Section 1: General Terms & Conditions

Website Terms and Conditions of Use for Axiom Equity

This page (together with any documents referred to on it) tells you the Terms and Conditions of Use (Terms of Use) on which you may make use of this website (the Website).

Please read these terms of use carefully before you start to use the Website. By using the Website, you indicate that you accept the Terms of Use and that you agree to abide by them. If you do not agree to the Terms of Use, please refrain from using the Website.

1. Information about us

1.1 Axiom Equity is a trading name of Sturgeon Ventures LLP (we, us, our, and Sturgeon Ventures). We are a Limited Liability Partnership registered in England and Wales at Companies House with the company number OC319614 and the registered office address at c/o Haggards Crowther, Heathmans House, 19 Heathmans Road, London, United Kingdom, SW6 4TJ.

1.2 We are authorised and regulated by the Financial Conduct Authority (the FCA) and entered on the Financial Services Register with the FRN # 452811.

1.3 If you have any queries about the Website or any information contained on it, please contact us at [email protected].

2. Accessing the website

2.1 Access to the Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on the Website without notice. From time to time, we may restrict access to some or all of the Website. We will not be liable if for any reason the Website is unavailable at any time or for any period.

2.2 If you breach these Terms of Use, your permission to use the Website terminates immediately and you must immediately destroy any downloaded or printed extracts from the Website.

2.3 You are responsible for making all arrangements necessary for you to have access to the Website.

2.4 By accessing the Website any person using your computer agrees to be bound by these Terms of Use. You are responsible for ensuring that all persons who access the Website through your internet connection and on your computer are aware of these Terms of Use and that they comply with them. You are also responsible for the use of the Website by any person using your computer.

3. Disclaimer

3.1 Nothing on this Website is intended, nor should it be taken, to create any legal or contractual relationship. Any transmission, downloading or sending of any information from the Website does not create any contractual relationship.

3.2 The content of the Website is designed for information purposes only. Neither the information nor any opinions stated on the Website constitutes a solicitation or offer by name of client to buy or sell any securities or other financial instruments or to provide any investment advice.

3.3 The provision of investment services may be restricted in certain jurisdictions. It is your responsibility to acquaint yourself with any local laws and restrictions on the usage of this Website and the availability of any services described on it. The information on this Website is not intended for distribution to or use by any personal entity in any jurisdiction or country where such distribution would be contrary to local law or regulation. The Services are available only to persons in the United Kingdom.

3.4 Nothing in this Website may be published in the press or elsewhere without permission of Axiom Equity.

3.5 Axiom Equity does not provide legal or tax advice. Viewers of this Website are encouraged to consult their own legal and tax advisers before making any investment decision. Potential investors should take independent legal and taxation and investment advice before investing in the fund.

3.6 While we always endeavour to ensure information on the Website is clear, fair and not misleading at the date of publication, we do not hold the information as impartial and it should not be viewed as wholly objective. Information on this Website is based on sources that we believe to be reliable, but we give no undertaking that it is accurate or complete and name of client cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose or at all.

3.7 The contents of this website are subject to change without notice and Axiom Equity is under no obligation to report updates or amendments or keep information accurate.

3.8 This Website is controlled and operated by Axiom Equity in the United Kingdom. We make no representations that materials on the Website are appropriate or available for use in other locations. Those who choose to access the Website from other locations do so at their own risk and are responsible for compliance with all applicable laws.

4. Intellectual property rights

4.1 This Website, its contents, any materials downloaded, and all intellectual property pertaining to or contained on the Website (including but not limited to copyrights, patents, database rights, graphics, designs, text, logos, trade dress, trademarks and service marks) are owned by or licensed to us and/or from third parties and all rights, title and interest in them shall remain the property of Axiom Equity and/or such third parties (collectively, the Content).

4.2 The Content is protected by copyright, patent and trademark laws, and various other intellectual property rights and unfair competition laws.

4.3 You are permitted to print copies and download extracts of the content on the Website for your own personal use for information purposes only, and may draw the attention of others within your organisation to material posted on the Website, subject to the following conditions:

4.3.1 our status (and that of any identified contributors) as the authors of material on our Website must always be acknowledged;

4.3.2 you must not modify in any way the paper or digital copies of any materials you have printed off or downloaded, and you must not use any illustrations, photographs, video or audio sequences or graphics separately from any accompanying text;

4.3.3 you must not duplicate, copy, publish, modify, create derivative works from, participate in the transfer of, post on the internet, or in any way distribute, redistribute or exploit the Website, or any portion of the Website, for any public or commercial use without our express prior written consent;

4.3.4 you must not otherwise use any part of the Website in contravention of these Terms of Use.

4.4 If you print off, copy or download any part of the Website in breach of these Terms of Use, your right to use the Website will cease immediately and you must, at our option, return to us or destroy any copies of the materials you have made.

5. Unlawful or prohibited use

5.1 We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, trojans, worms, logic bombs or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.

