 affiliates 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. Unitholders 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 Managers or the Administrator. 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 not 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’ money 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 Manager. 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 the 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 derivatives 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 any 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, that Sub-Fund may have a right to the return of equivalent assets rather
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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 variation 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 leveraged 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 Appendix 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 due 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. This 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 small 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 securities and money market instruments; (ii) units of closed-ended investment companies; (iii) financial instruments linked or backed to the performance of underlying financial instruments; (iv) UCITS and/or other undertakings for collective investment investing in these strategies and financial instruments; and (v) financial derivatives instruments on these financial instruments. The strategies may involve a degree of illiquidity (see ‘Liquidity Risk’) as well as a potentially high level of leverage, and be represented by physical and/or synthetic short selling. Their magnitude will depend on the exposure taken by the relevant Sub-Fund and certain or unexpected market conditions. (iv) Forward Contracts
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The ACS Manager or its delegates may enter into forward contracts and options on behalf of a Sub-Fund which are not traded on exchanges and are generally not regulated. There are no limitations on daily price moves of forward contracts. Counterparties with whom a Sub-Fund may maintain accounts may require a Sub-Fund to deposit margin with respect to such trading, although margin requirements are often minimal or non-existent. A Sub-Fund’s counterparties are not required to continue to make markets in such contracts and these contracts can experience periods of illiquidity, sometimes of significant duration (see ‘Liquidity Risk’). There have been periods during which certain counterparties have refused to continue to quote prices for forward contracts or have quoted prices with an unusually wide spread (the difference between the price at which the counterparty is prepared to buy and that at which it is prepared to sell). Arrangements to trade forward contracts may be made with only one or a few counterparties, which potentially reduces liquidity (see ‘Liquidity Risk’). The imposition of credit controls by governmental authorities might limit such forward trading to less than that which the ACS Manager would otherwise recommend, to the possible detriment of a Sub-Fund (see ‘Legal and Regulatory Risk’). Additionally, disruptions can occur in any market traded by a Sub-Fund due to unusually high trading volume, political intervention or other factors. Market illiquidity or disruption could result in major losses to a Sub-Fund. In addition, a Sub-Fund may be exposed to credit risks with regard to counterparties with whom it trades as well as risks relating to settlement default (see ‘Credit Risk’, ‘Counterparty Risk’ and ‘Settlement Risk’). Such risks could result in substantial losses to a Sub-Fund. (v) Futures Futures are standardised contracts between two parties to buy or sell a specified asset or index with a standardised quantity for a price agreed upon today with delivery and payment occurring at a future delivery date. They are negotiated on an exchange acting as an intermediary between parties. A Sub-Fund may enter into futures transactions as either the buyer or seller and may combine them to form a particular trading strategy as well as use futures for reducing an existing risk. Futures positions may be illiquid (see ‘Liquidity Risk’) because certain exchanges limit fluctuations in certain futures contract prices during a single day by regulations or an exchange or the Commodity Futures Trading Commission may suspend trading in a particular contract, order immediate liquidation and settlement of a particular contract, or order that trading in a particular contract be conducted for liquidation only. Investments in futures may also involve the following non-exhaustive list of risks see ‘Market Risk’, ‘Settlement Risk’. (vi) Hedging Techniques
Hedging techniques could involve a variety of derivative transactions (see ‘Derivatives (General)’). As a result, hedging techniques involve different risks than those of underlying investments, including liquidity risk and the potential for loss in excess of the amount invested. In particular, the variable degree of correlation between price movements of hedging instruments and price movements in the position being hedged creates the possibility that losses on the hedge may be greater than gains in the value of a Sub-Fund’s positions. In addition, although the contemplated use of these techniques should minimise the risk of loss due to a decline in the value of the hedged position, at the same time they may limit any potential gains resulting from an increase in the value of such positions. The ability of a Sub-Fund to hedge successfully will depend on the ACS Manager's, or its delegate’s, ability to predict pertinent market movements, and as a consequence there can be no assurance that hedging transactions will be successful in protecting against adverse market and/or currency movements. (vii) Investment in UCITS and/or Other Collective Investment Schemes Where a Sub-Fund invests in other collective investment schemes or exchange traded funds, it will assume any specific risks associated with those schemes or funds. Furthermore, there may be additional costs to a Sub-Fund with this strategy, arising out of the double charging incurred, as the underlying schemes can also have initial or entry charges and annual management charges plus additional attributable expenses. The charges levied by both the Scheme and the underlying scheme in which a Sub-Fund invests, will indirectly affect a Unitholder’s investment. (viii) Options An option is the right (but not the obligation) to buy or sell a particular asset or index at a stated price at some date in the future. In exchange for the rights conferred by the option, the option buyer has to pay the option seller a premium for carrying on the risk that comes with the obligation. The option premium depends on the strike price, volatility of the underlying, as well as the time remaining to expiration. Options may be listed or dealt in OTC. A Sub-Fund may enter into option transactions as either the buyer or seller of this right and may combine them to form a particular trading strategy as well as use options for reducing an existing risk. If the ACS Manager or its delegate is incorrect in its expectation of changes in the market prices or determination of the correlation between the instruments or indices on which the options are written or purchased and the instruments in a Sub-Fund’s investment portfolio, that Sub-Fund may incur losses that it would not otherwise incur. Investment in options may involve the following non exhaustive list of risks, see ‘Market Risk’, ‘Settlement Risk’, ‘Counterparty Risk’, ‘Liquidity Risk’. Their
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magnitude will depend on the exposure taken by a Fund and certain or unexpected market conditions. (ix) OTC Transactions There is less governmental regulation and supervision of transactions in OTC markets (in which currencies, forward, spot and option contracts, credit default swaps, TRS, and certain options on currencies and other types of derivative instruments are generally traded) than organised stock exchanges. Many of the protections afforded to transactions on organised exchanges such as the performance guarantee of an exchange clearing house may not exist for OTC transactions. The risk of counterparty default therefore exists (see ‘Counterparty Risk’ and ‘Credit Risk’). The ACS Manager or its delegates will regularly assess the credit and counterparty risk arising from trading activities e.g. counterparty risk exposures resulting from adverse movements in the prices or volatility of market prices and will assess the hedging effectiveness on an ongoing basis. Counterparty exposures are monitored against internal limits or thresholds as applicable. Further, in contrast to exchange traded instruments, forward, spot and option contracts on currencies do not provide the ACS Manager or its delegate with the possibility to offset a Sub-Fund’s obligations through an equal and opposite transaction. For this reason when entering into forward, spot or options contracts, a Sub-Fund may be required and must be able to perform its obligations under the contracts. (x) Swap Transactions Swap transactions are privately negotiated OTC derivative products in which two parties agree to exchange payment streams of a notional amount in relation to an asset or index. The notional amount is usually not exchanged between counterparties. By consequence, cash or collateral may be required. Swaps transactions can typically either be in the form of a credit default swap, a contract for difference, an interest rate swap, a TRS and an interest rate swaption. A Sub-Fund may enter into swap transactions as either the buyer or seller of this right and may combine them to form a particular trading strategy as well as using swap transactions for reducing an existing risk. A credit default swap allows the transfer of default risk. This allows Unitholders to effectively buy insurance on a bond they hold (hedging the investment) or buy protection on a bond they do not physically own where the investment view is that the stream of coupon payments required will be less than the payments received due to the decline in credit quality. A contract for difference is a contract between two parties, typically described as the buyer and the seller stipulating that the seller will pay to the buyer the difference between the current value of an asset and its value at contract time (if the difference is negative, the buyer pays the seller instead). Interest rate swaps involve an exchange with another party of respective commitments to pay or receive
interest, such as an exchange of fixed rate payments for floating rate payments. Currency swaps may involve the exchange of rights to make or receive payments in specified currencies. TRS involve the exchange of the right to receive the total return, coupons plus capital gains or losses, of a specified reference asset, index or basket of assets against the right to make fixed or floating payments. Where a Sub-Fund enters into interest rate swaps or TRSs on a net basis, the two payment streams are netted out, with each party receiving or paying, as the case may be, only the net amount of the two payments. Interest rate or TRS entered into on a net basis do not involve the physical delivery of investments, other underlying assets or principal. Accordingly, it is intended that the risk of loss with respect to interest rate swaps is limited to the net amount of interest payments that a Sub-Fund is contractually obligated to make (or in the case of TRS, the net amount of the difference between the total rate of return of a reference investment, index or basket of investments and the fixed or floating payments). If the other party to an interest rate swap or TRS defaults, in normal circumstances each Sub-Fund’s risk of loss consists of the net amount of interest or total return payments that each party is contractually entitled to receive. In contrast, currency swaps usually involve the delivery of the entire principal value of one designated currency in exchange for the other designated currency. Therefore, the entire principal value of a currency swap is subject to the risk that the other party to the swap will default on its contractual delivery obligations. Certain Sub-Funds may also buy or sell interest rate swaption contracts. These give the purchaser the right, but not the obligation to enter into an interest rate swap at a pre-set interest rate within a specified period of time. If the ACS Manager or its delegate is incorrect in its forecasts of market values, interest rates and currency exchange rates, the investment performance of a Sub Fund would be less favourable than it would have been if these investment techniques were not used. Illiquidity in the swaps market may prevent a Sub-Fund from being able to roll its swap positions on expiry which in turn may result in a Sub-Fund being temporarily unable to pursue its investment objective. In addition, the market for credit default swaps may sometimes be more illiquid than bond markets (see ‘Liquidity Risk’). The investment in options may also involve the following non-exhaustive list of risks; see ‘Market Risk’, ‘Credit Risk’, ‘Counterparty Risk’. Their magnitude will depend on the exposure taken by the relevant Sub-Fund and certain or unexpected market conditions. (xi) When Issued and Forward Commitment Securities A Sub-Fund may purchase “when-issued” securities and may contract to purchase or sell securities for a fixed price at a future date beyond the usual settlement time. When-issued securities are securities that have
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been authorized, but not yet received and can be used to hedge against anticipated changes in interest rates and prices or for speculative purposes. Forward commitment transactions involve a commitment by a Sub-Fund to purchase or sell securities at a future price and date. The purchase of such securities involves the risk of the value of the security being purchased declining before the purchase date. Equally the sale of securities on a forward commitment basis can expose a Sub-Fund to the risk of the value of the security being sold increasing prior to settlement. Such securities may be disposed of prior to settlement if deemed appropriate by the ACS Manager. (xii) SFTs The primary risk in any SFT is counterparty credit risk (see “Counterparty Risk”), Risk is mitigated by the choice of counterparty and the use of collateral. In the event of a counterparty default, collateral securities delivered by the failing counterparty are sold, and the sale proceeds used to purchase replacement loan securities. There is a risk that these collateral sale proceeds are insufficient to purchase the replacement loan securities, leading the Sub-Fund to incur a loss. This risk is mitigated by the fact that all SFT activity is governed by industry standard legal documentation and collateralised to a minimum value of 100% of the loan portfolio. Collateral, consisting of liquid, marketable securities, is valued daily on a mark-to-market basis. SFTs also involve operational liquidity risk arising where a Sub-Fund may be unable to settle the sale of a security if it cannot be recalled from a borrowing counterparty on a timely basis. This risk is mitigated by a comprehensive set of systems and procedures in place to ensure that any security on loan may be recalled at any time as required from the borrowing counterparty.
