Equinox, Expert fund manager in Russia since 1996

This app/website relates to Equinox Russian Opportunities Fund Limited (the Fund), which has been authorised by the Guernsey Financial Services Commission (GFSC) as a Collective Investment Scheme of Class B. The app/website is published by Equinox Fund Management (Guernsey) Limited (EFML), a company registered in Guernsey, no. 49587, and licensed by the GFSC under the Protection of Investors (Bailiwick of Guernsey) Law, 1987.

The information contained within this app/website has been prepared in accordance with Guernsey law. It may not satisfy the laws of any other country and some or all of the products and services described in the app/website may not be available to residents of some countries.

In particular, the content of this app/website has not been approved by an authorised person within the meaning of the Financial Securities and Markets Act 2000 (FSMA) of the United Kingdom. The Fund is an unregulated collective investment scheme for the purposes of the FSMA, the promotion of which is restricted by FSMA. This app/website is directed to, and should only be accessed by the following persons (collectively, relevant persons):

1. Persons who have professional experience in matters relating to investments, falling within article 19(5) ("investment professionals") of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (as amended) (the Order);
2. Persons falling within article 49(2)(a) to (d) ("high net worth companies, unincorporated associations etc") of the Order; or
3. Persons outside the United Kingdom (but not being US Persons as defined in Regulation S under the US Securities Act of 1933 (the 1933 Act)) to whom the content of this app/website may lawfully be communicated under the laws applicable to those persons.

The contents of this app/website must not be accessed, relied on or acted on by persons who are not relevant persons (as defined above). Any person who is in any doubt about whether they are a relevant person (as defined above) should consult their professional, financial or legal adviser before accessing this app/website.

Nothing in this app/website constitutes or forms part of any offer, invitation, solicitation or inducement to purchase or subscribe for, or otherwise engage in any investment activity in relation to shares in the Fund (Shares). Any purchase of, or subscription for, Shares may only be made on the basis of the legal documents relating to the Fund and subject to compliance with systems and procedures stipulated from time to time by EFML to ensure that any purchase or subscription is only effected by those persons who may lawfully do so without any breach of FSMA or other laws and regulations of applicable jurisdictions. Nevertheless, any person accessing this app/website or seeking to purchase, or subscribe for, Shares is responsible for ascertaining, and observing, the laws and regulations applicable to him/her/it and must not rely upon the Fund or EFML (nor any other member of the Equinox Group, as defined below) to do so nor upon the systems and procedures stipulated by EFML.

No action has been taken nor is being taken to register or otherwise qualify any Shares or this app/website in any jurisdiction where such action is required nor is there any intention for any such action to be taken in respect of any Shares in the future. In particular, Shares in the Fund have not been and will not be registered under the 1933 Act or under the United States Investment Company Act of 1940 and have not been approved (or disapproved) by the United States Securities and Exchange Commission or by any other authority in any jurisdiction.

Neither the Fund, nor EFML (nor any subsidiary, holding company or affiliate of any such company (collectively, the Equinox Group)) nor any of their respective directors, officers, employees, agents or advisers (whether individually or collectively) gives any representation or warranty, express or implied, as to the accuracy, reliability or completeness of the information presented, nor as to the appropriateness of the information for any use which any recipient may choose to make of it and none of them accept any responsibility for updating any part of the information or for correcting any material error or omission which may become apparent after information has been displayed on the app/website. No member of the Equinox Group nor any of their respective directors, officers, employees, agents or advisers accept any liability for any error, omission or misrepresentation in relation to the information provided or for any loss, damage, cost or expense (whether direct, indirect, consequential or otherwise) suffered by the recipient of any of that information or any other person as a result of the use of, or reliance upon, any information or statement of any kind (including statements of fact or opinion) in this app/website.

Switzerland

Shares of the Fund can be offered in Switzerland exclusively to Qualified Investors as defined by Article 10 § 3 of the Collective Investment Scheme Act (CISA) and Article 6 of the Collective Investment Scheme Ordinance (CISO) (Qualified Investors). The Fund has not been and will not be registered with the Swiss Financial Market Supervisory Authority (FINMA). These Scheme Particulars and/or any other offering materials relating to the Shares in the Fund may be made available in Switzerland solely to Qualified Investors.

Information for Swiss based Qualified Investors

• The domicile of the Fund is Guernsey
• The Representative of the Fund in Switzerland is: OpenFunds Investment Services AG Seefeldstrasse 35, CH-8008 Zürich Tel +41 44 500 3108, www.open-funds.ch

The statutory documents of the Fund such as the Scheme Particulars, the key investor information document (if any), the articles of incorporation, the annual and semi-annual reports and/or any other legal documents as defined in Article 15 of the CISA in conjunction with Article 13a of the CISO may be obtained free of charge from the Representative. The place of performance and jurisdiction for Shares of the Fund offered or distributed in or from Switzerland are the registered office of the Representative.

• The Swiss Paying Agent is: Società Bancaria Ticinese SA Piazza Collegiata 3, 6501 Bellinzona Tel +41 91 821 51 21, Fax. + 41 91 825 66 18, www.bancaria.ch Subscriptions and redemptions of Shares of the Fund as well as distributions may be made through the Swiss Paying Agent. A handling commission of CHF 150 per transaction will be charged by the Swiss Paying Agent and deducted from the subscription or redemption amount paid or received. If a subscription or redemption is made through the Swiss Paying Agent, instructions and money must be received by the Swiss Paying Agent at least 72 hours before the appropriate dealing cut-off time.
• Publications to Swiss investors in respect of the Shares in the Fund are effected by the Representative.

