Website terms and conditions of use.

These terms (and any documents referred to in them) tell you the terms on which you may make use of the NorthEdge Capital LLP website (the “Website”). Please read these terms carefully prior to use of the Website. By using the Website, you confirm your acceptance to these terms. If you do not agree to these terms, you should exit the Website immediately and refrain from using it.

1. INFORMATION ABOUT US

1.1 We are NorthEdge Capital LLP. We are a limited liability partnership registered in England and Wales at Companies House.

1.2 Our registered office is Number One Spinningfields, 1 Hardman Square, Spinningfields, Manchester, M3 3EB registered number OC345118

1.3 You can contact us by email, info@northedgecapital.com or by telephone on 0161 832 6654

2. INTELLECTUAL PROPERTY RIGHTS

2.1 This Website is owned by NorthEdge Capital LLP and any and all intellectual property rights in the Website including, but not limited to, copyright and database rights and any logos or trademarks (whether registered or unregistered) are owned by and remain the property of NorthEdge Capital LLP (or its third-party licensors as applicable) at all times.

2.2 You may print off one copy and may download extracts of the content on the Website for your personal reference and may draw the attention of others within your organisation to material posted on our Website, provided that:

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

2.2.2 You do not use any part of the content on the Website for commercial purposes without our prior written consent;

2.2.3 You do not modify in any way the paper or digital copies of any materials you have printed off or downloaded, including the removal of any copyright or other proprietary notices contained in the website;

2.2.4 Any information on the Website which is marked as being confidential is treated as such and is not disclosed to any third party; and

2.3 You agree that you will not use any part of the Website to:

2.3.1 commit or encourage any criminal offence;

2.3.2 send or receive any material which is offensive, or which may be abusive, indecent, obscene or menacing, or in breach of confidence, copyright, privacy or any other rights. In the event, we believe any material falls within any or all of these categories, we shall be entitled to remove it without notice;

2.3.3 collect or store personal data about other users;

2.3.4 insert or knowingly or recklessly transmit or distribute a virus, worm, trojan horses, time bombs, trap doors or any other computer code, files or programs or repetitive requests designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment or to diminish the quality of, interfere with the performance of or impair the functionality of this Website;

2.3.5 upload, post, email or otherwise transmit or post links to any content that facilitates hacking;

2.3.6 hack into any aspect of this Website;

2.3.7 upload, post, email or otherwise transmit links to any content that infringes the intellectual property rights of any third party;

2.3.8 circumvent or attempt to seek to circumvent, any of the security safeguards of this Website;

2.3.9 cause annoyance to other people accessing this Website;

2.3.10 send any unsolicited advertising or other promotional material, commonly referred to as “spam”, “junk mail”, “chain letters”, “pyramid schemes” or any other form of solicitation by email or by any other electronic means;

2.3.11 send email or any other type of electronic message with the intention or result of affecting the performance or functionality or any computer facilities; or

2.3.12 permit any third party to do any of the above.

2.4 If you use the content of the Website in breach of these terms of use, your right to use the Website will cease immediately.

2.5 Paragraph 2.2 does not apply to content contained on third party websites.

2.6 No links to the Website may be included on any other site without our prior written consent. You are not entitled to modify or redistribute the contents of the Website.

3. DISCLAIMER

3.1 This Site is not directed at, or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject the firm to any registration or licensing requirement within such jurisdiction, such as the United States (but not limited to). Neither this website as a whole nor any part hereof shall constitute an offer of or the solicitation of an offer to invest, or the sale of securities, nor shall there be any sale of any investments or commitments in connection with this website in any jurisdiction in which such offer, solicitation or sale would be unlawful including the United Kingdom and the United States. The contents of this website do not constitute investment, legal, tax or other advice and should not be taken as such. NorthEdge Capital LLP acts as fund manager to funds on behalf of institutional and professional clients and does not offer investment advice or opportunities to retail clients as defined in the FCA handbook COBS 3.4. The regulated services provided by NorthEdge Capital LLP are only accessible to Eligible Counterparties or Professional clients as defined in COBS 3.5 & 3.6 of the Financial Conduct Authority handbook. As the firm is not permitted to deal with Retail clients this means that the same levels of protection afforded to Retail Clients would not be available to prospective regulated activity clients of the firm. Please seek independent professional financial and legal advice if you are unsure of your categorisation or if you wish to find out more about the products or services on this website.