5.2 You must not misuse the Website by knowingly or recklessly introducing viruses, trojans, worms, logic bombs or any other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Website, the server on which the Website is stored, or any server, computer or database connected to the Website. You must not attack the Website via a denial-of-service attack or a distributed denial-of service attack.

5.3 Any such unauthorised use of the Website may give rise to a claim for damages and/or be a criminal offence under the Computer Misuse Act 1990. We will report any such activity to the relevant law enforcement authorities, and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately and without further notice.

6. Privacy

6.1 Our Privacy Policy applies to use of the Website, and its terms are made a part of these Terms of Use by this reference.

6.2 Additionally, by using the Website, you acknowledge and agree that internet transmissions are never completely private or secure. You understand that any message or information you send to our Website may be read or intercepted by others, notwithstanding our efforts to protect such transmissions. We are not responsible for any messages which are lost, altered by third parties or intercepted and we will not be liable to you or anyone else for any damages or otherwise in connection with any message sent by you to us or by us to you via the internet.

6.3 The Website makes use of cookies. Cookies are files which our server uses to identify your computer. Cookies cannot identify which person is using the computer. The cookies we use record which parts of our Site are being visited and for how long.

6.4 The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 requires that cookies can only be placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first access our Site. We require you to indicate your choice via an automated “pop-up” box, which explains the cookies we use and what we use them for. Most web browsers automatically accept cookies, but you can also usually modify your browser setting to decline cookies if you prefer. If you decline to accept our use of cookies or set your web browser to decline their use, you will have only limited functionality in the use of our Site. Our Privacy Policy contains further guidance on our use of cookies.

7. Exclusion of liability

7.1 The material displayed on our Website is provided without any guarantees, conditions or warranties as to its accuracy, originality or completeness. To the extent permitted by law, we and third parties connected to us hereby expressly exclude:

7.1.1 all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity;

7.1.2 any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in connection with the use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it, including:

a) loss of income or revenue;

b) loss of business;

c) loss of profits or contracts;

d) loss of anticipated savings;

e) loss of data;

f) loss of goodwill;

g) wasted management or office time; and

h) any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

7.1.3 in jurisdictions which do not allow the exclusion or limitations of certain types of liability, name of client’s liability will be limited to the maximum extent permitted by law.

8. Indemnity

8.1 By using the Website, you agree to indemnify and hold harmless Axiom Equity from and against any and all losses, claims, damages, costs and expenses (including reasonable legal and accounting fees) that Axiom Equity may become obliged to pay, arising or resulting from your use of the Website, the Content, or your breach of these Terms of Use. Axiom Equity reserves the right to assume or participate, at your expense, in the investigation, settlement and defence of any such action or claim.

9. Links to third party websites

9.1 The Website may contain links to websites and resources maintained by third parties. These links are provided for your information only. We have no control over the contents of those websites and resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. We are not responsible for the content, availability or privacy policies of those sites, and the existence of such links should not be considered an endorsement or recommendation of those sites or of any product or service offered on those sites or of any party that is associated with those sites.

9.2 Please note that other websites and resources linked to on the Website may be governed by separate terms and conditions, including privacy policies. You should refer to the applicable terms and conditions of those websites and resources before using them and you should direct any questions or comments about the linked website or resource to the appropriate website provider.

10. Linking to the website

10.1 You may link to the home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

10.2 You must not establish a link from any website that is not owned by you.

10.3 The Website must not be framed on any other website, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice.

10.4 If you wish to make any use of material on the Website other than that set out above, please address your request to [email protected]

11. Revision of terms

11.1 We may revise these Terms of Use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our Website.

12. Jurisdiction and Applicable law

12.1 The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to the Website. We retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country.

12.2 These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.

13. Miscellaneous

13.1 Any failure by Axiom Equity to exercise any rights or enforce any of these Terms of Use shall not constitute a waiver of such rights or terms.

13.2 If any provision of these Terms of Use or their application in a particular circumstance is held to be invalid or unenforceable to any extent, the remainder of these Terms of Use, or the application of such provision in other circumstances, shall not be affected thereby, and each provision of these Terms of Use shall be valid and enforced to the fullest extent permitted by law.

13.3 These Terms of Use (together with any documents referred to in them) constitute the entire agreement between you and name of client with regard to your use of our Website, and any and all other written or oral agreements or understandings previously existing between you and name of client with respect to such use are superseded and cancelled.

14. Your Concerns

14.1 If you have any concerns about any material which appears on our Website, please contact [email protected].

Section 2: Data Protection and Privacy

Data Protection & Privacy Statement

Axiom Equity is a trading name of Sturgeon Ventures LLP (company number: OC319614), Linstead House, 2nd Floor, 9 Disraeli Road, London, SW15 2DR, United Kingdom. Sturgeon Ventures (us or we) is committed to ensuring that your privacy is protected, and all data collected by us will be processed in accordance with this Data Protection Privacy & Cookies Policy. Please read this statement carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller is Sturgeon Ventures LLP of Linstead House, 2nd Floor, 9 Disraeli Road, London, SW15 2DR. We can be contacted at [email protected] or on 020 3167 4652.

