Disclosures


The [United Kingdom] Stewardship Code

Sanctum FI LLP (the “Firm”) is authorised and regulated by the Financial Conduct Authority (FCA), UK. In relation to Rule 2.2.3 of the FCA Conduct of Business Standards (COBS), it may be noted that the Firm is an investment manager with only one client, the SANCTUM FIXED INCOME FUND, L.P. (the “Fund”). The Fund only invests in sovereign bonds and their associated derivatives. There are subsequently no investee companies in which the Firm interacts, or shareholder value to protect, and the Code cannot therefore have any application in relation to the Firm’s activities as an investment manager.

The Firm will keep the position under review, and should it consider expanding its range of activities it will determine whether the Code is likely to become applicable to its investment management activities and act accordingly to ensure compliance with the Code and the associated rules of the FCA or any successor regulator.

Notice to persons in [Switzerland]

The distribution of Shares in Switzerland will be exclusively made to, and directed at, qualified investors (the “Qualified Investors”), as defined in the Swiss Collective Investment Schemes Act of 23 June 2006, as amended (“CISA”) and its implementing ordinance (the “Swiss Distribution Rules”). Accordingly, the Fund has not been and will not be registered with the Swiss Financial Market Supervisory Authority (FINMA).

1. Representative
The representative in Switzerland is ARM Swiss Representatives SA, Route de Cité-Ouest 2, 1196 Gland, Switzerland.

2. Paying agent
The paying agent in Switzerland is Banque Heritage SA, 61 route de Chêne, Case Postale 6600, CH-1211 Geneve 6, Switzerland.

3. Location where the relevant documentation can be obtained
The Prospectus, the Articles of Association and annual financial statements can be obtained free of charge from the representative in Switzerland.

4. Place of performance and jurisdiction
The place of performance and jurisdiction is the registered office of the representative in Switzerland with regards to the Shares distributed in and from Switzerland.

Notice to persons in the [European Economic Area]

Sanctum Fixed Income Fund (the “Fund”) is an alternative investment fund for the purposes of the EU Alternative Investment Fund Managers Directive (2011/61/EU) (the “AIFMD”). Accordingly, shares in the Fund (the “Shares”) may not be marketed to prospective investors or discretionary investment managers which are domiciled or have a registered office in any member state of the European Economic Area (“EEA Persons”), save where expressly permitted under the laws of an EEA member state implementing Article 36 of the AIFMD. At the date hereof, Sanctum FI LLP (the “Manager”) intends to qualify the Fund for marketing under the laws of the following EEA member states implementing Article 36 of the AIFMD: the United Kingdom. Restrictions applicable to the marketing of the Fund in those EEA member states is set forth on this page.

Notice to persons in the [United Kingdom]

The Fund is an alternative investment fund for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the “FSMA”). Until the effective date of the Manager’s authorisation by the FCA as a Fullscope UK AIFM (the “Transition Date”), the Fund may be marketed to EEA Persons in the United Kingdom on the same basis as to Other Persons, as described below. From the Transition Date, provided the Fund has been qualified under Regulation 57 of the Alternative Investment Fund Managers Regulations 2013, the Fund may be marketed in the United Kingdom only to EEA Persons who qualify as “professional investors”, as defined under the FSMA. As regards prospective investors in the United Kingdom who are not EEA Persons (“Other Persons”), the Fund is a collective investment scheme and is not a recognised scheme for the purposes of the Financial Services and Markets Act 2000 of the United Kingdom (the “FSMA”). The communication in the United Kingdom of this website or of any invitation or inducement to invest in Shares is restricted by law. Accordingly, this website is directed only at Other Persons in the United Kingdom reasonably believed to be of a kind to whom such an invitation or inducement may lawfully be communicated (i) if effected by a person who is not an authorised person under the FSMA, pursuant to the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the “FPO”) or (ii) if effected by a person who is an authorised person under the FSMA, pursuant to the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001 (the “PCIS Order”) or the rules in Section 4.12 of the Conduct of Business Sourcebook of the Financial Conduct Authority of the United Kingdom. Such persons include: (a) persons having professional experience of participating in unregulated collective investment schemes and (b) high net worth bodies corporate, partnerships, unincorporated associations, trusts, etc. falling within Article 49 of the FPO or Article 22 of the PCIS Order. Investment in the Shares is available only to such persons, and persons of any other description may not rely on the information in this website. All prospective investors in the United Kingdom are advised that all, or most, of the rules made under the FSMA for the protection of retail clients will not apply to an investment in the Fund, and compensation under the Financial Services Compensation Scheme of the United Kingdom will not be available.

Notice to persons in [All Regions]

Past performance is not necessarily a guide to future performance. The value of investments and the income from them can go down as well as up and an investor may not receive back, on redemption of his Shares, the amount which he invested. Neither Sanctum FI, LLP, nor its members or employees warrant the accuracy, adequacy, or completeness of the information contained herein, and Sanctum FI, LLP, expressly disclaims liability for errors or omissions in such information. No warranty of any kind implied, express, or statutory is given by Sanctum FI, LLP, or any of its members or employees in connection with the information contained herein Sanctum FI, LLP, has set procedures for dealing with any complaints that are made about any aspect of the services it provides as a whole, any particular aspects of that service, or any individual acting inappropriately in performing any duty on behalf of the firm. These are freely available on request. Prospective complainants should note that whilst the Firm is obliged to consider any complaint made by any reasonable means, the more clear and more detailed the complaint is will aid in its consideration and internal investigation This website is not an offer to subscribe for Shares in the Fund.