(c) Risk Factors Specific to Certain Sub-Funds The following are relevant to a Sub-Fund depending on the investment objective and policy of that Sub Fund. Details of which specific risk factors are relevant for a Sub-Fund are set out in Appendix 1. (i) Emerging Markets Where a Sub-Fund invests in emerging markets, it is likely to be more volatile than one that invests in developed markets. These markets may not be as strictly regulated, and securities may be harder to buy and sell than those in more developed markets. These markets may also be politically unstable which can result in the Sub-Fund carrying more risk. (ii) Smaller Companies Where a Sub-Fund invests in shares of smaller companies, these shares can be more volatile and may be harder to buy and sell than larger company shares which can result in the Sub-Fund carrying more risk. (iii) Fixed Interest
Where a Sub-Fund invests in fixed interest securities, such as corporate or government bonds, the value may go up and down as interest rates change. If interest rates rise, the value is likely to fall. Bonds with a lower credit rating are known as sub-investment grade or junk bonds. These carry an increased risk that the issuer of the bond will be unable to continue the interest payments or return the capital at maturity. (iv) Asset-Backed Securities Asset-backed securities represent interests in pools of consumer loans such as: credit card receivables, motor vehicle loans and leases, or leases on equipment such as computers, and are subject to certain additional risks. Due to the nature of the underlying assets, the ability of an issuer of asset backed securities to enforce its security interest in the underlying assets may be limited. The principal (amount loaned) on asset-backed securities may be prepaid at any time. Voluntary prepayment of the loan will reduce the yield and market value of an asset-backed security. Rising interest rates tend to extend the duration of asset-backed securities, making them more sensitive to changes in interest rates. As a result, in a period of rising interest rates, volatility of asset-backed securities may increase. The risk of default by borrowers is greater during periods of rising interest rates and/or unemployment rates. When interest rates are declining, there are usually more prepayments of loans as borrowers are motivated to pay off debt and refinance at new lower rates, which will shorten the life of asset-backed securities, reducing the potential capital growth. The reinvestment of cash received from prepayments will, therefore, usually be on less attractive terms and at a lower interest rate than the original investment, lowering the yield payable. The incidence of prepayment of asset-backed securities will also be affected by other factors including general economic and other demographic conditions. If a Sub-Fund purchases asset-backed securities that are “subordinated” to other interests in the same pool of assets, that Sub-Fund, as a holder of those securities, may only receive payments after the pool’s obligations to other investors have been satisfied. Instability in the markets for asset-backed securities may affect the liquidity of such securities, which means that a Sub-Fund may be unable to sell such securities at an advantageous time and price. As a result, the value of such securities may decrease and the Sub Fund may incur greater losses on the sale of such securities than under more stable market conditions. Furthermore, instability and illiquidity in the market for lower-rated asset-backed securities may affect the overall market for such securities, thereby impacting the liquidity and value of higher-rated securities. (v) Specialist Where a Sub-Fund invests only in a specific industry sector, it may carry more risk than Sub-Funds that invest across a variety of sectors. These Sub-Funds
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can be more volatile and higher risk due to their lack of diversification. (vi) Single Market Where a Sub-Fund focuses investments in a single country, region or currency, the Sub-Fund will have greater exposure to the market, political, economic, and currency risks of that country than if it was more diversified across a number of countries, regions or currencies. (vii) Money Market This Sub-Fund is not a cash deposit account but mainly invests in cash and money market instruments (which are assets with high liquidity, meaning they have similar characteristics to cash deposits with banks). In a low interest rate environment any charges applied to a money market fund may be greater than its return, so you would get back less than you have paid in. (viii) Index-Linked Where a Sub-Fund invests in index-linked bonds, the value may go up and down as the rate of inflation changes. If inflation falls, the value is likely to fall. (ix) Environmental, Social and Governance (ESG) If a Sub-Fund has an explicit sustainability objective or is required to invest in accordance with specific ESG investment criteria, this may limit the choice of investments. The Sub-Fund may not perform in line (either positively or negatively) with either the market (as represented by the relevant benchmarks/indices used by the relevant Sub-Fund), or other funds that have a broader investment policy. A Sub-Fund with a sustainability objective or which invests in accordance with specific ESG investment criteria may exercise any voting rights it has in relation to an investment in a manner that is consistent with such objective or criteria, which may not always be consistent with maximising the investment performance of the relevant investment or issuer.
In evaluating an investment based on ESG criteria, the Investment Manager is dependent upon information and data from third party resources, including the counterparty and data providers, which may be incomplete, inaccurate, inconsistent or unavailable. As a result, there is a risk that the Investment Manager may incorrectly assess an investment or issuer. There is also a risk that the Investment Manager may not apply the relevant ESG criteria correctly or that a Sub Fund with a sustainability objective or which invests in accordance with specific ESG investment criteria may nonetheless gain exposure to investments which are not consistent with the Sub-Fund’s objective or investment criteria. (x) Alternatives Where a Sub-Fund invests in alternatives, it may carry more risk as these instruments are generally priced less regularly and may be harder to buy and sell than investments in more conventional asset classes. Alternatives include commodities, hedge funds, equity
or debt securities of unlisted companies, real estate trusts (REITS) and venture capital. (xi) Concentration Sub-Funds may hold a limited number of holdings and the effect of this, together with its long term approach to investment, could result in large movements in the Unit price, or for Sub-Funds whose investment policy is to seek exposure through other collective investment schemes, could result in an increased exposure to the risk of suspension of those collective investment schemes. (xii) Active management There may be a higher turnover in a Sub-Fund. The Sub-Fund pays transaction costs, such as commissions, when it purchases and sells securities (or ‘turns-over’ its portfolio). A higher portfolio turnover will cause the Sub-Fund to incur additional transaction costs and associated costs which may affect the Sub Fund’s performance. (xiii) Equity Securities The value of equity securities fluctuates daily and can be influenced by many micro and macro factors such as political and economic news, corporate earnings report, demographic trends and catastrophic events. The prices of equities can be influenced by factors affecting the performance of the individual companies issuing the equities, as well as by daily stock market movements, and broader economic and political developments, including trends in economic growth, inflation and interest rates. The value of equities will go up and down and a Sub-Fund investing in equities could incur significant losses.
(xiv) Stock Connect Risk
The AI Stewardship International Equity Fund, the AI Asia Pacific Ex Japan Fund, the AI Global Equity Fund, the AI Global Equity Growth Fund, the Aviva Investors Pacific Equity Ex Japan Core Fund and Aviva Investors Emerging Market Equity Core Fund may invest in China A-Shares through the Shanghai-Hong Kong Stock Connect and the Shenzhen-Hong Kong Stock Connect programmes (the “Stock Connect”). The Stock Connect is a securities trading and clearing linked programme developed by Hong Kong Exchanges and Clearing Limited, the Hong Kong Securities Clearing Company Limited ("HKSCC"), Shanghai Stock Exchange, Shenzhen Stock Exchange and China Securities Depository and Clearing Corporation Limited ("ChinaClear") with an aim to achieve mutual stock market access between mainland China and Hong Kong. The Stock Connect allows foreign investors to trade certain Shanghai Stock Exchange or Shenzhen Stock Exchanges listed China A-Shares through their Hong Kong based brokers. The Sub-Fund seeking to invest via the Stock Connect is subject to the following additional risks:
Clearing and Settlement Risk: The HKSCC and ChinaClear have established the clearing links and each will become a participant of each other to facilitate clearing and settlement of cross-
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boundary trades. For cross-boundary trades initiated in a market, the clearing house of that market will on one hand clear and settle with its own clearing participants, and on the other hand undertake to fulfil the clearing and settlement obligations of its clearing participants with the counterparty clearing house. As the national central counterparty of the PRC’s securities market, ChinaClear operates a comprehensive network of clearing, settlement and stock holding infrastructure. ChinaClear has established a risk management framework and measures that are approved and supervised by the China Securities Regulatory Commission. The chances of a ChinaClear default are considered to be remote. In the event ChinaClear defaults, HKSCC's liabilities under its market contracts with clearing participants will be limited to assisting clearing participants in pursuing their claims against ChinaClear. HKSCC should act in good faith to seek recovery of the outstanding stocks and monies from ChinaClear through available legal channels or the liquidation of ChinaClear. In that event, the Sub-Fund may not fully recover its losses or its Stock Connect securities or the process of recovery could be delayed.
Legal/Beneficial Ownership: Where securities are held in custody on a cross-border basis, there are specific legal/beneficial ownership risks linked to compulsory requirements of the local Central Securities Depositaries, HKSCC and ChinaClear. As in other emerging and less developed markets, the legislative framework is only beginning to develop the concept of legal/formal ownership and of beneficial ownership or interest in securities. In addition, HKSCC, as nominee holder, does not guarantee the title to Stock Connect securities held through it and is under no obligation to enforce title or other rights associated with ownership on behalf of beneficial owners. Consequently, the courts may consider that any nominee or custodian as registered holder of Stock Connect securities would have full ownership thereof, and that those Stock Connect securities would form part of the pool of assets of such entity available for distribution to creditors of such entities and/or that a beneficial owner may have no rights whatsoever in respect thereof. Consequently the Sub-Fund and the Depositary cannot ensure that the Sub Fund’s ownership of these securities or title thereto is assured. To the extent that HKSCC is deemed to be performing safekeeping functions with respect to assets held through it, it should be noted that the Depositary and the Sub-Fund will have no legal relationship with HKSCC and no direct legal recourse against HKSCC in the
event that the Sub-Fund suffers losses resulting from the performance or insolvency of HKSCC.
(xv) No Protection by Investor Compensation Fund: Investments through the Stock Connect are conducted through brokers, and are subject to the risks of default by such brokers in their obligations. The Sub-Funds’ investments under the Stock Connect are not covered by the Hong Kong’s Investor Compensation Fund, which is established to pay compensation to investors of any nationality who suffer pecuniary losses as a result of default of a licensed intermediary or authorised financial institution in relation to exchange-traded products in Hong Kong. Therefore the Sub-Fund is exposed to the risks of default of the broker(s) it engages in its trading in China A-Shares through the Stock Connect. Further, since the Sub-Fund is carrying out trading through securities brokers in Hong Kong but not PRC brokers, it is not protected by the China Securities Investor Protection Fund in the PRC.
(xvi) Operational risk: The Stock Connect provides a channel for investors from Hong Kong and overseas to access the PRC Stock Exchanges directly. The Stock Connect is premised on the functioning of the operational systems of the relevant market participants. Market participants are able to participate in these programmes subject to meeting certain information technology capability, risk management and other requirements as may be specified by the relevant exchange and/or clearing house. The securities regimes and legal systems of the two markets differ significantly and market participants may need to address issues arising from the differences on an on-going basis. Further, the “connectivity” in the Stock Connect requires routing of orders across the border. There is no assurance that the order routing systems will function properly or will continue to be adapted to changes and developments in both markets. In the event that the relevant systems fail to function properly, trading in both markets through the programme can be disrupted. The Sub-Fund’s ability to access the China A-Shares market (and hence to pursue its investment strategy) will be adversely affected. The HKSCC provides clearing, settlement, nominee functions and other related services of the trades executed by Hong Kong market participants. PRC regulations which include certain restrictions on selling and buying will apply to all market participants. In the case of sale, pre-delivery of shares is required to the broker. Because of such requirements, the Sub-Fund may not be able to purchase and/or dispose of holdings of in a timely manner.
Quota limitations risk: The Stock Connect is subject to quota limitations. Trading under the Shanghai-Hong Kong Stock Connect and the
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Shenzhen-Hong Kong Stock Connect will be subject to a daily quota respectively (“Daily Quota”). The Daily Quota will apply on a “net buy” basis. In particular, once the remaining balance of the Daily Quota drops to zero or the Daily Quota is exceeded during the opening call auction session, new buy orders will be rejected (though investors will be allowed to sell their cross-boundary securities regardless of the quota balance). Therefore, quota limitations may restrict the Sub-Fund’s ability to invest in China A-Shares through the Stock Connect on a timely basis, and the Sub-Fund may not be able to effectively pursue its investment strategies.
Regulatory risk: Any changes in laws, regulations and policies of the China A-Shares market or rules in relation to Stock Connect may affect trading capabilities and/or share prices. Additionally, the Stock Connect is a novel concept and is subject to regulations promulgated by regulatory authorities and implementation rules made by the stock exchanges in the PRC and Hong Kong. Further, new regulations may be promulgated from time to time by the regulators in connection with operations and cross-border legal enforcement in connection with cross-border trades under the Stock Connect. Also, the current regulations are subject to change. There can be no assurance that the Stock Connect will not be abolished. Any Sub-Fund which may invest via the Stock Connect may be adversely affected as a result of such changes. Generally, investors should note that the rights of investors in China are uncertain, government intervention is common and unpredictable, and many of the market systems are unproven. Chinese authorities may impose measures that result in additional costs and/or have the effect of blocking, limiting or otherwise restricting trading, potentially hindering the Sub-Fund in implementing it’s intended investment strategy.
