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Newton Investment Management Limited
Newton Investment Management North America LLC

Terms & conditions of access to the Newton website (“the Terms”)

Please read the Terms carefully. By accessing any page of this website, you agree to be bound by the Terms below. If you do not agree to the Terms below, please do not access any pages of this website. This website is primarily intended for persons located in the United Kingdom and any other jurisdictions where Newton is permitted to undertake business. Please do not access the Newton website unless it is lawful for you to do so.

These Terms are legal terms governing use of the website of Newton Investment Management Limited (“NIM”), Newton Investment Management North America LLC (“NIMNA”) and Newton Investment Management Japan Ltd. (“NIMJ”), collectively known as Newton or the Newton Group, in relation to the services offered by the Newton Group (“the Services”). These Terms contain the full and complete understanding between Newton and you relating to this website or the Services. No advice or information, whether oral or written, obtained by you through or from the website or from any conversation with Newton staff or a professional financial adviser will operate to vary these Terms.

These Terms may be amended by Newton at any time. Following an amendment to these Terms, this page will be updated to reflect the change, and users of Newton Portal will also be prompted to read and accept our current Terms the next time they access Newton Portal. You should review these Terms each time you use this website to make sure you agree to them. By using this website or engaging in any of the activities described in these Terms after changes have been made to these Terms, you are agreeing to accept and comply with those changes.

Please note that the website may use pop-up windows to display certain types of information. Please therefore ensure that you have disabled pop-up blockers from your browser when using the website. Newton will not be held liable for any loss incurred as a result of your inability to view information resulting from the use of pop-up blockers.

1. Jurisdiction and governing law

These Terms and any and all contracts concluded under them (and any related non-contractual matters) are governed by and shall be construed in accordance with the laws of England and Wales and all references in these Terms to laws and regulations are references to English laws and regulations unless otherwise specified. You agree that any dispute(s) arising out of the Terms or otherwise between us shall be subject to the exclusive jurisdiction of the Courts of England and Wales.

2. Content of website

Whilst care has been taken to ensure the information contained within this website is accurate and up-to-date, no warranty is given as to the accuracy or completeness of any information and no liability is accepted for any errors or omissions in such information. All products referred to on this website are subject to change without notice. Newton may amend this website and our products and services at any time with or without notice to you. You agree that Newton shall not be liable to you or to any third party for any amendment, modification, suspension, or discontinuance of the website or any products or services offered through the website.

3. Use of the website

You agree that you will only use the website in a way which is consistent with the Terms and which complies with applicable laws and regulations. In particular, you agree that you will not use the website to send or upload any material containing software, viruses or other codes, programs or files designed to interrupt, destroy, damage or limit the functionality of any computer software, hardware or telecommunications equipment or in any other manner which would interfere with or disrupt the website.

4. Linking

We do not endorse and accept no responsibility for the content of any website not operated by Newton or BNY Mellon which you may visit by following a link from this website. Newton accepts no responsibility for any information contained in any website accessed via a hypertext link from this website. No other person/company may link their website into Newton’s website without the express written permission of Newton. The content, accuracy and opinions expressed in such websites are not checked, analysed, monitored or endorsed by Newton. Access to any third party website is at your own risk. You agree that Newton has no responsibility or liability for any third party website and that Newton shall not be liable in any way for any damage or loss caused in relation to the content, goods, products or services available through or mentioned in such third party websites.

5. Product availability

The information contained on this website does not constitute a distribution, an offer to buy or sell or the solicitation of an offer to buy or sell securities or investments in any jurisdiction or to engage in any other transaction, or to provide any investment advice or service. Some products and services detailed on this website may only be available to Professional Clients, as defined by the Financial Conduct Authority, or only to persons in certain named countries. If you are accessing this website outside the UK, your local legislation may not permit us to offer products to you in your own country. Please check with your professional financial adviser as to whether such products are available in the country in which you are resident.

6. No Advice

Information contained on this website is for information purposes only. Newton does not offer investment advice on the merits or suitability of its products or services or the purchase or sale of any security and no information contained within this website should be construed as such. No warranty is given in relation to any information or advice, whether oral or written, obtained from Newton through this website or otherwise.

