Legal Disclosures & Terms

If you do not agree to be bound by or comply with these Terms, do not access or use our website.
Acadian reserves the right, in our sole discretion, to change, modify, add or remove Terms or portions thereof at any time. Any changes, modifications, or additions to, or deletions from the Terms shall be effective upon posting on this website. If you use this website after we post changes to the Terms, you accept the Terms as changed.

 

This website is owned and operated by Acadian Asset Management LLC ("Acadian"), a Delaware limited liability company, located in Boston, Massachusetts, United States of America, registered with the U.S. Securities and Exchange Commission as an investment adviser pursuant to the Investment Advisers Act of 1940 (Registration with the U.S. Securities and Exchange Commission does not imply that an adviser has attained a particular level of skill or training).

 

Acadian is a subsidiary of BrightSphere Affiliate Holdings LLC, which is an indirect, wholly owned subsidiary of U.S.-based BrightSphere Investment Group Inc. (“BSIG”), a Delaware corporation publicly listed on the NYSE. Acadian exercises complete discretion over its investment philosophy, people and process, and Acadian is operated as a single independent entity. Acadian has been owned by BSIG since 2000 (previously called Old Mutual), when Old Mutual purchased Acadian’s former parent United Asset Management. Acadian had been acquired by UAM in 1992.

 

Acadian Asset Management (Singapore) Pte Ltd (Company Registration No: 199902125D) is located in Singapore and is registered with the Monetary Authority of Singapore.

 

Acadian Asset Management (UK) Ltd (Company Registration No: 05644066) is located in London and is authorized and regulated by the Financial Conduct Authority.

 

Acadian Asset Management (Australia) Limited (ABN 41 114 200 127) is the holder of Australian financial services licence number 291872 ("AFSL"). Under the terms of its AFSL, Acadian Asset Management (Australia) Limited is limited to providing the financial services under its licence to wholesale clients only.

Intended Audience and Purpose

 

The information provided on our website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Acadian, its wholly-owned affiliates, or any of its products to any registration requirement within such jurisdiction or country. Acadian assumes no responsibility for access to this website by any person located within a country or jurisdiction where such access would be contrary to any law or regulation in that country. 

Our website and its contents is for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security that may be referenced on or through our website. Further, our website and its contents does not constitute an offering or recommendation by Acadian or its wholly-owned affiliates of any transaction, product or service, including securities transactions and investment management or advisory services. Acadian does not provide investment advice, tax advice, or legal advice through this website, and you agree that this website will not be used by you for such purposes.

The information provided on our website is intended for institutional investors and Professional Clients and Eligible Counterparties as defined by the FCA under the Markets in Financial Instruments Directive. It is not intended for retail investors.

Use Limitations

 

All copyrights, trademarks, logos, service marks, trade names, or other intellectual property displayed on, or used in conjunction with, this website are proprietary to Acadian, unless otherwise noted. The content of this website is protected by applicable intellectual property (copyright) law. Acadian reserves all rights with respect to intellectual property ownership of all material on this website, and will enforce such rights to the full extent permissible by law.

The material accessible on or through this website is accessible for personal browsing and printing purposes only. Users of this website may not otherwise:

 (1) copy, reproduce, sell, republish, post, transmit (by electronic means or otherwise), modify, link into, use for any public or commercial purpose or distribute in any way material from this website without the express, written permission of Acadian;

 (2) use, copy, modify, or display any Acadian name, Acadian employee name, logo, text or graphic image without Acadian's express, written permission;

 (3) display any of the pages, text, images or other content of this website in any manner without Acadian's express written permission;

 (4) modify or use the pages, text, images, papers, or other content from this website for any purpose other than browsing or printing for personal, non-commercial use; or

 (5) take any action to create an impression of affiliation, sponsorship or endorsement between any user and/or website and Acadian.

Privacy

 

Acadian will not request and you should not send personal identification information such as a social security or passport number, bank or other investment account numbers, or any other specific personal financial information through our website. We do not solicit investment business or sell investment products via our website, the internet, email, or in a non-personal manner. We further do not conduct investment business directly with individual retail investors or non-professional investors. We do not take custody of client cash or assets and would never request that you send funds in any form directly to the firm or to a retail bank account we designate for investment. Should you receive any contact from anyone purporting to represent Acadian with any direction to the contrary please do not invest any funds and first call us at 617-850-3500 and request to speak with a compliance officer.

 

Acadian may collect information about you when you access the website if you voluntarily choose to send Acadian electronic mail, request information, or ask to be contacted. Acadian may use this information to provide you with updated information about the products and services we offer. Certain employees of Acadian and our wholly owned affiliates may be given the information you provide to respond to your requests. Employees of Acadian and its affiliates are instructed to handle any information you provide confidentially. Our full Privacy and Data Protection Policy is provided as part of the website.

