Sarasin Funds Management Limited

BACKGROUND The Firm is authorised by the Central Bank as a UCITS1 fund management company. The Firm does not have any employees but is managed by a Board of non-executive directors. The Firm’s Business Plan dated 20 September 2016 (the Business Plan) set out how it intended to comply with its regulatory obligations which included the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (the UCITS Regulations) and the Central Bank (Supervision and Enforcement) Act 2013 (Section 1 A UCITS (Undertaking for Collective Investment in Transferable Securities) is an investment fund that pools cash subscribed by investors and invests in a range of assets in accordance with its investment objective and policies. A UCITS is marketable to retail investors. 48(1)) (Undertakings for Collective Investment in Transferable Securities) Regulations 2015 (as amended)(the CBI UCITS Regulations). The Business Plan stated that, while the Board of Directors were jointly responsible for all the activities of the Firm, the monitoring of certain functions was assigned to the Designated Directors. The Firm delegated certain day-to-day functions to a number of service providers, including the investment management function to the Investment Manager, the depositary function to a Depositary, and the administration function to an Administrator (the Delegates). The UCITS Regulations permit the delegation by Irish fund management companies of certain tasks to external delegates. However, such a delegation does not reduce the management company’s responsibility to comply with its regulatory obligations.