(xvii) Benchmark Indices The constituents of a Sub-Fund’s benchmark Index may change over time. Potential investors in a Sub Fund may obtain a breakdown of the constituents of the relevant benchmark Index from the website of the index provider (as referred to in the relevant benchmark Index description outlined in Appendix 1). There is no assurance that a Sub-Fund’s benchmark Index will continue to be calculated and published on the basis described in this Prospectus or that it will not be amended significantly. The past performance of each benchmark Index is not a guide to future performance.
The ACS Manager may, if it considers it in the interests of any Sub-Fund to do so, and with the consent of the Depositary and FCA as necessary in accordance with COLL, and in line with Unitholder approval and notice requirements as set out in COLL 4.3, substitute
another index for the benchmark Index in circumstances such as the following: • the weightings of constituent securities of the Index would cause the relevant Sub-Fund (if it were to follow the Index closely) to be in breach of the COLL Sourcebook and/or any tax law or tax regulations that the ACS Manager may consider to have a material impact on any Sub-Fund; • the particular benchmark Index or index series ceases to exist; • a new index becomes available which supersedes the existing benchmark Index; • a new index becomes available which is regarded as the market standard for investors in the particular market and/or would be regarded as of greater benefit to the Unitholders than the existing benchmark Index; • it becomes difficult to invest in stocks comprised within the particular benchmark Index; • the benchmark Index provider increases its charges to a level which the ACS Manager considers too high; • the quality (including accuracy and availability of data) of a particular benchmark Index has, in the opinion of the ACS Manager, deteriorated; • a liquid futures market in which a particular Sub-Fund is investing ceases to be available; or • where an index becomes available which more accurately represents the likely tax treatment of the investing Sub-Fund in relation to the component securities in that index.
(xviii) Index-Related Risk In order to meet its investment objective, each Core Fund will aim to deliver returns which are similar to the returns of its benchmark Index as published by the relevant index provider. While index providers do provide descriptions of what each benchmark Index is designed to achieve, index providers do not generally provide any warranty or accept any liability in relation to the quality, accuracy or completeness of data in respect of their benchmark indices, nor any guarantee that the published indices will be in line with their described benchmark index methodologies. Errors in respect of the quality, accuracy and completeness of the data may occur from time to time and may not be identified and corrected for a period of time, in particular where the indices are less commonly used. Any such errors may potentially result in a negative or positive performance impact to a Sub-Fund and, by extension, impact its Unitholders. Apart from scheduled rebalances, index providers may carry out additional ad hoc rebalances to their benchmark indices in order, for example, to correct an error in the selection of index constituents. Where the benchmark Index of a Sub-Fund is rebalanced and that Sub-Fund in turn rebalances its portfolio to bring it in line with its benchmark Index, any transaction costs (including any capital gains tax and/or transaction taxes) and market exposure arising from such portfolio rebalancing will be borne by that Sub-Fund and, by extension, its Unitholders. Unscheduled rebalances to the benchmark Index may also expose a Fund to tracking error risk (see below). Therefore, errors and additional ad hoc rebalances carried out by an index provider to
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a Sub-Fund’s benchmark Index may increase the costs and market exposure risk of that Sub-Fund.
(xix) Tracking Error In order to meet its investment objective, each Core Fund will aim to deliver returns which are similar to the returns of its benchmark Index, whilst seeking to minimise tracking error to that benchmark Index. However, the Core Funds do not have an index replicating strategy and there is no guarantee that the Sub-Funds will stay within their expected average yearly tracking error range (as specified in each Core Fund’s investment policy).
The Core Funds may be subject to tracking error risk, which is the risk that the relevant Sub-Fund’s returns will not be similar to that of the benchmark Index from time to time. The impact of tracking error risk may be either positive or negative depending on the underlying circumstances. Tracking error risk may occur for a number of reasons:
• Due to the application of the Aviva Investors’ baseline exclusion policy and/or the ESG Overlay, as more fully described in each Core Fund’s investment policy.
• An inability to hold constituents of the benchmark Index, for example where there are local market trading restrictions, small illiquid components and/or where the COLL Sourcebook and/or any other applicable regulations and/or policies of the ACS Manager limit exposure to the constituents of the benchmark Index.
• Cash management and trading costs from rebalancing the Core Fund to the benchmark Index.
• Where the Core Fund and its benchmark Index are priced at different valuation points. In such circumstances the performance of the Sub-Fund at its valuation point, relative to the performance of benchmark Index, will be different compared to the performance that would have been attained had the Sub-Fund and the benchmark Index been priced at the same time.
• Where the pricing point between the Core Fund and its benchmark Index is the same, the underlying markets on which securities are traded do not always close at the same time as this pricing point and so there is a period of time between certain markets’ close and the Sub-Fund’s valuation point during which prices can move considerably, consequently there may be times when the ACS Manager will apply a fair value accounting policy, as described above. Such fair value pricing may affect the performance differential as the relevant benchmark Indices may not implement a fair value accounting policy.
• Certain aspects of the way that that the Sub-Fund operates including differences in the pricing sources used by the Sub-Fund and the benchmark Index, the timing of cash flows in or out of the Sub-Fund and the operation of a swinging price method.
Other factors may also include but are not limited to: withholding tax if any suffered by an Core Fund on any income received from its investments (the level and quantum of the performance differential arising due to withholding taxes depends on various factors such as any reclaims filed by the Depositary with various tax authorities and any benefits obtained by a Sub-Fund and/or Unitholder under a tax treaty), a new tax levied on securities held by a Sub-Fund or any stock lending activities carried out by a Sub-Fund.
27. Taxation The following provides guidance to United Kingdom (" UK ") corporate taxpayers other than dealers in securities on the UK taxation treatment of an ACS. This summary is general in nature and it is strongly recommended that Unitholders and potential Unitholders seek professional tax advice on their own situation. The taxation treatment outlined below could also change in future.
(a) Taxation of each Sub-Fund of the Scheme As the Scheme is an umbrella co-ownership ACS neither the Scheme nor its Sub-Funds are subject to UK tax on income or capital profits.
(b) Taxation of Unitholders Each Sub-Fund is tax transparent for income purposes meaning that UK tax-paying Unitholders are subject to tax on their share of income, net of allowable expenses, as it arises to the relevant Sub-Fund and not on distributions of income after deduction of expenses. Unitholders will therefore need information on their share of each Sub-Fund’s income, expenses and tax suffered on underlying investments with reference to their holding period. The ACS Manager will provide Unitholders in the Scheme with daily price components and an annual report showing their share of each Sub-Fund’s income (and other amounts taxable as income or potentially deductible from income) that should help those Unitholders liable to UK taxation to comply with their fiscal obligations. For the avoidance of doubt, this information does not extend to chargeable gains (and allowable losses) realised by Sub-Funds and Unitholders remain responsible for complying with their obligations and ensuring that appropriate claims and elections are made. For tax on chargeable gains purposes, Units are deemed to be assets. Therefore UK Unitholders are liable to tax, to the extent net gains are made, on disposal of their Units rather than when the Sub-Funds realise gains. UK insurance companies must consider the impact of section 212 Taxation of Chargeable Gains Act 1992 which imposes an annual deemed disposal on holdings in collective investment schemes such as UK co-ownership ACSs and section 213 of the same Act which dictates when such gains or losses are brought into the charge to tax. This will generally be over a seven year period but this period may be reduced in certain circumstances.
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There is no stamp duty on dealings of Units in the Sub Funds.
(c) Income equalisation Each Sub-Fund is tax transparent for income purposes meaning that UK tax-paying Unitholders are subject to tax on their share of income, net of allowable expenses, as it arises to the Sub-Fund and not on distributions of income after deduction of expenses.
Unitholders will be advised of their share of aggregated accrued income, expenses and withholding tax paid on overseas dividends, if applicable. When a Unit is purchased during the distribution period, part of the purchase price of the Unit reflects the relevant share of income and expenses accrued by the Sub-Fund, and this will be disclosed on the contract note.
The subscription price disclosed on the contract note reflects the acquisition cost which, in respect of determining the base cost of the Units for the purposes of chargeable gains, should be adjusted by the relevant share of income and expenses accrued by the Sub-Fund as disclosed on the contract note.
It is the responsibility of the Unitholder to maintain a record of the relevant amount(s) of income equalisation and to make the appropriate adjustment when completing their tax calculations.
Income equalisation will be applied on all of the Sub Funds in issue.
(d) Taxation of investments held by the Scheme To the extent that withholding taxes on investment profits are not reclaimable the Unitholder is liable for the withholding tax on their share. To help ensure the correct withholding tax treatment in respect of Scheme investments, Unitholders must notify the ACS Manager or transfer agent of any change in tax status. To the extent the Depositary, the ACS Manager, the Investment Manager, any other provider of services to or in relation to the Scheme, any Sub-Fund, any underlying investment or any of their respective delegates or agents is liable to pay any taxation because of the ownership of Units, whether directly or indirectly, by any Unitholder and such taxation is not paid by the relevant Unitholder on its own account, he shall pay an amount equal to the amount of the taxation to the relevant Sub-Fund (or otherwise as the ACS Manager may direct) before the time it becomes payable by the affected person. To the extent the amount of the taxation is not so paid, the Unitholder shall indemnify the ACS Manager, the other Unitholders or former Unitholders in the relevant Sub Fund or class, as appropriate, and any of the other persons mentioned who are affected by such taxation in relation to all such amounts of taxation. The ACS Manager in relation to the relevant Sub-Fund, or class, as appropriate, in which the Unitholder holds Units shall have the right to deduct and set off the amount of such taxation from any income distributed to or
accumulated on any Units owned by that Unitholder. Further, any amounts equal to such taxation and not paid as described may be deducted from any proceeds payable where a redemption request is met. The ACS Manager may also, compulsorily redeem any Units of the Unitholder concerned and use the proceeds of such redemption to pay any relevant taxation.
(e) Tax reporting The Scheme, the ACS Manager or both may have obligations to report details of Unitholders (and their direct or indirect investors) and their interest in the Scheme to HM Revenue & Customs or other tax authorities. This is because certain jurisdictions in which the Scheme intends to invest may require details of direct and indirect investors in such investment to be reported to them. It is also because the UK has entered into intergovernmental information exchange agreements with the United States of America (as a result of the Foreign Account Tax Compliance Act (“FATCA”)) and other countries (as a result of the Common Reporting Standard) and has introduced domestic law to implement the requirements of those regimes. Consequently, the ACS Manager is required to collect and/or report information about certain types of Unitholders in the Scheme. Such information may include the identity of Unitholders, their tax identification numbers, their status under the information exchange agreements, their tax residency status, payments made to the Unitholders in respect of their Units and the value of the Units at the end of the calendar year. The ACS Manager may pass this information to HM Revenue & Customs who may, if necessary, share this information with overseas government agencies (including those outside the EEA).
Although it is the intention of the ACS Manager that all of the Sub-Funds shall comply with the FATCA provisions, the ACS Manager is not able to guarantee that this will always be the case. Any failure in this regard, may result in withholding tax of 30% being deducted from US sourced payments. Were such tax to be suffered, it shall be charged to the relevant Sub Fund.
A condition of investing, or of continuing to invest, is that, upon request from the ACS Manager or its delegate, Unitholders provide accurate information to be passed on to HM Revenue & Customs which may, as already stated, be shared with other overseas government agencies. The Scheme may also require information in respect of Unitholders (and their direct or indirect investors) in order to assess the tax liabilities of the Scheme, any Sub-Fund or any underlying investment.
