Importance Notice

The information contained herein including the Silverdale Fund Communiques issued by Sri Silverdale Opportunities Fund and Silverdale Fund SPC, are strictly for information purposes only, and are not an offer or solicitation of offer or recommendation to buy any security, unit or fund.

Terms of Use

The information published on this website (‘Website’) is strictly for information purposes only and is not designed to meet any specific investment objectives, financial situation or particular needs of any person. Nothing contained in this Website constitutes any financial, tax, legal, insurance or investment advice; and it is not and should not be considered as an offer, or solicitation, to deal in any security or any fund or any product or any service.

By accessing the Website, you (or the ‘User’) confirm that it is your responsibility to be aware of and to observe all applicable laws and regulations of all relevant jurisdictions. By proceeding any further in this Website, you represent, warrant, undertake, acknowledge and confirm that you have read, understood, and accepted these Terms of Use, and further that you have agreed to be bound by them. If you do not agree to these Terms of Use, or do not intend to be bound by them, you should immediately stop accessing this Website, and must exit it immediately.

The Terms of Use of the Website inter alia are:

1. Owner

   The information on this Website has been published by Silverdale Capital Pte. Ltd. (hereinafter “Silverdale”) – a Monetary Authority of Singapore licensed Fund Management Company serving Accredited Investors – with registered office address at 8 Temasek Boulevard, #35-02 Suntec Tower 3, Singapore 038988.

2. Restricted Access

   The Website and the information therein is not directed at or intended for distribution to any person (or entity) who is a citizen or resident of (or located or established in) any jurisdiction where the use of the Website would be contrary to applicable law or regulation or would subject Silverdale to any registration or licensing requirement in such jurisdiction. Visitors who wish to access this Website are required to inform themselves about and adhere to any legal or regulatory restrictions which may affect their eligibility to access the Website. Professional advice should be sought in case of any doubt.Only such investors may transact in the funds or securities mentioned in this Website, as are defined in the respective offering documents (‘Eligible Investors’).Eligible Investors must also satisfy the requirements for an ‘Accredited Investor’ as defined in the Securities and Futures Act (Chapter 289) of Singapore.As per Section 4A of the Securities and Futures Act (Cap 289) of Singapore, Accredited Investor means:

    

   i. an individual:

   • whose net personal assets exceed in value S$2 million (or its equivalent in a foreign currency) or such other amount as the Monetary Authority of Singapore may prescribe in place of the first amount; or
   • whose financial assets (net of any related liabilities) exceed in value $1 million (or its equivalent in a foreign currency) or such other amount as the Authority may prescribe in place of the first amount, where “financial asset” means:
   • a deposit as defined in section 4B of the Banking Act
   • an investment product as defined in section 2(1) of the Financial Advisers Act; or
   • any other asset as may be prescribed by regulations made under section 341; or
   • whose income in the preceding 12 months is not less than $300,000 (or its equivalent in a foreign currency) or such other amount as the Authority may prescribe in place of the first amount

   ii. a corporation with net assets exceeding S$10 million in value (or its equivalent in a foreign currency) or such other amount as the Monetary Authority of Singapore may prescribe, in place of the first amount, as determined by:

   • the most recent audited balance-sheet of the corporation; or
   • where the corporation is not required to prepare audited accounts regularly, a balance-sheet of the corporation certified by the corporation as giving a true and fair view of the state of affairs of the corporation as of the date of the balance-sheet, which date shall be within the preceding 12 months;

   iii. the trustee of such trust as the Monetary Authority of Singapore may prescribe, when acting in that capacity; or

   iv. such other person as the Monetary Authority of Singapore may prescribe

   Before taking any decision (commercial, financial, investment, economic or otherwise) the User should obtain relevant offering materials from the issuer of the security / fund as well as satisfy the requirements for Eligible Investors and for Accredited Investors. This Website is not intended by for use by retail investors. If you are not a Eligible Investor, you should stop using this Website, exit immediately, and refrain from using the information obtained from the Website.