3.2 The content made available on the Website is intended for general information purposes only and is provided on an “as is” basis. It does not constitute advice or the making of any recommendation and the content on the Website should not be relied upon as the basis for any decision or action. We exclude to the fullest extent permitted by law any and all liability for any direct, indirect or consequential loss or damage arising as a result of the access to and use of the Website or reliance on the content contained on it.

3.3 We aim to ensure the Website is updated regularly. However, we are under no obligation to update the material contained on the Website and cannot guarantee that the content will always be completely up to date. For this reason, we make no warranties or representations and do not give any undertakings either express or implied about any of the content of the Website (including, without limitation, the accuracy, completeness or fitness for purpose of such content or that your use of our Website will not infringe the rights of third parties or for any alleged or actual infringement of third party intellectual property rights). The use of information obtained from the Website is at your sole discretion and risk.

3.4 Articles may be added to the content of our Website. Such articles will be added to the content of the Website at our sole discretion. Any material submitted will be considered non-confidential and non-proprietary and we have the right to use, copy, distribute and disclose to third parties any such material. We cannot guarantee the accuracy of such articles and exclude to the fullest extent permitted by law any and all liability for any direct, indirect or consequential loss or damage arising as a result of the access to and use of such articles or
reliance on their content.

3.5 We take reasonable precautions to prevent viruses and malicious code on the website, but you are responsible for ensuring that anything downloaded from the Website is suitable for use on your computer and is free from viruses and malicious code and we exclude to the fullest extent permitted by law any and all liability that may arise in connection with or as a result of any failure to do so.

3.6 We do not represent, warrant or undertake that the use of the Website will be uninterrupted or error free.

3.7 Any transmission, downloading or sending of any information from this Website does not create any contractual relationship.

3.8 Nothing in these terms of use attempts to limit or exclude our liability for death or personal injury arising as a result of our negligence, or for fraudulent misrepresentation.

4. RISK WARNING

4.1 No representation or warranty is given that the information or opinions contained in this website are accurate, reliable or complete. Any information contained within this website is subject to amendment, revision or updating. NorthEdge Capital LLP reserves the right to suspend or withdraw access to the pages of this site without notice at any time and accepts no responsibility for these pages not being available at all times.

4.2 Users of this website must not transmit any virus, ‘worm’, ‘Trojan horse’, or other item of a destructive nature to this site and it is the user’s responsibility to ensure that whatever is downloaded or selected for use from the site is free from such items. This site is governed in accordance with the laws of England and Wales. By accessing the site, you agree to submit to the exclusive jurisdiction of the Courts of England and any adjudication they make in respect of litigation arising in connection with the site

5. THIRD PARTY WEBSITES

5.1  While we retain the right to establish hypertext links* between the Website and any third party website, if you choose to use such a hypertext link you will leave the Website. Once you leave the Website, whether or not you realise that you are leaving, we are not responsible in any way for the content of any other website that you enter. We exclude to the fullest extent permitted by law any and all liability whatsoever or howsoever arising in connection with or as a result of such external website content causing any damage, costs, injury or financial loss of any kind.

5.2  You agree not to create any hypertext links or deep links** between this Website and any third party site without our express prior written consent.

*Hypertext links are a means by which visitors can swap from one website to another or from one page to another within the same site.

**A deep link is like a hypertext link but takes the visitor into the website bypassing the homepage on the third party website.

6. EVENTS

6.1 

While we try to ensure that any events advertised on the Website will run in accordance with the programme as advertised, changes to the programme may be necessary. We will endeavour to post a notice of the changes on the Website as soon as is reasonably possible, however we will not be liable for any loss resulting from any such change.

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Privacy policy.

1. INFORMATION:

The information contained in this privacy policy statement is intended to provide you with details of how we may collect and process your personal data from

time to time and the circumstances giving rise to the request and receiving of data. This privacy policy applies:

• when you use our website;
• if you are a recruitment candidate;
• if your company is a potential investment opportunity for us; or
• we have a relationship with you or your company (as further described in the “why do we collect your personal data?” section below).