 

Our website uses "cookies" and "web beacons" (such as Google Analytics) to collect, store and aggregate data about usage and browsing patterns. As it relates to web analytics, we use cookies and web beacons for session management and to analyze site usage; we do not use cookies and web beacons to store any personally identifiable information about you. A "cookie" is a small text file containing a random and unique alphanumeric identifier that we transfer to your computer's hard drive through your web browser (unless you set your browser to reject cookies) that enables our systems to recognize your browser. A "web beacon" (also known as a "page tag," "data tag" or "image tag") is a mechanism by which a small section of code that is embedded in our website pages allows us to check that a user has viewed the page. These technologies can help us analyze and better understand how our website is being used and improve the user experience.

 

Our website also uses "cookies" and "web beacons" that are able to collect, store, and aggregate personally identifiable information about usage and browsing patterns relating to users that have opted into our email marketing program. These specific "cookies" and "web beacons" will not collect any data if you are not part of our email marketing activities.

Singapore Personal Data Protection Act 2012

 

The Personal Data Protection Act 2012 (PDPA) governs the collection, use, and disclosure of personal data by Singapore organizations. It consists of two sets of requirements, covering personal data protection and the Do Not Call (DNC) registry

Acadian aims to comply with the requirements set forth in the Act, and respects your personal data held or controlled by us. Should you have any feedback or inquiries pertaining to your personal data, please contact the Data Protection Officer via email at dpo@acadian-asset.com.sg or in writing to the Singapore office address.

Disclaimer

 

Acadian does not warrant this website for any particular purpose. It is provided "as is" and on an "as available" basis. Acadian disclaims, to the fullest extent of the law, any warranty of any kind, whether express or implied, as to any matter relating to this website, including without limitation the implied warranties of merchantability, fitness for a particular purpose, and non-infringement. Use of this website is at your own risk.

All content on this website is presented as of the date published or indicated. It may not reflect current opinions or events. Although the information and data provided to you on this website is obtained or compiled from sources believed to be reliable, Acadian cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information, data or opinions made available to you for any particular purpose. This website may include forward-looking statements, which are based on current opinions, expectations and projections. Acadian expressly disclaims any duty to update or revise any information, opinion or forward-looking statement appearing on this website. Decisions based on information contained on this website are solely your responsibility.

In no event will Acadian be liable for any decision made, action or inaction taken by you in reliance on any information or data on our website and under no circumstances is any information available on our website to be construed as investment advice or recommendations.

Acadian does not warrant that our website, or the functions contained in our website, will be uninterrupted or error-free, that defects will be corrected, or that our website, or the servers that make it available, are free from viruses or other harmful components. You assume the entire cost of any necessary servicing, repairing, or correcting of your property or operations as a result of using our website. You accept at your own risk that the Internet or other online communications medium may not perform as intended as a result of human, mechanical or other error, despite the efforts of Acadian, you or any third party.

You hereby agree to indemnify, defend and hold harmless Acadian and its wholly-owned affiliates, and their directors, officers, employees and agents, from and against any and all claims, liabilities, damages, losses or expenses (including reasonable attorneys' fees and expenses) arising out of or in any way connected with your access to or use of our website.

 

Proxy Voting

 

Policy

 

Whether Acadian will have proxy voting responsibility on behalf of a separate account client is subject to negotiation as part of the overall investment management agreement executed with each client. We will have voting responsibility for all Acadian branded funds.

 

Should a separate account client desire that Acadian vote proxies on their behalf, Acadian will accept such authority and agree with the client as part of the investment management agreement whether votes should be cast in accordance with Acadian’s proxy voting policy or in accordance with a client specific proxy voting policy. Should the client wish to retain voting responsibility themselves, Acadian would have no further involvement in the voting process but would remain available to provide reasonable assistance to the client as needed.

 

Acadian utilizes the services of Institutional Shareholder Services (“ISS”), an unaffiliated proxy firm, to help manage the proxy voting process and to research and vote proxies. Acadian has adopted the ISS voting policies for use when contractually directed by the client to votes proxies on their behalf in accordance with our proxy voting policy. We review the ISS policies at least annually and believe that they are reasonably designed to ensure that we vote proxies in the best interest of clients and that our voting decisions are insulated from any potential material conflicts of interest.

 

Should a client contractually direct Acadian to vote proxies on their behalf in accordance with Client specific voting policies and procedures, we will still utilize the services of ISS to cast the votes in accordance with the client’s instructions.

 

When voting proxies on behalf of our clients, Acadian assumes a fiduciary responsibility to vote in our clients' best interests. In addition, with respect to benefit plans under the Employee Retirement Income Securities Act (ERISA), Acadian acknowledges its responsibility as a fiduciary to vote proxies prudently and solely in the best interest of plan participants and beneficiaries. So that it may fulfill these fiduciary responsibilities to clients, Acadian has adopted and implemented these written policies and procedures reasonably designed to ensure that it votes proxies in the best interest of clients.