3. No Offer

   The information is provided for information purposes only and does not constitute a solicitation or offer, or advice or recommendation, to buy or sell interests in any security or fund or services, to effect any transactions, or to conclude any transaction of any kind whatsoever.Potential investors should read the terms and conditions in the relevant offering materials carefully before any investment decision is made and pay
   particular attention to the relevant clarifying the persons to whom this material is intended to be communicated.

4. Singapore Registration

   This Website and information therein is not addressed or available to retail public.The information on this Website is not and should not be assimilated with a prospectus as defined in the Securities and Futures Act, Chapter 289 of Singapore (‘SFA’). Accordingly, Silverdale denies any and all liabilities (statutory or otherwise) to the maximum extent permissible by law in relation to the information herein and referred therein. As per Section 304 of SFA, offer or invitations for investments may be made to institutional investors specified.Sri Silverdale Opportunities Fund (‘SSOF’), sub-funds of Silverdale Fund VCC (‘SFVCC’) and sub-funds of Silverdale Fund SPC (‘SFSPC’) have been notified with Monetary Authority of Singapore (‘MAS’) as Restricted Foreign Scheme (under the Sixth Schedule to the Securities and Futures (Offer of Investments) (Collective Investment Schemes) Regulations.Please note that the inclusion of a scheme in the List of Restricted Schemes of MAS indicates that MAS has been informed of their intended offer in Singapore to Accredited Investors. SSOF, SFVCC or SFSPC is not authorized or recognized by MAS for offer to non-accredited retail investors. Inclusion in the aforesaid list does not indicate that MAS has licensed or endorsed the manager for the scheme. The offer, holding, and subsequent transfer of SSOF, SFVCC or SFSPC shares are subject to restrictions and conditions under SFA. SSOF is authorized and regulated by Financial Services Commission, Mauritius. SFVCC is registered with Monetary Authority of Singapore as a restricted scheme and SFSPC is registered with the Cayman Islands Monetary Authority.

5. US Person

   The securities (including fund, units, and shares) mentioned on this Website are not available to United States persons.

6. Website, Access, and Terms of Use Updation

   Unless otherwise stated, information published on the Website is current only as of the time of initial publication, irrespective of the date you access it. Silverdale reserves the right to alter, supplement, add or remove any Terms of Use or the information on the Website at any time and such changes shall be effective immediately upon publishing. Any continued use of the Website after such amendment(s) will represent an agreement by the User to be bound by the Terms of Use as amended. The information on the Website shall be changed, revised, updated, deleted or modified without notice.This Website may include forward-looking statements that are based upon Silverdale’s current opinions, expectations and projections. Silverdale undertakes no obligation to update or revise any forward-looking statements. Actual results would differ from those anticipated in the forward-looking statements.Silverdale reserves the right, in its sole absolute discretion, to deny any user access to the Website, or immediately suspend or terminate his/her access to the Website, or to disable any login ID or password at any time, without ascribing any reason thereof.

7. Use of Data

   Your use of the services on this Website may be monitored by Silverdale, and the resultant information may be used by Silverdale or its affiliates as permitted by law. You may refer to our Personal Data Protection Statement for further information.

8. Login Information

   Certain parts of this Website may be protected by passwords, or require login and are restricted to authorized users only. Users are to treat the information available in such parts as confidential and must not disclose it to any third party or allow any third party to access this Website using such login ID or password. Users shall immediately notify Silverdale if they suspect any unauthorized use of this Website or of their login ID or password.