This Privacy Policy describes how NorthEdge Capital LLP will collect and process your personal data as a data controller. NorthEdge Capital LLP is referred to as “NorthEdge, the firm, we”, “us” or “our” in this privacy policy statement.

Contact Details

NorthEdge Capital LLP, 13 Floor, Number One Spinningfields, 1 Hardman Square, Manchester, M3 3EB, Company registration number: OC345118

Contact details for the purpose of this privacy policy statement and the person responsible for data protection and privacy for the firm is Charlie Page. Email: charlie.page@northedge.com

The firm’s ICO registration number is: ZA218544

• THE PERSONAL DATA WE MAY COLLECT ABOUT YOU:

Where we collect data that identifies an individual this is classed as “personal data”. Personal data may include (but is not limited to) a name, date of birth, contact address and telephone number.

The types of personal data we may collect are:

• Full name and Title including any previous names
• Gender identity
• Ethnicity
• Photographic proof of Identity (typically passports or photo driving licences)
• Proof of address (utility bill)
• Marital status
• Contact information such as postal address, residential address, email address and telephone numbers
• Tax information (Unique tax reference number and national insurance number)
• Information regarding your investment experience, wealth, source of funds and bank details
• Information regarding your knowledge of investment and types of transactions undertaken
• Current role, employment history and salary details
• Information relating to your health
• Marketing preferences which include the type of information you wish to receive and how
• Profile information including your interests, preferences and feedback
• Information we learn from you such as requests, transactions, services provided or offered, any advice or recommendations made, a log of meetings, telephone recordings (where permitted and required for regulatory purposes) complaints and dissatisfaction notes, as well as email exchanges.

The above list is not exhaustive and we may from time to time require additional information in order to satisfy our legal and regulatory obligations. Where additional information is required we will provide you with a reasonable explanation of why it is required unless we are prevented from doing so by law.

We may use methods such as anonymisation which is a process whereby we remove or replace identifying fields of data with other non-identifying data fields so that individuals can no longer be identified, therefore meaning the data is no longer personal. For example, we may use this method when we undertake our annual ESG (Environmental, Social and Governance) survey and publish our annual ESG report, or where we are required to retain certain types of information for clients, such as number of females and males employed, jobs created and average salaries paid. This type of statistical data is often required for ESG purposes to show value added investments we make  on behalf of our clients.

Use of this website

• The type of data we collect when you visit our site may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site as well as the types of products and services and searches you conduct on our site.
• Please see our Cookie Policy for your information on how this site uses cookies.

Special Category Data

Special Categories of Personal Data (“Special Category Data”) refers to any data which is sensitive and is subject to additional rules and requirements under the UK General Data Protection Regulation (“GDPR”). Special category data may include information regarding: race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data. Personal data relating to criminal convictions and offences (“Criminal Records Data”), although not technically Special Category Data, is treated in a similar way.

We may process Special Categories Data and Criminal Records Data in the following circumstances:

• As part of our recruitment process for staff and contractors undertaking regulated activities, we are required to request information relating to criminal convictions, to support our efforts to prevent fraud and other unlawful actions.
• As part of our equal opportunities monitoring activities, we may process special category data to monitor the existence or absence of equality of opportunity and treatment between groups of people with a view to enabling such equality to be promoted or maintained.
• As part of our assessment of your company as a potential investment opportunity, we may process information relating to your health with your explicit consent.

If we are required by law to request any Special Category Data or Criminal Records Data from you, aside from the reasons mentioned above, we will provide you with a reasonable explanation as to the nature and purpose for this request. We will only process such data where we have a lawful basis to do so. In limited circumstances, we may seek your consent to process such data, and where we do so, you have the right to withdraw your consent at any time.

• HOW DO WE COLLECT YOUR PERSONAL DATA?