(f) Conversion, redemption or cancellation When the holder of any Units in any Class fails or ceases for whatever reason to be entitled to receive
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distributions or have allocations made in respect of his holding of Units, in terms of the ACS Manager making or not making any deduction of applicable tax before the distribution or allocation to the Unitholder or in terms of the entitlement of the Unitholder to any particular rate of withholding tax whether or not under an applicable double taxation convention or other agreement, as is envisaged for such Class, he shall, without delay, give notice of this to the ACS Manager and the ACS Manager shall, upon receipt of such notice, treat the Unitholder concerned as if it had served on the ACS Manager a conversion notice in accordance with the ACS Deed requesting conversion of all the relevant Units owned by such holder for Units of the Class or Classes which, in the opinion of the ACS Manager, such Unitholder is entitled to hold and most nearly equate to the Class or Classes being converted by that holder; or, if there is, in the opinion of the ACS Manager, no suitable alternative Class, the ACS Manager shall, upon receipt of such notice, treat the Unitholder concerned as if it had given a request in writing for the redemption or cancellation (at the discretion of the ACS Manager) of the affected Units. If at any time the ACS Manager becomes aware that the holder of any Units, on which it makes or intends to make distributions or allocations without any tax being deducted or accounted for by the ACS Manager, has failed or ceased for whatever reason to be entitled to receive distributions or have allocations made in respect of his holding of such Units without deduction of applicable tax or in terms of the Unitholder's entitlement to any particular rate of withholding tax, whether or not under an applicable double taxation convention or other agreement for the relevant Class, then the ACS Manager shall, without delay, treat the Unitholder concerned as if it had served on the ACS Manager a conversion notice in accordance with the ACS Deed requesting conversion of all the relevant Units owned by such holder for Units of the Class or Classes which, in the opinion of the ACS Manager, such Unitholder is entitled to hold and most nearly equate to the Class or Classes being converted by that holder; or, if there is, in the opinion of the ACS Manager, no suitable alternative Class, the ACS Manager shall, upon receipt of such notice, treat the Unitholder concerned as if it had given a request in writing for the redemption or cancellation (at the discretion of the ACS Manager) of the affected Units. An amount equal to any tax charge incurred by the Scheme or relevant Sub-Fund, Class or other Unitholder, as appropriate, or for which the Depositary or ACS Manager may be held liable as a result of a conversion shall be recoverable from the Unitholder concerned and may be accounted for in any adjustment made of the number of new Units to be issued.
28. Charges The current charges made for each Sub-Fund are shown below (subject to applicable value added tax ("VAT"), if any thereon). On giving at least 60 days' written notice to Unitholders, the ACS Manager may, where relevant, increase any of the charges on the
Sub-Funds provided any such increase does not constitute a fundamental change to the Sub-Fund. Any change to charges which constitutes a fundamental change will require prior Unitholder consent. For details of the categorisation of fundamental, significant and notifiable changes, please see section 31. Fees, costs and duties which are charged on the Sub Funds may, at the ACS Manager’s discretion, be charged to income or treated as a capital expense. The current policy of the ACS Manager is to treat all fees, costs and duties charged on the Sub-Funds as a capital expense, but the ACS Manager could, in the future, decide that it is more appropriate for these fees, costs and duties to be charged against income. Should this occur Unitholders will be notified either by an entry in the ACS Manager’s report or by special notification.
(a) ACS Management Charge The ACS Manager is permitted to deduct from each Sub-Fund an ACS management charge (in respect of investment management services provided to the Scheme). However, with the exception of:
UK Fund of Fund Accumulation Units (“FoF Units”); and
UK Feeder Fund Accumulation Units (“Feeder Units”); this charge will not be paid out of the property of a Sub Fund but instead will be charged in the manner set out in an investor agreement entered into between the ACS Manager and the Unitholder. This does not preclude the ACS Manager from changing the arrangement by giving due notice as agreed with the Depositary to the Unitholder. In respect of FoF Units any ACS Management Charge:
will be deducted from Scheme property of the FoF Units of the relevant Sub-Fund.
will accrue daily, and will be calculated as a percentage of the net asset value of the FoF Units within the relevant Sub-Fund on the previous Business Day, calculated on a mid market basis.
is payable quarterly in arrears.
may be greater than the fees payable by the ACS Manager in respect of investment management services provided by the Investment Manager. In these circumstances, the portion of the ACS management charge that exceeds the fees payable by the ACS Manager will be retained by the ACS Manager. Where FoF Units or Feeder Units have been made available on Sub-Funds where AIGSL is the Investment Manager, the ACS Manager currently charges 0.00% in respect of the FoF Units and Feeder Units, respectively, within the relevant Sub-Fund. Where FoF Units have been made available on Sub Funds where AIGSL is not the Investment Manager, the rate of any ACS Management Charge is stipulated per relevant Sub-Fund in Appendix 1 of this Prospectus.
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This fee will comprise the fee payable to the ACS Manager for all of its services, therefore including the expenses of the ACS Manager in respect of the administration and the oversight of its respective delegates, unless otherwise specified in this Prospectus, as well as investment management services to the Sub-Fund, but will be reduced in respect of the pro-rated annual management charges borne by the Sub-Fund’s investment in any underlying fund in which the Sub-Fund invests from time to time. As such, should the annual management charge incurred by the underlying funds increase, the amount of the ACS management charge that is deducted from Scheme property and which is payable to the ACS Manager will decrease. Conversely, should the annual management charge incurred by the underlying funds decrease, the amount of the ACS management charge that is deducted from Scheme property and which is payable to the ACS Manager will increase. The ACS Manager may make a charge to the property of the Sub-Fund(s) in respect of any future Unit Classes issued by amendment to this prospectus. In certain circumstances where one Sub-Fund of the Scheme invests in Units of another, the ACS Management charge will not be charged to the investing Sub-Fund. Further information is provided at paragraph 5.8 of Appendix 6 below.
(b) Administration Charge The ACS Manager is permitted to deduct from each Sub-Fund an administration charge, which reimburses the ACS Manager for carrying out its administration duties and responsibilities in respect of the Scheme. The ACS Manager will use the administration charge to cover the following costs, charges, fees and expenses which the ACS Manager pays on behalf of the Scheme:
the expenses of the ACS Manager in respect of the administration and the oversight of its respective delegates, unless otherwise specified in this Prospectus;
the fees and expenses payable to the Administrator;
the fees payable to the Depositary (excluding the expenses payable to the Depositary and the fees and expenses payable in respect of the Depositary’s custodian functions, as detailed below);
any costs in respect of the preparation and calculation of the net asset value and prices of Units and the publication and circulation thereof (including the costs of electronic data/information sources) and the costs of obtaining fund ratings and benchmark costs;
any cost in respect of establishing and maintaining the Register (and any sub register(s)) of the Sub Funds;
any costs incurred in producing, distributing and dispatching income and other payments to
Unitholders unless otherwise specified in this Prospectus;
the fees and charges of the Auditor for conducting the annual audit of the Sub-Funds (excluding the expenses and disbursements of the Auditor, see (d) (viii) below);
the ACS Manager is also entitled to receive all reasonable, properly documented out of pocket expenses incurred in the performance of its duties and responsibilities. The aggregate administration charge for each Sub Fund will not exceed 0.07% per annum of the relevant Sub-Fund’s value. However, the ACS Manager estimates that the current aggregate administration charge will be up to 0.03% per annum of the relevant Sub-Fund’s value. Any change to these figures will be notified to Unitholders in accordance with this Prospectus. The administration charges will accrue daily and is calculated as a percentage of the net asset value of the Units within the relevant Sub-Fund on the previous Business Day calculated on a mid-market basis and will be paid monthly in arrears as soon as practical after the month end.
(c) Depositary's Expenses In addition to the Depositary’s fee which will form part of the administration charge, the Depositary is entitled to receive reimbursement out of the property of each Sub-Fund for expenses properly incurred in performing or arranging for the performance of functions conferred on it by the ACS Deed, the Prospectus, the FCA Handbook, the Depositary Services Agreement or by general law. These functions may include (without limitation of the foregoing) custody, insurance, acquisition and dealing with assets of the Scheme; making deposits or loans, dealing with borrowings, effecting foreign currency dealings and effecting efficient portfolio management transactions, as permitted by the FCA Handbook; collection of income or capital; preparation of the Depositary’s annual report; calling Unitholders’ meetings and communicating with Unitholders; preparing, clearing and despatching income distribution payments; obtaining professional advice; conducting legal proceedings; carrying out administration relating to the Scheme; supervision of certain of the activities of the ACS Manager and such other duties as the Depositary is permitted or required by law to perform. The Depositary’s reimbursement shall accrue when the relevant transaction or other dealing is effected and shall be paid monthly in arrears. On the winding up of the Scheme, a Sub-Fund or the redemption and cancellation of a class of Units, the Depositary will be paid all accrued and owing fees, charges and reimbursement of expenses due up to the date of commencement of the winding up, or due in relation to the redemption and cancellation of the relevant class of Units (as appropriate) and any additional expenses necessarily arising out of or in
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connection with its obligations under the Depositary Services Agreement. The Depositary will also act as the custodian of the property of the Scheme and is entitled to receive reimbursement of the custody fees as an expense of the Scheme. The Depositary’s reimbursement for acting as custodian comprises a transaction fee plus safekeeping fees (such safekeeping fees covering assets in custody and those assets which are on loan under the securities lending programme), each determined by the territory or country in which each Sub-Fund’s assets are held. Currently, the transaction fees are in the range of £2.65 to £103.60 per transaction and the safekeeping fees, based upon the value of the assets held in the territory or country in question, are in the range of 0.0004% to 0.50% per annum. The Depositary is also entitled to be reimbursed out of the property of each Sub-Fund in respect of remuneration charged by the Depositary for such services as the ACS Manager and the Depositary may from time to time agree, being depositary services in performing or arranging for the performance of the functions conferred on the Depositary by the ACS Deed or FCA Handbook. Reimbursement charged under this paragraph shall accrue when the relevant transaction or other dealing is effected and shall be paid monthly in arrears. The following further expenses may also be paid out of the property of the Scheme:
all charges imposed by, and expenses of, any agents appointed by the Depositary to assist in the discharge of its duties;
all charges and expenses incurred in connection with the collection and distribution of income; and
all charges and expenses incurred in relation to the preparation of the Depositary’s annual report to Unitholders. Subject to current law and HM Revenue & Customs regulations, VAT at the prevailing rate may be payable in addition to the Depositary’s reimbursement and the above expenses. The rate of the Depositary’s transaction charges or charges for custody services may be increased only in accordance with the FCA Handbook. (d) Securities Lending Agent’s Fee For each Sub-Fund operating securities lending or entering into repo transactions, the Securities Lending Agent is permitted to deduct a monthly fee equating to 20 per cent of the income generated for that Sub-Fund from securities lending or entering into repo transactions. The fee will be charged to the relevant Sub-Fund each month in respect of the activity from the preceding month. No additional fee will be charged by the ACS Manager.