9. Intellectual Property Rights

   Except where otherwise acknowledged, the copyright in and to the contents of this Website is owned or licensed for use by Silverdale. No part or parts of this Website or its contents may be reproduced, distributed, published, modified, displayed, broadcast, hyperlinked or transmitted in any manner or by any means stored in an information retrieval system without the prior written consent of Silverdale. Thus, any use of the information for any purpose is prohibited except the information provided in PDF format on the Website.Any trade and/or service marks displayed on this Website are the sole and exclusive property of Silverdale and/or respective third parties. Such content is solely for personal and non-commercial use. No right or license is given for any reproduction or use of any such trade and/or service marks. This Website and all of its content, including but not limited to text, design, graphics, interfaces, codes and any selection and arrangement thereof, may be protected as a compilation under copyright laws.

10. No Warranties and Exclusion of Liability

    Whilst Silverdale uses reasonable efforts to obtain information from sources which are said to be reliable, Silverdale gives no warranty as to the accuracy, completeness or reliability of any data, information, opinions or forecasts contained on the Website, nor does it undertake to ensure that this Website will be available or accessible at all times. Silverdale shall have no liability (whether in contract, tort or otherwise) for any direct, indirect, consequential or special losses or damages of any kind whatsoever arising from or in connection with the access to, use of or linking to other websites from the Website or from other website to the Website or due to any reliance on any of the information herein and/or therein.

11. Investment

    Silverdale does not give any assurance, guarantee or warranty that the investment objective or target returns of any fund or security shall be achieved or that substantial losses will not be suffered. Past or projected performance is not necessarily a guide to future results. Potential investors should note that investments can involve significant risks and the value of an investment may go down as well as up, and the entire investment could be lost.

12. No Reliance

    Nothing contained on this Website constitutes investment, legal, tax or other advice or a recommendation to purchase or sell any investment. You should not rely on any of the information published on the Website in making an investment or other decision but should obtain relevant and specific professional advice and read the terms and conditions contained in the relevant offering prospectus carefully before any investment decision is made.The information contained on this Website is published in good faith and provided on an “as is” and “as available” basis for informational purposes only, and without verification or warranty as to their accuracy, completeness or suitability for any specific investment purpose.In particular, Silverdale Communique (which are available for download in PDF format on this Website) are issued by Sri Silverdale Opportunities Fund/Sri Silverdale Capital Partners/Silverdale Fund SPC/ Silverdale Fund VCC respectively . All materials on this Website are meant to be reviewed in their entirety, including any footnotes, disclaimers, restrictions or disclosures and terms and conditions of their use including inter alia any copyright notices. Any disclaimers, restrictions or disclosures apply to any partial document or material in the same manner as they do to the whole, and will be deemed to be incorporated in the portion of any material or document that the users may consult or download.No representation or warranty, express or implied, is therefore made by Silverdale or by any associated person as to its accuracy, adequacy, timeliness, commercial value or completeness, or that any of the information or our Website will be provided uninterrupted or free of errors or that any identified defect will be corrected, and it should not be relied on as such by the users. Silverdale shall have no liability for any loss or damage arising out of the use of or reliance on the information provided including without limitation, any loss of profit or direct, indirect, incidental, special, punitive or consequential or any other damage whatsoever, even if Silverdale or its agents have been advised of the possibility of such loss of profit or damages. Further, Silverdale makes no representations about the accuracy, quality, or the performance of this Website, its contents or any service obtained through this Website, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, satisfactory quality, fitness for a particular purpose, and freedom from computer virus. All terms that may be excluded are excluded to the fullest extent permitted under law.

13. Related Parties, Conflict of Interests, Disclosure

    Silverdale is advisor to Sri Silverdale Opportunities Fund and is materially interested in dealings with Sri Silverdale Opportunities Fund (‘SSOF’). Sri Silverdale Capital Partners (‘SSCP’) is investment manager of SSOF. Silverdale and SSCP have a common director. Silverdale is the Fund Manager of SFVCC and SFSPC, Silverdale, SFVCC and SFSPC have a common director. SSOF, SSCP, SFSPC, SFVCC and Silverdale are related parties.

14. Responsibilities of a User
    
    As a visitor to the Website, you are responsible for accessing it.