Typically, where we are required to obtain your personal data we will request it from you. However, we may also from time to time receive your personal data through intermediaries, for example if we are considering whether to invest in your company or if your company is in our portfolio. Intermediaries should inform you how your personal data will be shared and processed in these circumstances. Intermediaries may include accountants, solicitors, Independent Financial Advisors, Tax Advisors and Wealth Managers who may be working on your behalf. Personal data may be provided to us via post, in person, email or via a specially created secure data room / platform. The data collection may be facilitated by way of intermediaries completing an application form or questionnaire or by responding to information requests from us. We may also obtain or receive information from publicly available resources, such as Companies House, social media channels or company websites.

• WHY DO WE COLLECT YOUR PERSONAL DATA?
• We only collect or process your personal data where we believe we have a legitimate business interest with you or we otherwise have a lawful purpose to do so (see table at the bottom of this notice). This includes where you:
• Are a shareholder in one of the companies to whom we have an administration and/or management agreement with
• Are a Limited Partner or an investor in one of the funds to which we are appointed manager/operator, or any other such investment schemes under our management
• Are actively receiving investment services or products from us under a contractual arrangement or engagement, or if we are otherwise considering whether to invest in your company
• Are one of our operating partners, or are an employee or act on behalf of one of our operating partners. Our operating partners are service providers who we consider may be of interest to users of our NorthEdge Nexus Platform. Users of this Platform are employees or former employees of companies with whom we have (or had) an administration and/or management agreement with. In this case, we display your contact details on our NorthEdge Nexus Platform, to enable our users to contact you directly in relation to your products/services
• Have expressed an interest in NorthEdge, for the purpose of managing and developing our relationship with you
• Consent to receiving communications from us
• If you or your company have a contractual agreement with us
• Request resources or marketing be sent to you
• Give us feedback or some other form or legitimate business interest with you
• If you or your company engage in our equal opportunities monitoring activities
• HOW AND WHY DO WE USE YOUR PERSONAL DATA

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message, or as otherwise notified to you at the time. You have the right to withdraw consent at any time by emailing us at info@northedge.com. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. More information as to the lawful basis and conditions (if applicable) for processing personal data is located at the end of this privacy notice.

Marketing communications

You will receive marketing communications from us if you have:

• requested information from us or have a contractual agreement with us; or
• if you provided us with your details and have consented to us sending you marketing communications; and
• in each case, you have not opted out of receiving that marketing.

We will get your consent before we share your personal data with any third party for marketing purposes, you should be advised that consent is not permanent and you can opt-out from receiving marketing communication from us at any time by emailing; info@northedge.com.

Where you opt out of receiving our marketing communications, this will not apply to any other communications we make with you in relation to a legitimate business interest or other lawful purposes, such as the performance of a contract we may have with you.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will obtain your consent for this purpose, unless we are otherwise required and/or permitted by law to process your personal data for that purpose.

• SHARING AND DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for legitimate business interests and lawful purposes, these may include but are not limited to:

• Other companies in our group who provide IT and system administration services and undertake leadership reporting. Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, tax advisors and insurers who provide consultancy, banking, legal, insurance, tax and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances which may include but is not limited to the Financial Conduct Authority
• Fraud prevention agencies.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We may also share your data on an aggregated and anonymised basis (only) with organisations producing equal opportunities monitoring reports in relation to diversity, equality and inclusion, for example, organisations supporting industry-wide initiatives such as the Investing in Women Code.

If you are one of our operating partners, or an employee or act on behalf of one of our operating partners, we will also share your name and contact details with users of our NorthEdge Nexus Platform. We consider this is necessary for our legitimate interests and your legitimate interests — in particular, our Platform provides you with an opportunity to advertise your business’ products and services. It also enables us to provide information to our users on service providers they may find of interest to further develop their own businesses.

• INTERNATIONAL TRANSFERS

Countries outside of the UK and European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so data protection law has prohibited transfers of personal data outside of the UK or EEA unless the transfer location meets certain criteria.

We do not typically share or transfer your data outside of the UK or the EEA and would only do so if a similar degree of protection was afforded to your personal data. In this case, we would ensure that a safeguard was in place, such as transferring your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data or use of specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

Please email info@northedge.com if you like further information regarding international transfers .

• THE SECURITY OF YOUR DATA

We have put in place adequate, proportionate and appropriate security measures as is required of an authorised firm to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with data breaches in accordance with the UK GDPR and we will notify you and/or any applicable regulator of a breach where we are legally required to do so.