(e) Other Expenses The following other expenses may be reimbursed out of the property of the Scheme: (i) costs of dealing in the property of the Scheme (save where restricted pursuant to paragraph 5 ( Collective Investment Schemes ) of Appendix 6); (ii) the transaction costs of the Registrar, which includes the cost of producing and issuing contract notes to Unitholders; (iii) interest on borrowings permitted by the Scheme and related charges; (iv) taxation and duties payable in respect of the property of the Scheme, the ACS Deed, the issue, surrender or transfer of Units (including, without limitation, overseas transfer taxes and capital gains tax and any similar generated tax charges); (v) any costs incurred in modifying the ACS Deed, including costs incurred in respect of meetings of Unitholders convened for purposes which include the purpose of modifying the ACS Deed, where the modification is necessary or expedient by reason of changes in the law or to remove obsolete provisions; (vi) any costs incurred in respect of meetings of Unitholders convened on a requisition by Unitholders not including the ACS Manager or an associate of the ACS Manager; unanticipated liabilities on unitisation, scheme of arrangement or reconstruction where the property of a body corporate or of another collective investment scheme is transferred to the Depositary in consideration of the issue of Units in the Scheme to shareholders in that body or to participants in that other scheme; (vii) the cost of preparation only of key investor information documents. The costs of preparation and distribution of reports, accounts, any prospectuses, the ACS Deed and any costs incurred as a result of changes to any prospectus or ACS Deed, periodic updates of any other administrative documents, as well as the cost of maintaining other documentation required to be maintained in respect of the Scheme; (viii) any expenses and disbursements of the Auditor as well as the fees of and expenses of third party tax, legal and other professional advisers (including, without limitation, costs in relation to regular UK AIFM Regime fund reporting to the FCA); and (ix) the fees of the FCA under Schedule 1 Part III of the Financial Services and Markets Act 2000 Act and the corresponding periodic fees of any regulatory authority in a country or territory outside the UK in which Units of the Scheme are or may be marketed.
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The costs incurred by the ACS Manager in establishing the Scheme and any Sub-Fund including, but not limited to, the costs of obtaining professional advice, may, at the discretion of the ACS Manager, be borne by the Scheme or the relevant Sub-Fund. Any third party research received in connection with investment advisory services that the Investment Manager or the ACS Manager provides to the Sub Funds will be paid for by the Investment Manager or the ACS Manager, as relevant in relation to each Sub Fund, out of its fees and will not be charged to the Sub Funds. Fees, costs, and duties which are not attributable to a particular Sub-Fund will usually be allocated between the Sub-Funds pro-rata to the net asset value of each Sub-Fund or in accordance with another reasonable method at the ACS Manager's discretion.
29. Conflicts of Interest
(a) Use of brokers Subject to any policies adopted by the ACS Manager, any powers or restrictions in relevant regulations or set forth in the ACS Deed, when arranging investment transactions for a Sub-Fund of the Scheme, the ACS Manager and the Investment Managers will seek to obtain the best net results for that Sub-Fund, taking into account such factors as price (including the applicable brokerage commission or dealer spread), size of order, difficulty of execution and operational facilities of the firm involved and the firm's risk in positioning a block of securities. Therefore, whilst the ACS Manager and the Investment Managers generally seek reasonably competitive commission rates, a Sub Fund does not necessarily pay the lowest commission or spread available. In a number of developing markets, commissions are fixed pursuant to local law or regulation and, therefore, are not subject to negotiation.
The ACS Manager, the Investment Managers, or both may select brokers (including, without limitation, brokers who are affiliated with either the Aviva Group or, if different, the Investment Managers). In line with FCA regulations, the ACS Manager and the Investment Managers do not generate any soft commissions for the Sub Funds. When executing orders, or placing orders with other entities for execution, that relate to financial instruments for, or on behalf of, the Sub-Funds, the Investment Manager or ACS Manager (as relevant) will not accept and retain any fees, commissions or monetary benefits; or accept any non-monetary benefits, where these are paid or provided by any third party or a person acting on behalf of a third party. The Investment Manager or ACS Manager will return to each relevant Sub-Fund as soon as reasonably possible after receipt any fees, commissions or any monetary benefits paid or provided by any third party or a person acting on behalf of a third party in relation to the services provided to that fund, and disclose in
the annual report the fees, commissions or any monetary benefits transferred to them. However, the Investment Manager or ACS Manager may accept without disclosure minor non-monetary benefits that are capable of enhancing the quality of service provided to the fund; and of a scale and nature such that they could not be judged to impair their compliance with its duty to act honestly, fairly and professionally in the best interests of each Sub-Fund. (b) Relations with the Aviva Group
The ultimate holding company of the ACS Manager and AIGSL, is Aviva plc.
Subject to any restrictions adopted by the ACS Manager, any powers or restrictions in relevant regulations or set forth in the ACS Deed, the ACS Manager and any other company in the Aviva Group and any directors of the foregoing, may (a) have an interest in the Scheme or in any transaction effected with or for it, or a relationship of any description with any other person, which may involve a potential conflict with their respective duties to the Scheme, and (b) deal with or otherwise use the services of companies in the Aviva Group in connection with the performance of such duties; and none of them will be liable to account for any profit or remuneration derived from so doing. For example, such potential conflicts may arise because the relevant Aviva Group company:
(i) undertakes business for other clients;
(ii) has directors or employees who are directors of, hold or deal in securities of, or are otherwise interested in, any company the securities of which are held by or dealt in on behalf of the Scheme;
(iii) may benefit from a commission, fee, mark-up or mark-down payable otherwise than by the Scheme;
(iv) may act as agent for the Scheme in relation to transactions in which it is also acting as agent for the account of other clients of itself;
(v) may deal in investments and/or currencies as principal with the Scheme or any of its Unitholders;
(vi) transacts in units or shares of another collective investment scheme or any company of which any Aviva Group company is the manager, operator, banker, adviser or trustee; or
(vii) may effect transactions for the Scheme involving placings and/or new issues with another of its group companies which may be acting as principal or receiving agent's commission.
Additionally, potential conflicts of interest may arise because the ACS Manager itself, a director or an employee of the ACS Manager, or a person linked by control (including a delegate) to the ACS Manager:
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(i) is likely to make a financial gain (or avoid a loss) at the expense of the Scheme or a client or group of clients or an Unitholder in the Scheme that is contrary to the interest of that Unitholder or that Scheme;
(ii) has a financial or other incentive to favour the interest of one Unitholder in the Scheme or a client or group of clients over another;
(iii) has an interest in the outcome of a service/activity provided to the Scheme or its Unitholders or a client or of a transaction carried out on behalf of the Scheme or a client or a Unitholder, which is distinct from the Scheme's interest in that outcome; or
(iv) carries out the same activities for the Scheme as it does for another fund, client or clients which are not funds.
(c) Execution of transactions
The ACS Manager must act in the best interests of each Sub-Fund when executing decisions to deal on behalf of the relevant Sub-Fund. The ACS Manager is also required to have an order execution policy in place detailing (i) the systems and controls that have been put in place and (ii) how the ACS Manager will act in line with the best interests of the Scheme and the Sub Funds whilst complying with its obligations to obtain the best possible result, when it directly executes an order, places an order with, or transmits an order to, another entity for execution. Copies of the ACS Manager’s order execution policy and of the Investment Manager’s order execution policy which the ACS Manager relies on, are available from the ACS Manager on request. If you have any questions regarding the policy please contact the ACS Manager.
Securities may be held by, or be an appropriate investment for, the Scheme as well as by or for the ACS Manager's other clients, clients of the Investment Managers or other companies in the Aviva Group. Because of different objectives or other factors, a particular security may be bought for one or more such clients, when other clients are selling the same security. If purchases or sales of securities for the Scheme or such clients arise for consideration at or about the same time, such transactions will be made, insofar as feasible, for the relevant clients in a manner deemed equitable to all.
Establishing, holding or unwinding opposite positions (i.e. long and short) in the same security at the same time for different clients may prejudice the interests of clients on one side or the other and may pose a conflict of interest particularly if the ACS Manager or the Investment Managers involved may earn higher compensation from one activity than from the other. This activity may occur as a result of different portfolio management teams taking different views of a particular security or in the course of implementing risk management strategies, and special policies and
procedures are not generally utilised in these situations.
This activity may also occur within the same portfolio management team as a result of the team having both long only mandates and long-short or short only mandates or in the course of implementing risk management strategies. Where the same portfolio management team has such mandates, shorting a security in some portfolios that is held long in other portfolios or establishing a long position in a security in some portfolios that is held short in other portfolios may be done only in accordance with established procedures designed to ensure the presence of appropriate fiduciary rationale and to achieve execution of opposing transactions in a manner that does not systematically advantage or disadvantage any particular set of clients. Aviva Group compliance team monitors compliance with these policies and procedures and may require their modification or termination of certain activities to minimise conflicts. Exceptions to these procedures must be approved.
The rationales that may justify taking opposite positions in the same security at the same time may include, without limitation, the following: (i) differing views as to the short-term and long-term performance of a security, as a result of which it may be inappropriate for long only accounts to sell the security but may be appropriate for short-term oriented accounts that have a shorting mandate to short the security over the near term; and (ii) to neutralise the effect of the performance of a particular segment of one company's business by taking the opposite position in another company whose business is substantially similar to that of the segment in question.
In certain cases efforts to effectively manage these conflicts may result in a loss of investment opportunity for its clients or may cause it to trade in a manner that is different from how it would trade if these conflicts were not present, which may negatively impact investment performance.
The investment activities of the Aviva Group for its own account may limit the investment strategies that can be conducted on behalf of the Scheme by the Investment Managers as a result of aggregation limits. For example, the definition of corporate and regulatory ownership of regulated industries in certain markets may impose limits on the aggregate amount of investment by affiliated Unitholders that may not be exceeded. Exceeding these limits without the grant of a licence or other regulatory or corporate consent may cause the Aviva Group and the Scheme to suffer disadvantages or business restrictions. If such aggregate ownership limits are reached, the ability of the Scheme to purchase or dispose of investments or exercise rights may be restricted by regulation or otherwise impaired. As a result the Investment Managers on behalf of the Scheme may limit purchases, sell existing investments or otherwise restrict or limit the exercise of rights (including voting rights) in light of potential regulatory restrictions on ownership or other restrictions resulting from reaching
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investment thresholds. As a consequence, a Scheme's ability to provide returns that reflect the performance of the relevant benchmark index may be affected.
(d) Additional Conflicts of Interest in the Context of Delegation
In addition to the conflicts described above, conflicts may arise between the interests of the ACS Manager and its permitted delegates in certain circumstances, for example, where there is likelihood that: (i) the delegate and a Unitholder in a Scheme are members of the same group or have any other contractual relationship, if the Unitholder controls the delegate or has the ability to influence its actions (in such cases the likelihood of conflict is likely to increase the greater the extent of such control); (ii) the delegate makes a financial gain, or avoids a financial loss, at the expense of the Scheme or the Unitholders in that Scheme; (iii) the delegate has an interest in the outcome of a service or an activity provided to the ACS Manager or the Scheme; (iv) the delegate has a financial or other incentive to favour the interest of another client over the interests of the Scheme or the Unitholders in that Scheme; (v) the delegate receives or will receive from a person other than the ACS Manager an inducement in relation to the collective portfolio management activities provided to the ACS Manager and the Scheme in the form of monies, goods or services other than the standard commission or fee for that service.
Any conflict that may arise from the ACS Manager’s delegation of securities lending to the Securities Lending Agent is managed, in addition to the measures identified in this section 29, by the appointment of the Securities Lending Agent on normal commercial terms negotiated at arm’s length. The Aviva Group has written policies and procedures in place to monitor the conflicts of interest that may arise in the context of the ACS Manager's delegation of certain of its functions. To the extent any actual conflicts of interest are determined to have arisen, the Aviva Group will manage such conflicts to minimise any impact on the investment performance, and will also seek to prevent them from reoccurring. Certain activities may be required to be modified or terminated to minimise conflicts of interest which may be identified from time to time. Where a conflict of interest cannot be avoided, the ACS Manager will ensure that the Scheme and the other funds it manages are fairly treated.
The ACS Manager maintains a written conflict of interest policy. The ACS Manager acknowledges that there may be some situations where the organisational or administrative arrangements in place for the management of conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the Scheme or its Unitholders will be prevented. Should any such situations arise the ACS Manager will, as a last resort if the conflict cannot be avoided disclose these to Unitholders in an appropriate format.