By visiting our Site or by providing us with information you are accepting the practices described in this Data Protection Privacy Statement.

1. What information do we collect from you?

Personal information (or ‘personal data’) means any information that can identify a living person, whether directly or indirectly. We collect and process personal demographics such as your title name, address, phone number and email address.

We will process personal information about you that we have collected from the website https://www.axiomequity.com/ (the Website). We collect information when you submit information to us directly using the contact form on the Website. We also collect information automatically when you use the Website. This includes technical information including the internet protocol (IP) address used to connect to the internet, information about your visit including the full uniform resource locators (URL) clickstream and your search history on the Website.

2. How do we use your personal data?

When you provide us with your information in making an enquiry, we will use it for the purpose of administering your enquiry and responding to you. We have legitimate interests in processing your personal data in this way, since if we do not process your data, we will be unable to do this.

When we collect information from you (or the entity you work for), we use it in order to consider your application for investment. We have legitimate interests in processing your personal data in this way.

Should you choose to invest in the Fund, your personal data will be used for all investor communication. Your personal data will also allow us to provide a secure reporting space for updates of the Special Purpose Vehicles (SPV) in which you have invested.

We may also process your personal information collected on our Website on the basis of our legitimate interests in providing you with the best possible service:

• to ensure that the content from the Website is presented in the most effective manner for you and your computer;
• as part of our efforts to keep the Website safe and secure; and
• for internal analytical and statistical purposes.

3. Disclosure of Information

We will only supply your personal information to a third party:

• where we need to share the information to provide a product or a service requested by you;
• where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you, in which case such persons or organisations may only use this information in order to provide such product or service and not for any other purpose;
• companies which perform marketing services on our behalf or with whom we have joint marketing agreements, where we have your consent to share the information;
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of our company, our clients or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4. Where we store your information

The data that we collect from you is stored in the UK in a recognised cloud-based storage system with 256-bit Advanced Encryption Standard (AES) encryption. We will retain your information for six years, after which time it will be destroyed.

5. IP addresses and cookies

When you use the Website, we may obtain information about your computer and general internet usage, including your IP address, operating system and browser type, for system administration purposes.

Cookies contain information that is transferred to your computer’s hard drive. Cookies allow us to tailor our Website to your needs by gathering and remembering information about your usage and preferences.

In particular, cookies enable us:

5.3.1 to gather information on IP addresses and pages visited;

5.3.2 to analyse trends;

5.3.3 to administer the website;

5.3.4 to track users’ movements on the website; and

5.3.5 to undertake statistical analysis.

Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website or accessing certain parts. Our system will issue cookies when you access our Website unless you have adjusted your browser settings so that it will refuse cookies.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

6. Links to other policies and websites

The Website does not contain links to and from other websites.

7. Your rights in respect of your information

The GDPR gives you a number of rights in respect of your personal data, including:

7.1 Right to access
7.1.1 You have the right to access the information we hold about you. We may request proof of your identity before sharing such information.

7.2 Right to rectify your personal data 7.2.1 If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information.

7.3 Right to be forgotten 7.3.1 You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us and we will do our best to assist with your request.

7.4 Other rights
7.4.1 In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspect of your rights or would like to exercise them, please contact us using.

8. Contact

8.1 If you have any questions, want to exercise any of your rights or make a complaint, please contact us using the details at the beginning of this statement.

8.2 If we are unable to resolve your complaint you may contact the Information Commissioner’s Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tele: 0303 123 1113.

9. Changes to this Data Protection Privacy Statement

This statement may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.

10. Law and Jurisdiction

Your use of the Website is subject to the laws of England and Wales and the exclusive jurisdiction of the English courts regarding any disputes that may arise under it.

Section 3: Anti-Bribery and Corruption Policy

Introduction

Axiom Equity (a trading name of Sturgeon Ventures LLP)

Axiom Equity values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

• Setting out a clear anti-bribery policy;
• Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others;
• Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
• Notifying all third parties that Axiom Equity engages with its policy and has zero tolerance of bribery and/or corruption.
• Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
• Taking firm and vigorous action against any individual(s) involved in bribery.

The Policy

Axiom Equity prohibits:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement

to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company

by any individual consultant, agent or other person or body acting on Axiom Equity’s behalf

in order to gain any commercial, contractual or regulatory advantage for Axiom Equity in a way that is unethical

or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

Further Clarification

Axiom Equity recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Partnership or of the person or body employing or contracting with them or whom they represent

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

• normal and appropriate hospitality;
• the giving of a gift for a corporate reason or at another special time, as long as it is reported in the proper manner within the firm on the gifts register;

Inevitably, decision as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer.

Consultants and Principles Responsibility within Axiom Equity

The prevention, detection and reporting of bribery is the responsibility of all consultants throughout Axiom Equity. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.

Useful resource: www.transparency.org.uk for the Transparency Index

A fuller Policy and Procedures outlining al the Principles of the Act can be requested from the Compliance Officer of Sturgeon Ventures LLP, of whom Axiom Equity is a Trading name of the firm, by emailing [email protected]