• DATA RETENTION PERIODS

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our clients (including contact, identity, financial and transaction Data) for six years for tax purposes and for at least five years after a client ceases to be a client under the UK Money Laundering Regulations 2017.

In some circumstances we may anonymise your personal data for statistical purposes in which case we may use this information indefinitely without further notice to you.

1. INDIVIDUAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

These include the right to:

• Request access to your personal data (Subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data. Where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You have an absolute right to object at any time to the processing of your personal data for direct marketing purposes.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us at info@northedge.com. Please note that if you do not agree to the way we process your personal data, or if you do not provide us with certain data when requested, it may not be possible for us to provide our services (if applicable) to you.

You will not have to pay a fee to access your personal data (or to exercise any of your rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. In order to respond to a subject access request, we may need to confirm your identity as a security measure to safeguard you from your personal data from being disclosed to non-authorised third parties. Please provide us with as much information (as we may reasonably request) to enable us to comply with your request within an acceptable time-frame. We are required to respond to all requests within one month. Occasionally it may take us longer than a month if your request is complex or you have made several requests. In this case, we will notify you and keep you updated.

1. COMPLAINTS AND QUERIES

If you are not happy with any aspect of how we collect and use your data, please contact charlie.page@northedge.com and we will do our best to resolve your issue. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

1. ACCURACY

We will make all reasonable efforts to ensure the data we hold on you is accurate and up to date and to correct any inaccuracies that we become aware of. Please help us to comply with our obligations by letting us know of any changes in relation to the data we hold about you as It is very important that the information we hold about you is accurate and up to date. Please email info@northedge.com with any required updates or amendments.

1. CHANGES TO THE PRIVACY POLICY

NorthEdge reserves the right to modify or amend the Privacy Policy at any time and for any reason, as permitted by applicable law.

This Privacy Policy was last changed on 8 April 2026.

Further information: our lawful bases for processing your personal data

Further information on our legal bases and conditions for processing personal data is as follows:

Purpose of the processing	Legal basis and conditions for processing
Undertaking due diligence on the company (and its directors and board members, as applicable) for the purpose of assessing our management of the company and any related investment	Our legitimate interests to assess the viability of our management of the company, any related investment and assessment of any material risks For criminal records data: our legal obligations – we are required by law to undertake checks to comply with laws relating to money laundering and fraud. For health data (optional): explicit consent
Managing and administering the relationship we have with you or your company, as a company within our portfolio	Performance of our contract with you (if our contract is with you, as an individual) Our legitimate interests to manage our portfolio and perform our portfolio management duties Our legal obligations
Managing and administering the relationship we have with you or your company, if you are a Limited Partner or investor in funds to which we are appointed manager/operator, or any other such investment schemes under our management	Performance of our contract with you (if our contract is with you, as an individual) Our legitimate interests to manage the relationship we have with you or your company Our legal obligations
Providing investment services or products under a contractual arrangement or engagement	Performance of our contract with you (if our contract is with you, as an individual) Our legitimate interests to perform our contractual obligations / duties
Operating the NorthEdge Nexus Platform, including displaying and sharing operating partner contact details to enable users to contact service providers directly	Our legitimate interests in providing information to our users on service providers they may find of interest to further develop their own businesses, and the legitimate interests of operating partners in advertising their business’ products and services
Managing and developing our relationship with individuals who have expressed an interest in NorthEdge	Our legitimate interests in developing and maintaining business relationships
Sending marketing communications to you via email or text message	Your consent, which you can withdraw at any time by emailing info@northedge.com Our legitimate interests to contact you about marketing we think may be of interest to you
Collecting website usage data including login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform, and the types of products and services and searches you conduct on our site	Our legitimate interests in understanding the performance and use of our website, and improving user experience
Equal opportunities monitoring activities to monitor the existence or absence of equality of opportunity and treatment between groups of people with a view to enabling such equality to be promoted or maintained. E.g., through our annual ESG survey and report or contributions to the Investing in Women Code (all data will be aggregated and anonymised for this purpose)	Our legitimate interests in promoting diversity, equity and inclusion in potential investment opportunities, our portfolio and in our business, and (where applicable) contributing to industry statistics on DEI. For special category data: substantial public interest (equality of opportunity or treatment)
Undertaking KYC checks and screening against sanctions lists (in relation to our clients) in order to comply with anti-money laundering and counter-terrorism financing obligations and financial services regulations and to manage our financial crime risks and prevent fraud	Our legal obligations Where we process special categories of personal data or personal data relating to criminal convictions and offences, this processing is necessary for reasons of substantial public interest (regulatory requirements relating to unlawful acts and dishonesty).
Producing financial documentation (including statements and reports), maintaining board documentation, conducting audits, and conducting annual corporate filings/declarations	Our legal obligations Our legitimate interests in complying with our record-keeping and reporting requirements and maintaining good business practice
To monitor, maintain and improve internal business practices, for the day-to-day running of our business and to protect our employees and clients	Our legitimate interests to seek to continually improve and develop our business and to ensure we operate effectively as a business
Compliance with law (including general tax and accountancy requirements)	Our legal obligations
Sharing personal data with service providers who provide IT and system administration services	Our legitimate interests in the administration of our business and ensuring effective IT and system support
Sharing personal data with professional advisers including lawyers, bankers, auditors, tax advisors and insurers who provide consultancy, banking, legal, insurance, tax and accounting services	Our legitimate interests in obtaining professional advice and services to effectively manage our business operations Our legal obligations
Sharing personal data with HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions (including the Financial Conduct Authority) who require reporting of activities in certain circumstances	Our legal obligations to disclose information to regulators and tax authorities Our legitimate interests to protect our business and cooperate with government and regulatory authorities
Dealing with legal claims, disputes and proceedings	Our legitimate interests in protecting our business and enforcing our rights
Enable a proposed or actual sale, reorganisation, transfer or other transaction relating to our business	Our legitimate interests in managing our business
Recruitment activities including making decisions about recruitment, checking if candidates are legally entitled to work in the UK, screening to make decisions about appointments, and assessing suitability for work	Our legal obligations to verify identity and check right to work Our legitimate interests in recruiting suitable candidates. For criminal records data: the processing is necessary for reasons of substantial public interest (preventing or detecting unlawful acts).

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Cookies.

This page describes NorthEdge Capital LLP (NorthEdge) cookie policy, which applies to this website. If you do not accept this Cookie Policy please do not use this site.

What are cookies?

For almost any modern website to work properly, it needs to collect certain basic information on its users. To do this, a site will create files known as cookies – which are small text files – on its users’ computers. These cookies are designed to allow the website to recognise its users on subsequent visits, or to authorise other designated websites to recognise these users for a particular purpose.

Cookies do a lot of different jobs which make your experience of the Internet much smoother and more interactive. For instance, they are used to remember your preferences on sites you visit often, to remember your user ID and the contents of your shopping baskets, and to help you navigate between pages more efficiently. They also help ensure that the advertisements that you see online are more relevant to you and your interests. Much, though not all, of the data that they collect is anonymous, though some of it is designed to detect browsing patterns and approximate geographical location to improve user experience.

Information collected by cookies is not personally identifiable.

What types of cookie are there?

Broadly speaking, there are four types of cookie: strictly necessary cookies, performance cookies, functionality cookies and targeting or advertising cookies.

• Strictly necessary cookies are essential to navigate around a website and use its features. Without them, you wouldn’t be able to use basic services.
• Performance cookies collect anonymous data on how visitors use a website; they can’t track users, and are only used to improve how a website works.
• Functionality cookies allow users to customise how a website looks for them: they can remember usernames, language preferences and regions, and can be used to provide more personal services like local weather reports and traffic news.
• Advertising and targeting cookies are used to deliver advertisements more relevant to you, but can also limit the number of times you see an advertisement, and be used to chart the effectiveness of an ad campaign by tracking users’ clicks.

Additionally, these cookies break down into two further sub-types.

• Persistent cookies remain on a user’s device for a set period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
• Session cookies are temporary. They allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser windowand finishes when they close the browser window. Once you close the browser, all session cookies are deleted.

 
What’s the law?