 

Procedures

 

Proxy Voting Guidelines

 

Acadian acknowledges it has a duty of care to its clients that requires it to monitor corporate events and vote client proxies when instructed by the client to do so. To assist in this effort, Acadian has retained ISS to research and vote its proxies. ISS provides proxy-voting analysis and votes proxies in accordance with predetermined guidelines. Relying on ISS to vote proxies is intended to help ensure that Acadian votes in the best interest of its clients and insulates Acadian’s voting decisions from any potential material conflicts of interest. Acadian will also accept specific written proxy voting instructions from a client and communicate those instructions to ISS to implement when voting proxies involving that client’s portfolio.

 

In specific instances where ISS will not vote a proxy, will not provide a voting recommendation, or other instances where there is an unusual cost or requirement related to a proxy vote, Acadian’s Head of Investment Operations will coordinate with members of our investment team to conduct an analysis to determine whether the costs related to the vote outweigh the potential benefit to our client. If we determine, in our discretion, that it is in the best of interest of our client not to participate in the vote Acadian will not participate in the vote on behalf of our client. If we determine that a vote would be in the best interest of our client, Acadian will provide voting direction back to ISS and ensure the vote is cast as they instruct.

 

Unless contrary instructions are received from a client, Acadian has instructed ISS to not vote proxies in so-called "share blocking" markets. Share-blocking markets are markets where proxy voters have their securities blocked from trading during the period of the annual meeting. The period of blocking typically lasts from a few days to two weeks. During the period, any portfolio holdings in these markets cannot be sold without a formal recall. The recall process can take time, and in some cases, cannot be accomplished at all. This makes a client’s portfolio vulnerable to a scenario where a stock is dropping in attractiveness but cannot be sold because it has been blocked. Shareholders who do not vote are not subject to the blocking procedure.

 

Acadian also reserves the right to override ISS vote recommendations under certain circumstances. Acadian will only do so if they believe that voting contrary to the ISS recommendation is in the best interest of clients. The reasons for any overrides and for voting against the ISS recommendation will be documented.

 

Conflicts of Interest

 

Occasions may arise during the voting process in which the best interest of our clients conflict with Acadian’s interests. In these situations, ISS will continue to follow the same predetermined guidelines as formally agreed upon between Acadian and ISS before such conflict of interest existed. Conflicts of interest generally include (i) business relationships where Acadian has a substantial business relationship with, or is actively soliciting business from, a company soliciting proxies, or (ii) personal or family relationships whereby an employee of Acadian has a family member or other personal relationship that is affiliated with a company soliciting proxies, such as a spouse who serves as a director of a public company. A conflict could also exist if a substantial business relationship exists with a proponent or opponent of a particular initiative.

 

If Acadian learns that a conflict of interest exists, the Head of Investment Operations will work with our compliance and investment team as needed to document (i) the details of the conflict of interest, (ii) whether or not the conflict is material, and (iii) procedures to ensure that Acadian makes proxy voting decisions based on the best interests of clients. If Acadian determines that a material conflict exists, it will defer to ISS to vote the proxy in accordance with the predetermined voting policy.

 

Voting Policies

 

Acadian has adopted the proxy voting policies developed by ISS, summaries of which can be found at http://www.issgovernance.com/policy and which are deemed to be incorporated herein. The policies have been developed based on ISS’ independent, objective analysis of leading corporate governance practices and their support of long-term shareholder value. Acadian may change its proxy voting policy from time to time without providing notice of changes to clients.

 

Voting Process

 

Acadian’s Head of Investment Operations acts as coordinator with ISS including ensuring proxies Acadian is responsible to vote are forwarded to ISS, overseeing that ISS is voting assigned client accounts and maintaining appropriate authorization and voting records.

 

After ISS is notified by the custodian of a proxy that requires voting and/or after ISS cross references their database with a routine download of Acadian holdings and determines a proxy requires voting, ISS will review the proxy and make a voting proposal based on the recommendations provided by their research group. Any electronic proxy votes will be communicated to the proxy solicitor by ISS Global Proxy Distribution Service and Broadridge’s Proxy Edge Distribution Service, while non-electronic ballots, or paper ballots, will be faxed, telephoned or sent via Internet. ISS assumes responsibility for the proxies to be transmitted for voting in a timely fashion and maintains a record of the vote, which is provided to Acadian on a monthly basis. Proxy voting records specific to a client’s account are available to each client upon request.

 

Proxy Voting Record

 

Acadian will maintain a record containing the following information regarding the voting of proxies: (i) the name of the issuer, (ii) the exchange ticker symbol, (iii) the CUSIP number, (iv) the shareholder meeting date, (v) a brief description of the matter brought to vote; (vi) whether the proposal was submitted by management or a shareholder, (vii) how Acadian/ ISS voted the proxy (for, against, abstained) and (viii) whether the proxy was voted for or against management.

 

Obtaining a Voting Proxy Report

 

Clients may request a copy of these policies and procedures and/or a report on how their individual securities were voted by contacting Acadian at 617-850-3500 or by email at compliance-reporting@acadian-asset.com.