1. ABOUT US

Eight Roads is a global investment firm which uses personal data in order to source, transact and manage investment opportunities and comply with legal and governance obligations. We do not provide products or services to individuals for their personal use. This privacy policy sets out the basis on which data we collect about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our approach and practices regarding your personal data and how we will treat it.

2. INFORMATION ABOUT US

3. WHO DO WE COLLECT INFORMATION ABOUT?

We do not provide products or services, or promote our business, to consumers. We do collect information about individuals who invest in or are concerned with the investments we manage, and much of our work is the evaluation of existing and potential investments. We therefore collect information about individuals who are or may become directors, officers, shareholders or persons with management or control responsibility in:

• existing or potential investments
• other co-investors with us in our investments (or potential investments)

We also collect:

• information about individuals representing businesses that we work with
• certain information from users of our website, as described in Section 8.

4. WHAT INFORMATION WE COLLECT

We collect:

• contact information, for example, personal and work email addresses and phone numbers
• identifying information, for example, passport, ID or driving licence number, date of birth and gender
• professional information, for example, employment history, educational and professional qualifications and accreditations, directorships
• information about relationships with Eight Roads, the FIL Limited group and our investments or potential investments
• financial information about you and your business interests, your creditworthiness and your financial history
• information from anti-fraud, due diligence, political exposure and sanctions databases, which may include public domain information about your medical history, your family, criminal convictions, political opinions or affiliations
• from users of our website, information about the website that users came from or are going to. We also collect information on which pages of our website users visit, IP addresses, the type of browser used and the times our website is accessed. However, this information is aggregated and is not used to identify individuals. We do not require personal data to be submitted in order to use our website.

5. SOURCES AND HOW WE COLLECT INFORMATION

We collect information:

• through contact with you, your advisers and with businesses you are associated with
• from the evaluation and completion of investment transactions including information provided during the due diligence process
• from public domain sources, such as social media and newspaper reports
• from third party sources, such as the providers of databases like Worldcheck and C6 Intelligence which we use to assist us in undertaking investment due diligence and background checking.

6. HOW WE USE INFORMATION

We use personal information for a number of purposes relating to our interest in operating and promoting our business. In doing so, we balance our appropriate business needs with your right to have your information handled in a way which does not unreasonably prejudice your interests.

• to evaluate and execute potential investment opportunities
• to operate and manage our investments
• to carry out market research, business and statistical analysis
• to comply with best practice and standards in making investment decisions
• to comply with applicable law, regulation and internal compliance relating to the prevention of fraud, tax evasion, bribery and corruption, money laundering and terrorist offences or relating to cyber or data security.

The most common use of personal information is as an input to our opinion on whether to pursue, or complete, an investment transaction and if so, on what terms. We may decide not to pursue an investment transaction (or be unable to do so for legal or regulatory reasons) as a result of due diligence and background check enquiries (and the information revealed by those enquiries).

We are required to use certain personal information in order to comply with legal obligations to which we are subject. If we contract with you directly, we will use personal information in order to perform our contractual obligations.

We only collect and process "special categories" of information (such as information regarding political affiliations) when we have been provided with it by third party providers of due diligence and background checking data services, from information which is in the public domain.

You can complain to us about our use of information about you received from third party providers of data services, or to the providers themselves (Worldcheck and C6).

7. CSR at Eight Roads Investment Advisors Private Limited

Education and Skill Development

Covid-19 support

8. OUR WEBSITE

Performance Cookies

We use performance cookies which collect anonymous information on how people use our website. For example, we use Google Analytics cookies to help us to understand how users arrive at our website, browse or use our website and highlight areas that can be improved such as navigation. The data stored by these cookies never shows personal details from which users' individual identities can be established.

Use of web beacons

Some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.

Links to other websites

Our website contains links to other websites. Any such links are provided for your convenience only. We are not responsible for privacy policies or practices of other websites to which users choose to link from our website. We encourage users to review the privacy policies of those other websites to understand how they collect, use and share personal information. Furthermore, we have no control over third party websites and accept no legal responsibility for any content, material or information contained in them. Your use of a third party site may be governed by the terms and conditions of that third party site.

9. MARKETING COMMUNICATIONS

We may use your information to send you emails, for example, with newsletters and invitations to events, and if you do not wish to receive these kinds of communications, you can opt out of our mailing list.

10. SHARING INFORMATION

We may share information with other companies in the Eight Roads group and with our sister firms, FIL Limited and FMR LLC (and members of their groups), with associated entities and limited partners of the venture funds in which we invest.

We may share information collected as detailed under Section 4 in order to comply with legal and regulatory obligations and best practice in relation to investment due diligence and decisions.

We may share information with third party suppliers or service providers, for example, legal advisers, but this will be limited to the amount of information needed for that third party to carry out the relevant function.

We may also share information with third parties where you have authorised us to do so, such as providing information for the purposes of completing tax returns.

If you would like more details about our sharing of personal information, please contact us as set out in Section 2.