Recently, the law on cookies has changed. Now sites that try to place performance, functionality, and targeting and advertising cookies need your permission before they can place them onto your computer.

How does NorthEdge use cookies?

NorthEdge collects a number of cookies from its users for various reasons, not least to track our own performance – but also it will assist in improving your overall experience of the site. Amongst other things, the cookies we use allow us to calculate how many visitors we have – anonymously, of course – and how long they stay on our site.

We do our utmost to respect users’ privacy. We use these cookies to monitor and improve our services. We believe that your experience of the site would be adversely affected if you opted out of the cookies we use.

Google Analytics

NorthEdge uses Google Analytics to monitor visits to our website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

We set the following cookies:

Cookie Name	Cookie Description	Cookie Purpose	Cookie Description	ICC UK Definition
__utma	Google Analytics	Identifying Unique Visitors	Each unique browser that visits a page on our site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to your website via the same browser are recorded as belonging to the same (unique) visitor.	Performance
__utmb __utmc	Google Analytics	Determining Visitor Session	The Google Analytics tracking for ga.js uses two cookies to establish a session. If either of these two cookies are absent, further activity by the user initiates the start of a new session.	Performance
__utmz	Google Analytics	Tracking Traffic Sources & Navigation	When visitors reach our site via a search engine result, a direct link, or an ad that links to our page, Google Analytics stores the type of referral information in a cookie. This cookie gets updated with each subsequent page view to your site; thus it is used to determine visitor navigation within your site.	Performance

How do I turn cookies off?

Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally you have the option to accept all cookies, to be notified when a cookie is issued or reject all cookies. Visit the ‘options’ or ‘preferences’ menu on your browser to change settings. You can find out more about how to switch off cookies here here.

User agreement

By continuing to use our site, you agree to the placement of cookies on your device. If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling
as it would otherwise be. For instance, the site won’t be able to recognise your commenter ID, meaning that you won’t be able to leave comments.

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Disclaimer.

Legal Notice

This website is issued by NorthEdge Capital LLP and is for informational purposes only. Use of this website is subject to the following terms. By using this website, you are deemed to have accepted these terms.

This Site is not directed at, or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject the firm to any registration or licensing requirement within such jurisdiction, such as the United States (but not limited to). Neither this website as a whole nor any part hereof shall constitute an offer of or the solicitation of an offer to invest, or the sale of securities, nor shall there be any sale of any investments or commitments in connection with this website in any jurisdiction in which such offer, solicitation or sale would be unlawful including the United Kingdom and the United States. The contents of this website do not constitute investment, legal, tax or other advice and should not be taken as such. NorthEdge Capital LLP acts as fund manager to funds on behalf of institutional and professional clients and does not offer investment advice or opportunities to retail clients as defined in the FCA handbook COBS 3.4. The regulated services provided by NorthEdge Capital LLP are only accessible to Eligible Counterparties or Professional clients as defined in COBS 3.5 & 3.6 of the Financial Conduct Authority handbook. As the firm is not permitted to deal with Retail clients this means that the same levels of protection afforded to Retail Clients would not be available to prospective regulated activity clients of the firm. Please seek independent professional financial and legal advice if you are unsure of your categorisation or if you wish to find out more about the products or services on this website.

Risk Warning

The investments communicated may relate to investments in unlisted securities which carry a high degree of risk due to their illiquid nature, Investments may fall as well as rise and you may not get back all you have invested. Past performance should not be seen as an indication of future results, you may lose some, part or all of your original capital invested.

No representation or warranty is given that the information or opinions contained in this website are accurate, reliable or complete. Any information contained within this website is subject to amendment, revision or updating. NorthEdge Capital LLP reserves the right to suspend or withdraw access to the pages of this site without notice at any time and accepts no responsibility for these pages not being available at all times.

Users of this website must not transmit any virus, ‘worm’, ‘Trojan horse’, or other item of a destructive nature to this site and it is the user’s responsibility to ensure that whatever is downloaded or selected for use from the site is free from such items.

This site is governed in accordance with the laws of England and Wales. By accessing the site, you agree to submit to the exclusive jurisdiction of the Courts of England and any adjudication they make in respect of litigation arising in connection with the site.