The financial intermediaries may pay retrocessions as remuneration for distribution activity in respect of Fund’s Shares in or from Switzerland to the distributors and sales partners listed below:

• distributors subject to authorisation as defined in Article 19§ 1bis of the CISA (Swiss or foreign distributors regulated in their home jurisdiction);
• distributors that are not required to obtain an authorisation as defined under Article 19§ 1bis of the CISA and Article 8 of the CISO (financial intermediaries regulated by FINMA, banks, insurances, fund managers, representatives);
• sales partners who place shares in funds/sub-funds with their customers exclusively through a written commission-based asset management mandate (independent asset managers), i.e. the customer has to be transparently informed that the sales partner is receiving retrocessions from the Fund and/or fund manager and/or the distributor.

This remuneration may be deemed payment for the following services in particular:

• the introduction of potential qualified investors; and
• the organisation of road shows.

Retrocessions are not deemed to be rebates even if they are ultimately passed on, in full or in part, to the investors. The recipients of the retrocessions must ensure transparent disclosure and inform investors, unsolicited and free of charge, about the amount of remuneration they may receive for distribution. On request, the recipients of retrocessions must disclose the amounts they actually receive for distributing the collective investment schemes of the investors concerned.

In respect of distribution in or from Switzerland, the Financial Intermediaries do not pay any rebates to reduce the fees or costs incurred by the investor and charged to the Fund.

Comparative Performance

Statistical data and other information about other investments, including performance of stock exchange indexes and share prices, have been taken from sources considered suitable by EFML. However, given the inherent uncertainty of source material in the region, neither the Fund nor EFML nor any other member of the Equinox Group nor any of their respective directors, officers, employees, agents or advisers accept any responsibility or liability for the accuracy or completeness of that data or information. Past performance is not a guarantee of future returns. The price of Shares, and any income from them, can go down as well as up and investors are exposed to a significant risk of losing all of their investment.

Privacy

By you or the business that employs you becoming a client of the Equinox Group you have either provided or will provide the Equinox Group with personal information, which may constitute personal data within the meaning of data protection legislation in Guernsey, Cyprus, Russia and any other relevant jurisdiction (the “Data Protection Legislation”). This data is used for the purposes of administration, client identification, statistical analysis, and research. By becoming a client of the Equinox Group, you have entered into a contract with the Equinox Group, its delegates and its duly authorised agents and any of its or their respective related, associated or affiliated companies. Data will be obtained, held, used, disclosed and processed for any one or more of the following purposes:

• To manage and administer the client’s relationship with the Equinox Group on an ongoing basis.
• For any other specific purposes where the client has given specific consent.
• To comply with legal and regulatory obligations applicable to the client.
• For disclosure or transfer, whether in Guernsey, the European Economic Area (“EEA”), Russia or countries other than those listed, including without limitation the United States of America and Canada which may not have the same data protection laws as Guernsey, the EEA, or Russia, to third parties including financial advisers, regulatory bodies, auditors, technology providers or to the funds managed by the Equinox Group and its delegates and its or their duly appointed agents and any of its or their respective related, associated or affiliated companies for the purposes specified above.
• For other legitimate business interests of the Equinox Group.

Pursuant to Data Protection Legislation, data subjects have a right of access to their personal data kept by the Equinox Group and the right to amend and rectify any inaccuracies in their personal data held by the Equinox Group by making a request to the Equinox Group’s Data Responsibility Officer in writing.

Data subjects should address such requests by email to Richard.Bray@activeoffshore.com or by post to Equinox Fund Management Limited, PO Box 336, Anson Court, La Route des Camps, St Martin, Guernsey GY1 3UQ.

The Equinox Group includes Eurostep Holdings Limited, Eurostep (Cyprus) Limited, Eurostep (Cyprus) Limited Representative Office in Moscow, Technoilgas CIS Limited, JSC Yamaltek, Equinox Fund Management (Guernsey) Limited, and AS Eurostep Digital. Eurostep (Cyprus) Limited Representative Office in Moscow and JSC Yamaltek are data operators as identified within Russian data protection legislation. Eurostep (Holdings) Limited, Eurostep (Cyprus) Limited, Technoilgas CIS, Equinox Fund Management (Guernsey) Limited and AS Eurostep Digital are Data Controllers within the meaning of European and Guernsey Data Protection Legislation. All Equinox Group entities undertake to hold any personal information provided by clients in confidence and in accordance with the relevant Data Protection Legislation.

After the relationship has been terminated, the Equinox Group will retain a record of the data to enable it to satisfy audit and statutory requirements.

The rights in respect of the protection of personal data are defined in the Data Protection Legislation. These rights include the right of data subjects to access all the personal data relating to that data subject held by the Equinox Group. Further information regarding these rights may be obtained from the relevant Data Protection Commissioners in Guernsey, Cyprus, Estonia or Russia.

Cookies

Equinox Group uses Cookies on their app/website for analytics purposes only. If you are unaware of what cookies are or how they are used we recommend you visit www.aboutcookies.org which will give you details on how to control cookie use and delete them if required.

The only use of cookies on the app/website are first party cookies in conjunction with Google Analytics which we use to gather data on visitor trends. All information gathered from these cookies is anonymous and is used to improve the usability of the site. If you wish to review Google’s position on privacy with respect to its analytics services visit http://www.google.co.uk/intl/en/analytics/privacyoverview.html

I confirm that I am a relevant person as described in paragraph 1, 2 or 3 above and that I accept that my accessing the website is evidence of my acceptance of the above terms and conditions.