(e) Service Providers Certain entities in which a Sub-Fund has an investment (whether directly or indirectly) may also provide goods or services to, or have a business, financial or other relationship with other Sub-Funds of the Scheme, ACS Manager, their associates and other funds managed by the ACS Manager or their associates. Such entities may also be a source of financing and investment opportunities or co-investors in investments made by the Sub-Funds (whether directly or indirectly) or other funds managed by the ACS Manager or their associates. These relationships may influence the ACS manager or their associates in deciding whether to select or recommend a supplier of goods or a service provider to perform services for the Sub-Funds or other funds managed by the ACS Manager or associates (the cost of which will generally be borne directly or indirectly by the Sub-Fund or such other funds). Notwithstanding the above, the selection of such entities that may provide goods and services will generally be allocated based on an evaluation which includes such entities’ provision of certain goods and services that the ACS Manager or associates believes to be of benefit to a Sub-Fund, or such other funds managed by the ACS Manager or associates.
30. Fair Treatment The detailed rights and obligations of the Depositary, ACS Manager and Unitholders are set out in the ACS Deed. The ACS Manager ensures that the ACS Deed is made available for review by each Unitholder as set out in section 36 (viii), such that each Unitholder is informed about its rights and obligations under that document. The ACS Manager seeks to ensure fair treatment of all Unitholders by complying with the terms of the ACS Deed and applicable law.
31. Changes to the Scheme and Meetings of Unitholders Changes to any Scheme may be made in accordance with the method of classification described in sections (a), 31(b) and 31(c) below.
(a) Fundamental Change A fundamental change is a change or event which: (i) changes the purpose or nature of the Scheme; or (ii) may materially prejudice a Unitholder; or (iii) alters the risk profile of a Sub-Fund of the Scheme; or (iv) introduces any new type of payment out of Scheme property. The ACS Manager will obtain prior approval from Unitholders to any fundamental change by way of an extraordinary resolution of the Unitholders of the Scheme. See below for details of calling a meeting of Unitholders.
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(b) Significant Change A significant change is a change or event which the ACS Manager and Depositary have determined is not a fundamental change but is a change which: (i) affects a Unitholder's ability to exercise his rights in relation to his investment; or would reasonably be expected to cause a Unitholder to reconsider his participation in the Scheme; or (ii) results in any increased payments out of Scheme property to the ACS Manager or any of its associate companies; or (iii) materially increases other types of payment out of Scheme property. The ACS Manager will give Unitholders at least 60 days' notice in advance of implementing any significant change.
(c) Notifiable Change A notifiable change is a change or event, other than a fundamental change or a significant change, which is reasonably likely to affect or have affected the operation of the Scheme. Depending on the nature of the change the ACS Manager will inform Unitholders of notifiable events either by: (i) sending of an immediate notification to Unitholders; or (ii) publishing information about the change on the ACS Manager's website; or (iii) including it in the next report for the Scheme.
(d) Notice The ACS Manager will write to Unitholders at their registered postal or e-mail address (as applicable) to give notice of any fundamental, significant, or notifiable changes, as appropriate.
(e) Meetings of Unitholders Rules for the calling and conduct of meetings of Unitholders and the voting rights of Unitholders at such meetings are governed by the COLL Sourcebook and the ACS Deed. At a meeting of Unitholders a resolution put to the vote shall be decided on a show of hands unless a poll is demanded by the chairman, by the Depositary or by at least two Unitholders present in person or by proxy. On a show of hands every Unitholder who (being an individual) is present in person or, (being a corporation) is present by its representative properly authorised in that regard, has one vote. On a poll the voting right for each Unit must be the proportion of the voting rights attached to all of the Units in issue that the value of the Unit bears to the aggregate value of all the Units in issue. A person entitled to more than one vote need not use all his votes or cast all the votes he uses in the same way. A corporation being a Unitholder may authorise such a person as it thinks fit to act as its representative at any meeting of Unitholders and the person so authorised
shall be entitled to exercise the same powers on behalf of the corporation which he represents as the corporation could exercise if it were an individual Unitholder. In the case of joint Unitholders any joint Unitholder may vote provided that if more than one votes the most senior Unitholder in the Register who tenders a vote whether in person or by proxy shall be accepted to the exclusion of the votes of the other joint Unitholders. For this purpose seniority will be determined by the order in which the names stand in the register of Unitholders. On a poll, votes may be given either personally or by proxy. The ACS Manager and its associates may hold Units in the Sub-Funds. The ACS Manager is entitled to receive notice of and attend any meeting but it is not entitled to vote or be counted in the quorum and its Units are not regarded as being in issue in relation to such meetings. An associate of the ACS Manager may be counted in the quorum but may not vote except where the associate is in receipt of voting instructions in respect of Units held on behalf of a person who, if himself the registered Unitholder, would be entitled to vote, and from whom the associate has received voting instructions.
32. Winding Up The Scheme may be wound up upon the happening of any of the following: the order declaring it to be an authorised contractual scheme is revoked; or in response to a request to the FCA by the ACS Manager or the Depositary for the revocation of the order declaring it to be an authorised contractual scheme the FCA has agreed, albeit subject to there being no material change in any relevant factor, that, on the conclusion of the winding up of the authorised contractual scheme, the FCA will accede to that request; or the effective date of a duly approved scheme of arrangement, which is to result in the authorised contractual scheme being left with no property. On a winding up (otherwise than in accordance with an approved scheme of arrangement) the Depositary is required as soon as practicable after a Sub-Fund falls to be wound up, to realise the property of a Sub-Fund and, after paying out of the Sub-Fund or retaining adequate provision for all liabilities properly so payable and retaining provision for the costs of the winding up, to distribute the proceeds of that realisation to the Unitholders and the ACS Manager (upon production by them of such evidence as the Depositary may reasonably require as to their entitlement) proportionately to their respective interests in a Sub Fund as at the date of the relevant event. The Depositary may, in certain circumstances, (and with the agreement of the affected Unitholders) distribute property of a Sub-Fund (rather than the proceeds on the realisation of that property) to Unitholders on a winding-up.
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Any unclaimed net proceeds or other cash held by the Depositary after the expiration of twelve months from the date on which the same became payable is to be paid by the Depositary into court subject to the Depositary having a right to retain from those net proceeds or other cash any expenses incurred in making the payment into court. If the Scheme is to be wound up in accordance with an approved scheme of arrangement, the Depositary is required to wind up the Scheme in accordance with the resolution of Unitholders approving such scheme. Distributions will only be made to Unitholders entered on the register. Any net proceeds or cash (including unclaimed distribution payments) held by the Depositary which have not been claimed after 12 months will be paid into court, after the deduction by the Depositary of any expenses it may incur.
33. Allocation of Income The income available for allocation by distribution is determined in accordance with the COLL Sourcebook and the Investment Management Association's Statement of Recommended Practice for Accounting Standards for Investment Funds (SORP). Distributable income comprises all income received or receivable for the account of any Sub-Fund in respect of the accounting period concerned, after deducting net charges and expenses paid or payable out of such income and after making such adjustments as the ACS Manager considers appropriate, in accordance with the COLL Sourcebook. Income on debt securities, such as bonds and other fixed interest securities is calculated using the "Effective Interest Rate" method, in accordance with the methodology laid down in the FRS 102 (UK GAAP). The Effective Interest Rate method for calculating income generated from debt securities, treats any premiums and discounts arising on the purchase of a debt security (when compared to its maturity or par value) as income and this, together with any future expected income streams on the debt security, is amortised (written off) over the life of that security (to its maturity) and discounted back to its present value and included in the calculation of distributable income. For the purposes of allocating income, the ACS Manager will determine on an annual basis, with reference to the objectives of a Sub-Fund, whether such income should exclude premiums and discounts arising on purchase of bonds attributed through the Effective Interest Rate method. Each Sub-Fund will distribute any available income in accordance with the provisions of section 21 following the end of each of its accounting periods in relation to which it has an income allocation date. Each accounting period ends on an accounting date (either interim or final). Details of the accounting periods and income allocation dates for each Sub-Fund are set out in Appendix 1.
34. Information Made Available to Unitholders Under the UK AIFM Regime and the COLL Sourcebook, the ACS Manager must periodically disclose to Unitholders certain information in relation to the Scheme. This includes providing disclosure on each Sub-Fund's risk profile, which, as prescribed in the UK AIFM Regime, shall outline: (i) the measures used to assess the sensitivity of a Sub-Fund's portfolio to the most relevant risks to which that Sub-Fund is or could be exposed; and (ii) if risk limits set by the ACS Manager have been or are likely to be exceeded and, where these risk limits have been exceeded, a description of the circumstances and the remedial measures taken. The ACS Manager intends to comply with its periodic disclosure requirements in the manner set out below. The following information will be made available to Unitholders, as a minimum, as part of the Scheme's annual report:
(i) the percentage of each Sub-Fund's assets which are subject to special arrangements arising from their illiquid nature;
(ii) any new arrangements for managing the liquidity of a Sub-Fund; (iii) the current risk profile of each Sub-Fund and the risk management systems employed by the ACS Manager to manage those risks; and the total amount of leverage employed by each Sub-Fund. Unitholders will also be provided with information regarding changes to (i) the maximum level of leverage which a Sub-Fund, or the ACS Manager on that Sub Fund's behalf, may employ; or (ii) the rights for re-use of collateral under a Sub-Fund's leveraging arrangements; or (iii) any guarantee granted under a Sub-Fund's leveraging arrangements. This information will be made available to Unitholders, without undue delay following the occurrence of that change, usually by way of update to this Prospectus. Where required, such change will be preceded by notification to Unitholders. It is intended that Unitholders will be notified immediately if a Sub-Fund uses its powers of deferral in relation to redemption requests, activates similar liquidity management arrangements, or if the ACS Manager decides to suspend redemptions. Unitholders will also be notified whenever the ACS Manager makes material changes to liquidity management systems and procedures employed in respect of a Sub-Fund.
35. Telephone recording The ACS Manager may record telephone calls for training and monitoring purposes and to confirm investors’ instructions. Recordings will be provided on request for a period of at least five years from the date of such recording, or, where requested by a competent regulatory authority, for a period of seven years, where the ACS Manager can identify the call coming from the
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relevant investor. If the ACS Manager is requested to provide a recording of a particular call, the ACS Manager may ask for further information to help it identify the exact call to which the request relates.
36. Additional Information
(i) Each Sub-Fund is only available for investment by: (i) a professional ACS investor; (ii) a large ACS investor; or (iii) a person who already holds Units in the Scheme (as these terms are defined in the FCA Handbook). This means the Scheme is designed for investment by institutional investors and not members of the general public. The ACS Manager will not consider the suitability or appropriateness of an investment in the Sub-Funds for an Unitholder's individual circumstances. Unitholders should be willing to accept capital and income risk, which may vary greatly from Sub-Fund to Sub-Fund. The Sub Funds are not suitable for short term investment and should therefore generally be regarded as long-term investments. The price of Units in a Sub-Fund, and any income from them, can go down as well as up and is not guaranteed. (ii) A subscription for or redemption of Units by approved electronic communication and/or in writing is a legally binding contract (see section 11 for more details regarding a Unitholder's contract for investment). (iii) Any person relying on the information contained in this Prospectus, which was current at the date shown, should check with the ACS Manager that this document is the most recent version and that no revisions have been made nor corrections published to the information contained in this Prospectus since the date shown. This document is important and Unitholders should read all the information contained in it carefully. If Unitholders are in any doubt as to the meaning of any information contained in this document, Unitholders should consult either the ACS Manager or their financial adviser. The ACS Manager has taken all reasonable care to ensure that the facts stated herein are true and accurate in all material respects and that there are no material facts, the omission of which would make misleading any statement herein whether of fact or opinion. (iv) Annual and half-yearly reports on the Scheme are available free of charge on request by visiting the ACS Manager's website https://www.avivainvestors.com/en gb/institutional/fund-centre/tax-transparent.html or speaking to its Client Relationship Management Team on 0207 809 8135. 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” above for further information. The reports include the following details in relation to each Sub-Fund: the investment objectives, the policy and strategy pursued to achieve those objectives, a review of the investment activities for the period covered by the report and a list of holdings of securities. The ACS Manager must, within four months after the end of each annual accounting period and two months after the end of each half-yearly accounting period respectively, make available and publish such reports. For information on the publication dates pertaining to the reports of each of the Sub-Funds, please refer to Appendix 1. (v) Complaints may be made about the operation of the Scheme or any aspect of the service received to the Compliance Officer of the ACS Manager at its registered address. Making a complaint will not prejudice a Unitholder's right to take legal action. Written details of the ACS Manager's complaints procedure are available from the ACS Manager upon request. Making a complaint will not prejudice a Unitholder’s right to take legal proceedings. The ACS Manager is a participant in the Financial Services Compensation Scheme. Unitholders may be entitled to compensation from the scheme if the ACS Manager cannot meet its obligations. This depends on the type of business and the circumstances of the claim. Further information about the Financial Services Compensation Scheme is available on request, or by contacting the FSCS Limited at 10 th Floor, Beaufort House, 15 St. Botolph Street, London EC3A 7QU Tel: 0800 6781100. Further information regarding any compensation scheme or any other investor compensation scheme of which the ACS Manager or any Sub-Fund is a member (including, if relevant, membership through a branch) or any alternative arrangement provided, are also available on request. Each Sub-Fund qualifies as a non-UCITS retail scheme and will only be marketed in the UK. (vi) Copies of the ACS Deed, key investor information document, the most recent annual and half-yearly reports and the COLL Sourcebook may be inspected at the ACS Manager's registered office during Normal Business Hours. Copies of the Prospectus may be obtained from the ACS Manager at its registered office free of charge and copies of the ACS Deed are available free of charge to Unitholders and at a charge of up to £5 per copy for each ACS Deed for non-Unitholders. (vii) The personal details of each Unitholder will be held by the ACS Manager in accordance with current data protection law for the purposes of carrying out its agreement with each Unitholder.