     

    • By accessing the Website, you undertake to use the Website in accordance with applicable law and regulations, and these Terms of Use; and to ensure that nothing you do whilst accessing the Website will damage the Website.
    • The user of the Website should obtain opinion from independent professional adviser before making any decision or taking any action based on this Website. Silverdale accepts no responsibility for any action taken or not taken based on the materials published on the website.
    • Your dealings with Silverdale or any of its related parties are not covered by the rules and/or regulations made for the protection of investors in your country of legal residence, including any compensation arrangements, complaints process or rights of cancellation under the rules of the regulatory authorities of your country. Further, similar protection is also not available from the country of incorporation of Silverdale and its related parties. Further, even where investor protection provisions exist, the rules and/or regulations applicable to the provision of investor protection may not be applicable to interfacing conducted through the internet medium and its various applications, of which this Website forms a material part.
    • As a User of the Website, you undertake to indemnify and hold Silverdale harmless from and against all or any claims, actions, liabilities, demands, proceedings or judgments (‘Proceedings’) brought or established against Silverdale and against all losses and all reasonable costs, charges and expenses (including legal fees) which Silverdale may suffer or incur (including, but not limited to, all such losses, costs, charges or expenses reasonably suffered or incurred in disputing or defending any Proceedings and/or in establishing its right to be indemnified and/or in seeking advice in relation to any Proceedings) and which in any such case arise in connection with or out of any breach or alleged breach by a user of any of the obligations and/or undertakings under the Terms of Use of this Website.
15. Governing Law

    These Terms of Use shall be governed by and construed in accordance with the law of the Republic of Singapore.

Trademark

The brand “Silverdale” and the monogram thereof is a registered trademark (Regn. No. 2576679 and T11006991) of Silverdale Holdings Pte. Ltd., a company within the Silverdale group. Any unauthorised use of the trademark is liable to prosecution.

Personal Data Protection Statement

General

Singapore has enacted the Personal Data Protection Act 2012 (“PDPA”) with effect from 2 July 2014 which strives to protect personal data of individuals. It is our policy to comply with the requirements of the PDPA. In doing so, we will ensure compliance by our staff to the standards of security and confidentiality in line with industry standards. This Singapore Data Protection Statement (the “Statement”) explains our practices.

Please take a moment to read this Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

The purpose of this Personal Data Protection Statement (“this Statement”) is to inform you of how we, Silverdale Capital Pte Ltd., (where “we”, “us”, “our”, “our company” shall refer collectively to Silverdale Capital Pte Ltd. and its officers, employees, representatives, agents and service providers) manage personal data, which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (the “Act”). Please take a moment to read this Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data (as the term is defined in the Act and reflected herein).

By interacting with us, submitting information to us, responding to any of our job postings or signing up for any products or services offered by us, and by our responding to you and providing you with any of our products or services, you agree and consent to us, collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our service providers and relevant third parties in the manner set forth in this Statement. Such consent shall continue to subsist until we receive written communication from you of the withdrawal of your consent.

This Statement supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

We may from time to time update this Statement to ensure that it is consistent with future developments in our business, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, by using or continuing to use our services and our continuing the provision of such services to you and/or our response to your applications or inquiries, you agree to be bound by the prevailing terms of this Statement as updated from time to time on our website: www.silverdalegroup.com. Please check back regularly for any updated information relating to the handling of your Personal Data.

For the avoidance of doubt, this Statement forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

What is Personal Data?

Personal data refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access.

Depending on your relationship with us (e.g. prospective or current client, employee or distributor), the personal data about you that we may collect, use, store and disclose include:

• your contact details like your name, passport or other identification numbers, contact numbers, address, email;
• your personal details enabling us to evaluate and manage your client, employment or business relationship with us, e.g. your work experience, education, date of birth, bank details;
• your personal details enabling us to analyse your situation, determine suitable strategies and execute respective action, e.g. family status, financial status, transaction history;
• photos and videos of you from our events or office surveillances; and
• information about your use of our services and website, including cookies and IP address.