Confidentiality

Information is an asset and NorthEdge Capital LLP acknowledges that there is a corporate responsibility to safe guard such information provided to us by our clients. NorthEdge Capital LLP has in place policies and procedures with regards to office and Data security and Data protection and we are fully committed to comply with our obligations as set out in the Data Protection Act 1998 and the forthcoming GDPR. If you require full details of the information on what type of information we hold on our clients and how we safeguard this information, please contact the firm’s Compliance Officer “Charlie Page”. The firms ICO registration number is ZA218544

Complaints

We are committed to working with our clients to achieve best client outcomes, and we welcome feedback and the opportunity to improve our service. Please direct any complaints or queries to the firm’s compliance officer in writing in the first instance as follows:

Charlie Page, NorthEdge Capital LLP, 13th Floor, Number One Spinningfields, 1 Hardman Square, Spinningfields, Manchester, M3 3EB

Although the firm does not have eligible complainants as defined in the FCA handbook DISP 2.7.3R, the firm is committed to achieving best client outcomes. The firm has a complaints policy and procedure and as such we will acknowledge receipt of your complaint / enquiry, in writing, and endeavour to resolve any issues as soon as is practicably possible. However on occasion matters may take longer to investigate and in this instance we will keep you informed and will provide you with our final written response within eight weeks of receipt of the complaint.

TCF Policy Statement

The firm is committed to Treating customers fairly and as such has a TCF policy which sets out the firm’s procedures and obligations. Although the firm does not have Retail clients, it does have a duty to achieve best client outcomes and adhere to the FCA handbook rule PRIN 2.1.1R, and the TCF initiative which as per principle 6 states “A firm must pay due regard to the interests of its customers and treat them fairly”.

Anti-Bribery and Corruption Policy

NorthEdge Capital LLP is committed to apply the highest standards of ethical conduct and integrity in its business activities.  Every employee and individual acting on behalf of NorthEdge Capital LLP is responsible for conducting business honestly and professionally.

NorthEdge Capital LLP benefits from carrying out business in a transparent and ethical way and by helping to ensure that there is honest, open and fair competition in our sectors.  Where there is a level playing field NorthEdge Capital LLP can lead the market through innovation and by delivering excellent services to its customers.

NorthEdge Capital LLP does not tolerate any form of bribery by, or of, its employees or any persons or companies acting for it or on its behalf. The Partners and senior management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

NorthEdge Capital LLP has issued an Anti-Bribery policy in order to prevent and prohibit bribery and corruption.  The Anti Bribery policy applies to all employees and they are required to familiarise themselves and comply with the policy.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of NorthEdge Capital LLP are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its Anti-bribery measures, NorthEdge Capital LLP is committed to engage only in transparent, proportionate, reasonable and legitimate hospitality and promotional expenditure.

A breach of the NorthEdge Capital LLP anti bribery policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.  Employees and other individuals acting for NorthEdge Capital LLP should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for NorthEdge Capital LLP.

NorthEdge Capital LLP will not conduct business with service providers, agents or representatives that do not support the firm’s anti-bribery and corruption objectives.

The success of NorthEdge Capital LLP’s anti-bribery measures depends on everyone playing their part in helping to detect and eradicate bribery.  Therefore, all employees and others acting for, or on behalf of NorthEdge Capital LLP are encouraged to report any suspicious activity to the Whistle Blowing Officer Ray Stenton. NorthEdge Capital LLP senior management will support any individuals who make such a report in good faith. NorthEdge Capital LLP does not hold any responsibility for contractors or agents whom act on their own initiative and do not comply with the firm’s anti bribery policy despite agreeing to do so, and reserves the right not to deal with any persons or firms who do not agree to the firm’s anti bribery policy. Acceptance of our policy is deemed as acceptance of compliance with the firm’s policy.

NorthEdge Capital LLP is authorised and Regulated by the Financial Conduct Authority – FRN 502462, and is Registered in England and Wales No OC345118, Number One Spinningfields, 1 Hardman Square, Spinningfields, Manchester, M3 3EB, VAT Registration number 135 6130 37, ICO Registration number: ZA218544