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This may include the transfer of such data (i) to other members of the Aviva Group and (ii) to other businesses (including their offices outside the European Union) where the transfer is necessary for the provision of services in relation to any of the Aviva Group's investment products or services. Unitholders have the right to access their personal data processed by the Aviva Group together with the right to object to the processing of such data for legitimate reasons. Information regarding the ACS Manager's data protection policies is available upon request.
37. Client Money (i) All money received from you or due to be paid to you will be held in bank accounts domiciled in the UK. When the money is held outside the Delivery versus Payment window (defined above) it will be held in a client money bank account and segregated from the ACS Manager’s own money as required by the FCA’s Client Asset (CASS) Rules. Money held in client money bank accounts will not accrue interest. No interest will be paid to you, and none will be retained by the ACS Manager. (ii) The ACS Manager will send an annual client money statement if it holds any client money for you on the statement date. (iii) Where the ACS Manager holds money for you and has been unable to return it to you for a period of at least six years, despite trying to contact you, the CASS Rules permit us to pay the unclaimed client money (excluding unclaimed distributions of income) to charity. The payment of unclaimed money to charity does not prevent you from claiming the money in the future, and we will honour all valid claims whether or not the unclaimed money has been paid to charity.
38. Restrictions on investment and holding of Aviva Plc shares and other Aviva securities All Sub-Funds, with the exception of the AI UK Listed Equity Fund and the AI UK Listed Equity Income Fund, are prohibited from directly investing in or holding Aviva Plc shares. The AI UK Listed Equity Fund and the AI UK Listed Equity Income Fund both received holdings of Aviva Plc shares on launch of the Sub-Funds, via an in-specie transfer (‘Legacy Holdings’). These Sub-Funds are permitted to continue to hold these Legacy Holdings but are prohibited from making any new direct investment in Aviva Plc shares.
The ACS Manager has determined to extend these restrictions, and with effect from 17 February 2020, in addition to the restrictions outlined above, Sub-Funds that are managed by investment managers within the Aviva group,
such as Aviva Investors Global Services Limited, shall no longer be permitted to indirectly invest in or hold Aviva Plc shares, or directly or indirectly invest in or hold other securities issued by Aviva Plc such as bonds, commercial paper and derivatives of these securities (collectively ‘Aviva Securities’).
The prohibition on indirect exposure to Aviva Securities shall not include:
indirect exposure to a financial index, for example through an index future, where Aviva is a constituent of the financial index and,
investment in other funds managed by third parties, where the underlying funds may have exposure to Aviva Securities. For further details on the Funds which are impacted refer to Appendix 6 Investment Restrictions applicable to the Scheme.
39. Firm-level stewardship and ESG Integration approach
The Investment Manager endeavours to comply with the requirements of the UK Stewardship Code. Stewardship is the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries. Environmental and social factors, in addition to governance, can be material issues for fund managers to consider when making investment decisions and undertaking stewardship. We therefore seek to integrate financially material ESG insights into the investment process to allow for better risk management, the identification of investment opportunities and to support the delivery of long-term risk-adjusted returns. These considerations are not binding on the investment manager's decision beyond any specific criteria in the relevant mandate or in this prospectus. ESG insights also inform our stewardship activities, including considering the potential or actual material risk that sustainability issues may have on an investment. For more information on how the Investment Manager carries out this activity and meets the requirements of the UK Stewardship Code, as well as details about Aviva Investors’ firmwide policies, please see www.avivainvestors.com/en gb/about/responsible-investment/policies-and documents . These disclosures are consistent with Aviva Investors’ obligations under the FCA Rules as set out in COBS 2.2B to disclose our approach to engagement and voting.
40. Benchmark Regulation
The ACS Manager is required under the Benchmark Regulation to set out whether the benchmarks used by the Sub-Funds are provided by administrators in the UK and are included in the FCA Benchmarks
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Register, or by administrators who have registered with the European Securities and Markets Authority (“ESMA”) as an EEA benchmark administrator and are included in the ESMA Register of Benchmarks. The FCA has confirmed equivalence which means any EEA benchmark administrators included in the ESMA Register of Benchmarks will be able to access UK markets and UK supervised entities can continue to use their benchmarks on that basis. The UK Government has extended the transitional period for all third country benchmarks set out in Benchmark Regulation from the end of 2022 to the end of 2025. That means UK supervised entities are permitted to use all third country benchmarks until the end of 2025 without further action from the EEA benchmark administrator.
As at the date of this Prospectus, the relevant benchmark administrators are MSCI® Limited, S&P® Dow Jones Indices LLC, ICE Benchmark Administration Limited, JPX Market Innovation & Research, Inc, J.P. Morgan Securities LLC, FTSE® International Limited, Bloomberg Index Services Limited, and The Bank of England, who have registered, as required, as a Benchmark Administrator in respect of those benchmarks referred to in this Prospectus.
41. Index Disclaimers Where a Sub-Fund refers to an index in its investment objective and or policy, the index provider does not approve, sponsor, advise, review, recommend, endorse, produce or promote the Sub Fund, and in particular for the following index providers, please note the following:
Index provider
Disclaimer
FTSE International Limited
The Sub-Funds have been developed solely by Aviva Investors UK Fund Services Limited. The Sub Funds are not in any way connected to or sponsored, endorsed, sold or promoted by the London Stock Exchange Group plc and its group undertakings (collectively, the “LSE Group”). FTSE International is a trading name of certain of the LSE Group companies. All rights in FTSE International vest in the relevant LSE Group company which owns the Index. “FTSE®”, “FTSE International ®”, “Russell®”, “FTSE Russell®”, are a trade mark(s) of the relevant LSE Group company and is/are used by any other LSE Group company under license. The Index is calculated by or on behalf of FTSE International Limited or its affiliate, agent or partner. The LSE Group does not accept any liability whatsoever to any person arising out of (a) the use of, reliance on or any error in the Index or (b) investment in or operation of
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the Sub-Funds. The LSE Group makes no claim, prediction, warranty or representation either as to the results to be obtained from the Sub Funds or the suitability of the Index for the purpose to which it is being put by Aviva Investors UK Fund Services Limited. MSCI Limited Certain information contained herein (the “Information”) is sourced from/copyright of MSCI Inc., MSCI ESG Research LLC, or their affiliates (“MSCI”), or information providers (together the “MSCI Parties”) and may have been used to calculate scores, signals, or other indicators. The Information is for internal use only and may not be reproduced or disseminated in whole or part without prior written permission. The Information may not be used for, nor does it constitute, an offer to buy or sell, or a promotion or recommendation of, any security, financial instrument or product, trading strategy, or index, nor should it be taken as an indication or guarantee of any future performance. Some funds may be based on or linked to MSCI indexes, and MSCI may be compensated based on the fund’s assets under management or other measures. MSCI has established an information barrier between index research and certain Information. None of the Information in and of itself can be used to determine which securities to buy or sell or when to buy or sell them. The Information is provided “as is” and the user assumes the entire risk of any use it may make or permit to be made of the Information. No MSCI Party warrants or guarantees the originality, accuracy and/or completeness of the Information and each expressly disclaims all express or implied warranties. No MSCI Party shall have any liability for any errors or omissions in connection with any Information herein, or any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) even if notified of the possibility of such damages. S&P Dow Jones Indices Limited
An index referenced as “Markit” and the S&P® 500 Total Return GBP Index (“Index(es)”) are products of S&P Dow Jones Indices LLC or its affiliates (“SPDJI”), and have been licensed for use by Aviva Investors Global Services Limited. S&P®,
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Aviva Investors Funds ACS Prospectus (5 October 2026) 46
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S&P 500®, SPX®, SPY®, US 500 ™ , The 500 ™ , iBoxx®, iTraxx® and CDX® are trademarks of S&P Global, Inc. or its affiliates (“S&P”); Dow Jones® is a registered trademark of Dow Jones Trademark Holdings LLC (“Dow Jones”); and none of such parties make any representation regarding the advisability of investing in such product(s) nor do they have any liability for any errors, omissions, or interruptions of the relevant Index.
JPX Market Innovation & Research, Inc
The Total Return TOPIX ® Index and the Total Return TOPIX ® Index Marks are subject to the proprietary rights owned by JPX Market Innovation & Research, Inc. or affiliates of JPX Market Innovation & Research, Inc. (hereinafter collectively referred to as "JPX") and JPX owns all rights and know-how relating to Total Return TOPIX ® Index such as calculation, publication and use of the Total Return TOPIX ® Index and relating to the Total Return TOPIX ® Index Marks. JPX shall not be liable for the miscalculation, incorrect publication, delayed or interrupted publication of the Total Return TOPIX ® Index. ICE Data Indices, LLC
Source ICE Data Indices, LLC (“ICE Data”), is used with permission. ICE® is a registered trademark of ICE Data or its affiliates and BOFA® is a registered trademark of Bank Of America Corporation licensed by Bank Of America Corporation and its affiliates ("BOFA") and may not be used without BOFA'S prior written approval. ICE Data, its affiliates and their respective third party suppliers disclaim any and all warranties and representations, express and/or implied, including any warranties of merchantability or fitness for a particular purpose or use, including the indices, index data and any data included in, related to, or derived therefrom. Neither ICE Data, its affiliates nor their respective third party suppliers shall be subject to any damages or liability with respect to the adequacy, accuracy, timeliness or completeness of the indices or the index data or any component thereof, and the indices and index data and all components thereof are provided on an “as is” basis and your use is at your own risk. ICE Data, its affiliates
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and their respective third party suppliers do not sponsor, endorse, or recommend Aviva Investors Global Services Limited, or any of its products or services. J.P. Morgan Securities LLC
Information has been obtained from sources believed to be reliable but J.P. Morgan does not warrant its completeness or accuracy. The Index is used with permission. The Index may not be copied, used, or distributed without J.P. Morgan's prior written approval. Copyright 2025, J.P. Morgan Chase & Co. All rights reserved. Bloomberg Index Services Limited
“Bloomberg®” and the Bloomberg indices listed herein (the “Indices”) are service marks of Bloomberg Finance L.P. and its affiliates, including Bloomberg Index Services Limited (“BISL”), the administrator of the index (collectively, “Bloomberg”), and have been licensed for use for certain purposes by Aviva Investors Global Services Limited.