Voluntary Provision of Personal Data

Your provision of personal data to us is voluntary. However, if you choose not to provide us with the personal data we require, it may not be possible for us to contact you, or provide products or services which you need from us.

Accuracy and Completeness of Personal Data

You confirm that all personal data that you provide to us is true, accurate and complete.

Purposes for Collection, Use and Disclosure of Your Personal Data

We collect, use and disclose your Personal Data for the following purposes:

1. In connection to the provision of our products and services to you:
   1. the opening, operation, administration or continuation of accounts with us and/or any service providers;
   2. responding to your queries, requests and complaints, if any;
   3. managing our administrative and business operations and complying with internal policies and procedures;
   4. processing any corporate actions which affect your investments (which may arise in connection to any merger, acquisition or asset sale);
   5. providing confirmation of any Personal Data held which relates to you for any of the purposes listed herein;
   6. sending you updates and information in relation to our management of your investments, our services, products, newsletters and related investment and market information, reports or commentaries;
   7. any purpose that is reasonable and incidental to our provision of our products or services to you;
   8. carrying out due diligence, monitoring or other screening activities in accordance with our legal or regulatory obligations or risk management procedures;
   9. implementing processes with a view to preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing commercial risks;
   10. carrying out all regulatory filings;
   11. compliance with any applicable rules, laws and regulations, industry codes of practice or guidelines and any directives or best practices issued or administered by any regulatory authorities or relevant trade bodies or to assist in law enforcement and investigations by relevant authorities.
2. In the case where you submit an application to us as a candidate for employment:
   1. processing your application including the conducting of pre-recruitment checks, such as in relation to your credit standing and qualifications;
   2. providing or obtaining references and for background screening/vetting from your referees, past employers, present or past colleagues and the staff of past academic institutions;
   3. collecting information to assess your suitability for the position applied for;
   4. communicating with you as is required to comply with our policies and processes, including for business continuity purposes;
   5. maintaining our records where you have not been successful in your job application to us, to inform you should a suitable position which might be of interest to you be open in the future; or where you are subsequently employed by us and thereafter leave our employment, to provide you a reference, when so requested by your future prospective employer; and
   6. any other purposes relating to the aforesaid (hereinafter collectively referred to as the “Purposes”).

If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will adequately seek your consent.

Transfer of Personal Data Out of Singapore

You fully understand and unambiguously consent that we may transfer your personal data to any location outside of Singapore for the purposes set out above.

How We May Collect Your Personal Data

We may collect your personal data ourselves or through third parties in ways including the following:

• during our preliminary discussions with you for investments in our funds;
• when you interact with our employees;
• when you provide all the KYC documents for investment into our funds;
• when you communicate with us by email or telephone, your emails will be retained and we may monitor and/or record your voice calls to us;
• when you enter our premises, we may take pictures or videos or you may be captured on our closed-circuit television cameras surveillance;
• when you access our website;
• when you respond to our requests for additional personal data; or
• when you submit your personal data to us for any other reason.
• When you access our website you generally do so anonymously. Your activity may however be monitored by Cookies or other navigational data. “Cookies” are small data files sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

Personal Data to be Kept Confidential and Secure

At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and/or procedural safeguards to protect your personal data against loss, misuse, damage and unauthorized access, modifications or disclosures.

Disclosure of Your Personal Data

Where your consent is given, the personal data which you have provided to us may be transferred to the parties set out below within or outside Singapore, as may be necessary for any of the Purposes stated above:

• our affiliate companies including associated entities and any of their branches and offices which may also include entities and activities overseas;
• banks, financial institutions and their respective service providers;
• companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies;
• agents, contractors or third-party service providers who provide services to us such as fund administrator, telecommunications, information technology, payment, data processing, storage and archival;
• our professional advisers such as our auditors and lawyers;
• government authorities, regulatory bodies and/or other law enforcement agencies
• courts, tribunals and/or parties to the legal proceedings; and/or
• When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available, or where use/disclosure of your personal data is otherwise legally mandated and exempted.