11. OUR RETENTION OF INFORMATION

We retain information we collect for as long as is reasonably necessary to comply with the purposes set out in Section 6.

12. SECURITY

We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. These include the anonymization of information where appropriate and the encryption of all personal information stored in our systems.

In accessing our website, because the internet is an open system, we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use our website users' personal information for improper purposes.

13. TRANSFERS OF INFORMATION

We may transfer information to countries outside the United Kingdom or the European Economic Area, including to other companies in the Eight Roads group. We do this in accordance with applicable law. You can contact us as detailed in Section 2 to find out more.

14. YOUR RIGHTS

You have a right to:

• access information we hold about you, and know for what purpose we use that information
• correct inaccuracies in information we hold about you
• withdraw any consent you have given to use of your information
• complain to the relevant supervisory authority in any jurisdiction about our use of your information
• in some circumstances:
  • request that we erase information we hold about you
  • receive a copy of any personal information provided by you and require us to provide this information to a third party
  • restrict the use of information we hold about you
  • object to the use of information we hold about you, including where that information is used for direct marketing purposes.

You can exercise these rights by contacting us as detailed under Section 2.

15. CHANGES TO OUR PRIVACY POLICY

If our privacy policy changes in any way, we will place an updated version on our website.

Thank you for visiting our website.

16. UK TAX STRATEGY

We believe that high standards of corporate responsibility make good business sense and have the potential to protect and enhance investment returns. Our tax affairs are managed in line with these standards and in keeping with our core values.

UK tax strategy

• The Eight Roads Holdings Limited group (“ER” or the “Group”) is a global proprietary investment group.
• Our UK tax strategy applies to all UK resident companies (“UK entities”) in the Eight Roads Holdings Limited group.
• For this purpose, “UK tax” refers to corporate income tax, indirect tax, payroll and all other UK taxes set out in paragraph 15, Schedule 19, Finance Act 2016.

Tax Governance

• Responsibility for ER’s governance framework, Group strategy including tax strategy and the management of tax risk ultimately sits with the Eight Roads Holdings Limited Board. Day-to-day management of each of these areas is delegated to the Head of Tax Eight Roads, who reports to ER’s Group CFO, with executive responsibility for ER tax matters.
• Our UK tax strategy is subject to the approval of the Eight Roads Holdings Limited (“ERHL”) Board, which includes non-executive Directors offering independent oversight, and annual review by the Group Audit and Risk Committee, which also oversees relevant regulatory, tax and legal matters on behalf of the ERHL Board.
• Our UK tax affairs are regularly reviewed by external auditors and by HMRC as part of the normal course of local tax compliance procedures.
• The operation of our UK tax strategy is supported by ER’s governance structure and the Group’s Enterprise Risk Management framework.

Management of tax risk

The Group faces a variety of tax risks, including:

• Tax compliance and reporting risk;
• Transactional risks; and
• Reputational risk.

ER’s tax risk management procedures include:

• Clearly documented processes and controls relating to the management of UK tax in order to achieve full compliance with the UK Senior Accounting Officer regime. Processes and controls are subject to an annual review and are regularly updated to reflect business and legislative changes;
• The employment of appropriately qualified tax professionals within ER’s tax function;
• Dedicated oversight and management of operational tax risk;
• Where necessary, obtaining external advice from a network of specialist professional advisors in relation to areas of complexity or uncertainty;
• The integration of tax risk management into the Group’s Enterprise Risk Management framework with associated assessment, monitoring and reporting procedures;
• Periodic review of tax risk management procedures by Internal Audit.

Relationship with UK tax authorities

• We seek at all times to comply with our UK tax filing, tax reporting and tax payment obligations in line with statutory timelines.
• An important part of our UK tax strategy is the maintenance of a constructive and transparent relationship with HMRC. We seek to maintain an open dialogue with HMRC via meetings with our Customer Compliance Manager and we provide updates on any changes or developments in business activities.
• It is possible that our views on appropriate tax treatment may differ from those of HMRC. If such circumstances arise, we aim to work proactively and constructively with HMRC in order to achieve a swift resolution.
• We may also seek HMRC’s opinion on new legislation, or areas of uncertainty where appropriate.

Our attitude to tax planning and risk appetite

• We conduct our tax affairs in a manner which ensures compliance with all relevant legal, regulatory, and fiscal obligations.
• We ensure that our tax planning is aligned with the commercial objectives of our business and our long-term business model.
• We will consider using tax incentives or tax planning opportunities in this context, taking into account our responsibilities towards our stakeholders, and where they do not carry significant reputational risk.
• We will also act in line with our enterprise-wide approach to managing risk exposures which include formalised risk policy and risk appetite statement approved by the ERHL Board.
• Remuneration packages for employees and directors are structured so that the proper amounts of tax and social security contributions are paid.

The publication of this UK tax strategy statement relates to the year ended 31 December 2021 and is regarded as satisfying the statutory obligation in Para 19(2), Schedule 19, Finance Act 2016. It will be updated on an annual basis.