The Sub-Funds are not sponsored, endorsed, sold or promoted by Bloomberg. Bloomberg does not make any representation or warranty, express or implied, to the owners of or counterparties to the Sub-Funds or any member of the public regarding the advisability of investing in securities or commodities generally or in the Sub-Funds particularly. The only relationship of Bloomberg to Aviva Investors Global Services Limited is the licensing of certain trademarks, trade names and service marks and of the Indices, which are determined, composed and calculated by BISL without regard to Aviva Investors Global Services Limited or the Sub-Funds. Bloomberg has no obligation to take the needs of Aviva Investors Global Services Limited or the Sub-Funds into consideration in determining, composing or calculating the Indices. Bloomberg is not responsible for and has not participated in the determination of the timing, price, or quantities of the Sub-Funds to be issued. Bloomberg shall not have any obligation or liability, including, without limitation, to customers of the Sub-Funds, in connection with the administration, marketing or trading of the Sub-Funds.
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Aviva Investors Funds ACS Prospectus (5 October 2026) 47
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BLOOMBERG DOES NOT GUARANTEE THE ACCURACY AND/OR THE COMPLETENESS OF THE INDICES OR ANY DATA RELATED THERETO AND SHALL HAVE NO LIABILITY FOR ANY ERRORS, OMISSIONS OR INTERRUPTIONS THEREIN. BLOOMBERG DOES NOT MAKE ANY WARRANTY, EXPRESS OR IMPLIED, AS TO RESULTS TO BE OBTAINED BY LICENSEE, OWNERS OF THE SUB-FUNDS OR ANY OTHER PERSON OR ENTITY FROM THE USE OF THE INDICES OR ANY DATA RELATED THERETO. BLOOMBERG DOES NOT MAKE ANY EXPRESS OR IMPLIED WARRANTIES AND EXPRESSLY DISCLAIMS ALL WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE WITH RESPECT TO THE INDICES OR ANY DATA RELATED THERETO. WITHOUT LIMITING ANY OF THE FOREGOING, TO THE MAXIMUM EXTENT ALLOWED BY LAW, BLOOMBERG, ITS LICENSORS, AND ITS AND THEIR RESPECTIVE EMPLOYEES, CONTRACTORS, AGENTS, SUPPLIERS, AND VENDORS SHALL HAVE NO LIABILITY OR RESPONSIBILITY WHATSOEVER FOR ANY INJURY OR DAMAGES— WHETHER DIRECT, INDIRECT, CONSEQUENTIAL, INCIDENTAL, PUNITIVE OR OTHERWISE— ARISING IN CONNECTION WITH THE SUB-FUNDS OR INDICES OR ANY DATA OR VALUES RELATING THERETO—WHETHER ARISING FROM THEIR NEGLIGENCE OR OTHERWISE, EVEN IF NOTIFIED OF THE POSSIBILITY THEREOF. The Bank of England
The Bank of England (the benchmark administrator of SONIA) does not endorse, approve or guarantee any ICE SONIA Index, and it expressly disclaims any liability for any ICE SONIA Index, and makes no representations or warranties whether express or implied, that any ICE SONIA Index contains, comprises or is based on the SONIA benchmark, nor does it make any representations or warranties whether express or implied as to the currency, accuracy, timeliness, completeness or fitness of any ICE SONIA Index. To the extent that any
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ICE SONIA Index comprises or is based on the SONIA benchmark, the "SONIA" mark is used under licence from the Bank of England and the use of such mark does not imply or express any approval or endorsement by the Bank of England. SONIA is copyright the Bank of England. The trade marks “Bank of England” and “SONIA” are registered trade marks of the Bank of England. All Rights Reserved. The SONIA benchmark includes the proprietary information of the Bank of England and the data comprising the SONIA benchmark may not be copied or distributed except as specifically authorised. The SONIA benchmark is not intended to be relied upon as authoritative or taken in substitution for the exercise of judgement and do not constitute investment advice. The SONIA benchmark is not, and should not be construed as, an offer, bid or solicitation in relation to any financial instrument. The Bank of England does not guarantee, and expressly disclaims any liability for, and makes no representations or warranties whether express or implied, as to the currency, accuracy, timeliness, completeness or fitness for any particular purpose of the SONIA benchmark. The Bank of England accepts no liability whatsoever for any loss (including, but not limited to any direct, indirect or consequential loss, whether or not such loss is foreseeable and whether or not the Bank of England has been appraised of the use to which the SONIA benchmark will be put) howsoever arising from the use, the timeliness of delivery or the failure of delivery of the SONIA benchmark
42. Preferential Treatment From time to time the ACS Manager may afford preferential terms to certain investors or certain groups of investors. In assessing whether such terms are afforded to an investor, the ACS Manager will ensure that any such concession is not inconsistent with its obligation to act in the overall best interests of the relevant Sub-Fund and its investors. In particular, the ACS Manager may exercise its discretion to waive charges or investment minima for investment in a Class by investors that are investing sufficiently large amounts or institutional investors including investors within the ACS Manager’s group. The ACS Manager may also have agreements in place with such groups
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Aviva Investors Funds ACS Prospectus (5 October 2026) 48
of investors which result in them paying a reduced ACS Management Charge.
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Aviva Investors Funds ACS Prospectus (5 October 2026) 49
Aviva Investors: Confidential
APPENDIX 1
AI Stewardship UK Equity Fund # FCA product reference number: 658285
The Sub-Fund is a sub-fund of the Scheme, a non-UCITS retail scheme under the COLL Sourcebook. The Sub-Fund was authorised by the FCA on 5 December 2014.
This product does not have a UK sustainable investment label. This is because – although the Sub-Fund has sustainability characteristics - it does not currently meet the criteria for a label. Sustainable investment labels help investors find products that have a specific sustainability goal. They can be applied to funds with an explicit sustainability objective that also meet other specific regulatory criteria for a UK sustainable investment label.
Investment Objectives The Sub-Fund aims, through the responsible allocation of capital, to grow your investment and provide an average annual net return greater than the FTSE® All-Share Custom Index over a rolling 5-year period through investment in shares of UK companies. At least 85% of the Sub-Fund’s investments (the “ minimum stewardship allocation ”) must contribute to one of three pillars through their products and services or through their operations:
∙ Climate - for example, tackling the causes or impacts of climate change;
∙ Earth - for example, tackling increasing biodiversity loss and resource scarcity;
∙ People - for example, tackling social inequality and unfair working practices.
Further details on the Investment Manager’s proprietary investment framework are set out under “Sustainability Strategy” below.
Investment Policy
Core investment: At least 85% of the Sub-Fund will be invested in shares of companies domiciled or incorporated in the UK. Other investments : The Sub-Fund may also invest in other shares, other funds (including funds managed by Aviva Investors companies), derivatives, cash and deposits. Derivatives may be used for investment purposes or to gain a particular market exposure which would otherwise be difficult or costly to achieve, or to manage the Sub-Fund’s cash flows in a cost-effective manner. Derivatives may also be used to reduce risk, such as foreign currency risk within the Sub-Fund. Exclusions: The Sub-Fund is subject to two sets of screens, the Aviva Investors’ baseline exclusion policy and the stewardship exclusions, which exclude companies that do not meet certain ethical, social and environmental standards, so that the Sub-Fund does not invest in companies that the Investment Manager regards as incompatible with the three pillars of Climate, People and Earth. The purpose of these screens is to ensure that the Sub-Fund does not invest in companies that derive prescribed levels of revenue from a range of activities, including certain fossil fuel (thermal coal, oil and gas) activities, or companies that have significant reserves of certain fossil fuels, activities that are not compatible with animal welfare, or certain activities connected to alcohol and gambling, genetic modification and adult entertainment - please see Appendices 2 and 3 for information on these investment restrictions . If there are any differences between the baseline exclusion policy and the stewardship exclusions, the more restrictive exclusions will apply. As these screens only exclude shares issued by companies, this screening process is not applied to other investments, for example cash and certain derivatives. Investment Strategy and Asset Selection: The Sub-Fund is actively managed, selecting investments aligned to the Sub-Fund’s growth aims and in-line with the Sub-Fund’s Sustainability Strategy (see below). The Investment Manager aims through the responsible allocation of capital (stewardship) to encourage companies to improve environmental and/or social outcomes through their products and services, and/or through their operations.
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Aviva Investors Funds ACS Prospectus (5 October 2026) 50
Aviva Investors: Confidential
The Investment Manager has the discretion to build a diverse portfolio of companies of any size, at any stage of the business cycle and across different industry sectors with an emphasis on risk management within the Sub-Fund. Once any excluded companies have been removed from the available investment universe (see above), the Sub Fund must invest in its minimum stewardship allocation. To be eligible for investment, the company must meet the Fund’s qualifying criteria through either the company’s:
Products and Services - consideration will be given to the revenue a company generates from products and services that are linked to investment themes that fall under one or more of the three pillars.
Operations – consideration is given to the sustainability practices of a company’s operations. The Investment Manager may look at a range of factors to assess a company’s operations against investment themes linked to the three pillars, including (for example) its governance commitments, policies and actions to manage social and environmental issues, and performance compared to peers.
See “Sustainability Strategy” below for how the minimum stewardship allocation is achieved . Outside of its minimum stewardship allocation, up to 15% of the portfolio may be in investments that do not meet the standards required by the Investment Manager’s investment framework; the Investment Manager refers to these as “neutral” assets. Neutral assets include investments where the Investment Manager has otherwise determined that the issuing company has an overall neutral alignment to the three pillars (see “Sustainability Strategy” below), the nature of the asset is such that the sustainability characteristics of the asset are not possible to assess (for example, cash, third-party funds and derivatives) or where there is not sufficient sustainability data available to determine if that investment meets the Investment Manager’s criteria. The Sub-Fund may hold such neutral assets in order to support the financial objectives of the Sub-Fund, for liquidity purposes and for efficient portfolio management purposes. The Sub-Fund’s minimum stewardship allocation will be reviewed on an ongoing basis against a range of key performance indicators (KPIs) to ensure that they remain compliant with the Investment Manager’s investment framework – please see “Sustainability Strategy” below for further information. Performance & Risk Strategy: The Sub-Fund’s performance is measured against the FTSE® All-Share Custom Index (the “ Custom Index ”), □ a customised version of the FTSE® All-Share Index (the “ Index ”), that applies the same negative screening criteria as the Sub-Fund. The Sub-Fund’s performance is also compared to the Index □ . The Sub-Fund does not base its investment process upon the Index (applying specific exclusions, and the minimum stewardship allocation requirement, that do not apply to the Index) or the Custom Index. Therefore, the Sub-Fund will not hold every company in either the Index or the Custom Index and may also hold companies that do not form part of them. The Sub-Fund uses a “tracking error” to measure the consistency of the Sub-Fund's returns and the returns of the Custom Index. In general, the lower the tracking error, the more consistent the Sub-Fund’s returns are relative to the Custom Index, and vice-versa. The Sub-Fund is expected to have an average yearly tracking error of between 2% and 6% when compared to the Custom Index. In certain conditions the Sub-Fund may be outside of this range. The Index represents the performance of all eligible companies listed on the London Stock Exchange, and 98% of the UK’s market capitalisation (total market value of a company’s outstanding shares). The Index has been selected as a comparator benchmark for performance because it is representative of the UK equity market and the type of companies in which the Sub-Fund is likely to invest, although investors should be aware
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"text": "AVIVA INVESTORS NORTH AMERICAN EQUITY CORE FUND"
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"text": "AVIVA INVESTORS EMERGING MARKET EQUITY CORE FUND"
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"text": "This Prospectus is dated and is valid as at"
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"text": "Prepared in accordance with the Collective Investment Schemes Sourcebook and the FUND"
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"text": "Aviva Investors Funds ACS Prospectus (5 October 2026)"
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"text": "Aviva Investors: Confidential"
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"text": "AVIVA INVESTORS FUNDS ACS 4"
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"text": "THE ACS MANAGER 8"
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"text": "THE INVESTMENT MANAGERS"
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