Retention of Personal Data

The PDPA does not prescribe the retention period. However, we shall retain your personal data for as long as necessary to fulfil the Purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required.

Third-party Sites

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

Contact Us

You can contact our Data Protection Officer (“DPO”) via email: [email protected] if you have any of the following enquiries:

1. Access to and Correction of Personal Data
   You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested.

   To update your personal data in our possession or under our control, please submit a written request to your Portfolio Manager or our DPO via email: [email protected]. Our DPO shall respond to you within 30 days of your submission.

   Where you provide us personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

2. Withdrawal of Consent

   If you wish to withdraw your consent to our collection, use or disclosure of your personal data, please submit a written request to our DPO via email: [email protected]. Our DPO shall strive to respond to you within 30 days of your submission.

   Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

3. Complaints

   We are committed to protecting your personal data. If, however, you should be dissatisfied with our handling of your personal data, please submit a written complaint containing details of your dissatisfaction to our DPO via email: [email protected]

   Our DPO shall acknowledge in writing the receipt of your complaint within 2 business days. Within 10 business days, our DPO shall strive to contact you to provide you with an estimated timeframe for our investigations and resolution of your complaint. If your complaint requires more time beyond such estimation to resolve due to its complexity, our DPO shall inform you accordingly on or before the expiry of the original estimated timeframe.

4. General Queries
   If you have general queries about this Statement, our data protection process and/or practices, please submit a written request to our DPO via email: [email protected]. Our DPO shall respond to you within 30 days of your submission.

Whistle Blower Policy

Silverdale does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work. Silverdale has a Whistle-blower Policy is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences.

Employees may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, insider trading, collusion with competitors, serious breaches of policy, unsafe work practices or any other matters involving fraud, corruption and employee misconduct.

The whistleblower can report irregularities such as:

• Forgery
• Misappropriation of funds and classified documents
• Abuse and misrepresentation of power and authority
• Failure to comply with laws and regulations
• Harassment
• Corruption and bribery
• Theft

Business Continuity Plan

In order to ensure the smooth functioning of the business of the Company, in face of any disruption, the management of the Company has established a business-continuity plan. The management is also responsible for implementing and maintaining the same to address disaster recovery or periodic disruptions of the financial markets and ensuring that losses are limited, essential data and functions are preserved and performance of activities is maintained.

Silverdale is committed to protecting its staff and ensuring the continuity of critical businesses and functions in order to mitigate risk, safeguard revenues and sustain both a stable financial market and customer confidence.

The Business Continuity Plan focuses on the following:

• Ensuring that the resource requirements of the Company such as people, systems and other assets are at all times protected;
• Establishing and maintaining remote data management and automated back-up facilities to manage events of business disruption swiftly and efficiently;
• Using adequate information technology and support systems and upgrading the same from time to time to meet the technological requirements of the Company;
• Adopting a communication plan to ensure that all Silverdale employees and third parties (if required) receive emergency notifications and instructions through a number of sources; and
• Regular testing of the business continuity policy in a manner which is commensurate with the Company’s nature, scale, and complexity of business operation.

AML Policy

Silverdale has a robust AML Policy to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

Silverdale has a multi-level KYC Protocol which involves customer KYC being done by the Investment Manager, the Fund Administrator and the AML Agent.

The Company strictly does not allow third party funding. Any funds coming to the account must come from the same account holder
Silverdale has an inhouse Money Laundering Reporting Officer (“MLRO”). The MLRO acts as the focal point in Silverdale for all matters relating to money laundering. All reports of knowledge or suspicion of money laundering must be reported to the MLRO who will then investigate into the same.

MLRO shall consider if the circumstances are suspicious so as to warrant the filing of a Suspicious Transaction Report (STR) and document the basis for its determination where Silverdale is for any reason unable to complete Client Due Diligence (CDD) measures;