Use of Winton Name and Logo Policy

The name “Winton” and the Winton “W” logo are registered trademarks of Winton Group Limited and its affiliates (together, “Winton”). Except as expressly permitted by this policy or as otherwise agreed by Winton in writing, no person has any right to use the name, trademarks or logos of Winton in any manner, including (without limitation) in the name of any investment product, fund, strategy, model, service or report. Any permitted use is non-exclusive, non-transferable and may be revoked by Winton at any time. Winton may amend this policy at any time.

This policy sets out the limited circumstances in which a third party may use or refer to the name “Winton” or any affiliate name in the absence of a separate written agreement governing such use. No use of any Winton logo is permitted unless expressly authorised in writing by Winton.

Policy scope

This policy applies in respect of:

• Distributors or promoters of Products - any third party that distributes, markets or otherwise offers one or more investment products managed or advised by Winton or one or more investment products that provide direct exposure to an investment product or entity that is managed or advised by Winton (each, a “Product”); and
• Users of Winton-related Data - any third party that includes or references data relating to Winton or any investment product managed or advised by Winton (or data derived from such data) (“Data”) in materials or on websites targeting investors or potential investors in Products.

Permitted Use of Winton name

Where this policy applies, a third party may, in marketing materials (including, without limitation, any brochures, fliers or presentations), offering memoranda, investor reports, websites, regulatory documentation or other materials relating to the Product or containing the Data (“Materials”) and in oral communications with investors and prospective investors:

• Accurately cite Winton’s name and accurately describe Winton’s role in respect of the relevant Product or Data; and
• Use factual descriptions of Winton’s business or investment strategies, provided that such descriptions are:

              i.            taken from Winton’s current SEC Form ADV, Part 2A (available at www.adviserinfo.sec.gov); and

               ii.             not presented in a manner that could imply Winton’s endorsement, approval or sponsorship of the Materials.

All Materials must contain the following disclaimer:

“Neither Winton Group Limited nor any of its affiliates takes responsibility for the contents of these materials and each disclaims any and all liability for any losses or damages incurred by any party arising from reliance on these materials.”