Newton only provides information about the products it manages and its services and does not give investment advice based on individual circumstances. Newton believes that it is important that any investments you make are suitable for your needs. Therefore we recommend that prior to making an investment into any of our products you consult with a professional financial adviser who will be able to consider your particular investment and help you to determine which is most appropriate for your circumstances.

7. Taxation

Tax treatment depends on the individual circumstances of each client and may be subject to change in the future. Newton is not a tax expert and independent tax advice should be sought. Except where stated otherwise, the contents of this website are based on Newton’s interpretation of relevant taxation law and practice as at the date appearing at the foot of each product fact sheet. While we believe this interpretation is correct, we can give no guarantee that tax reliefs and the tax treatment of funds will remain the same in the future. The value of any tax reliefs will depend on individual financial circumstances and the country of residence of the relevant investor. If you are in any doubt, you are advised to consult your professional financial and tax advisers.

8. Liability

To the extent permitted by law, Newton accepts no legal liability for loss, damages or expenses which you may suffer or incur directly or indirectly by you accessing this website. Newton assumes no liability (direct or consequential or any form of liability) for any errors in, or reliance upon, the information contained in the website. Newton and/or any of its affiliates are not responsible for any subsequent investment advice given based on the information contained in the website. Newton reserves its right to restrict, suspend or terminate your use of this website at any time in its absolute discretion. Newton will use all reasonable efforts to keep this website operational at all times but Newton does not guarantee that the website or that use of the website will be free from fault, interruption or error, nor that the website will be continuously accessible. Access to the website may be interrupted or restricted at any time for routine or emergency maintenance or repairs or to introduce new facilities, products, functionality or services. The security and reliability of communications on the internet cannot be assured. Newton cannot be held responsible for any disruptions, insecurity, viruses and other risks associated with internet usage. Newton excludes all liability for direct and indirect losses from such matters.

9. “Newton Portal” service

In addition, the following applies to the “Newton Portal” facilities:

The “Newton Portal” facilities are secure sections of the website that provide online access to certain information relating to your investment account. Information available via “Newton Portal” may include unaudited and audited data. Unaudited data has not been reconciled, reviewed or finalised by Newton and is provided for information purposes only. Newton cannot guarantee the accuracy of, and shall not accept liability for, any reliance placed upon the unaudited data via “Newton Portal”, including any unaudited or audited data which is able to be downloaded and manipulated by you. Newton does not take responsibility for the data or how this data may be displayed on your computer. For complete audited valuations and stock transactions please refer to the periodic valuation statements, where available, via “Newton Portal” and which may also be sent to you by Newton in accordance with your investment management agreement, if relevant.

You shall assume responsibility for ensuring that your username and password are kept secure and secret at all times and not disclose these to anybody else. Your username and password should be reserved for your use only. Newton does not accept liability for any unauthorised access to your account via “Newton Portal”, or for any use or misuse of any information by any person authorised to have access to your account via “Newton Portal”. You, or any person authorised by you to have access to your account, shall notify Newton in the event that you or they no longer require access to “Newton Portal”. If you or they know, or suspect, that someone else has obtained the username or password to your account or accessed your account without authorisation, please contact Newton immediately.

Newton may stop or suspend access via “Newton Portal” if it reasonably considers it necessary, including without limitation because it suspects that there may be unauthorised access.

10. Downloading and copying

You may download materials and information from the website to a single personal computer and/or print a hard copy of any materials and information from the website in order to help you decide whether to invest in a Newton product or service or to take advice from a professional financial adviser regarding any Newton product or service provided that you do not delete, change or modify in any way any copyright notices or disclaimers attaching to such materials and information. Except for this limited licence you may not copy, reproduce, re-publish, upload, post, transmit or distribute any material on this website in any way. Doing so could constitute an infringement of Newton’s and/or a third party’s copyright and other intellectual property rights and/or may constitute an infringement of laws, rules or regulations applicable to the marketing or sale of securities. You may not download or copy material in breach of any applicable law, whether in the place where the download is made or in breach of any law prohibiting the export or use of technology or information, including any United Kingdom or European Union embargos or sanctions, U.S. Department of Treasury or U.S. Department of Commerce regulations, including to a resident of or location in any nation to which the US or UK has embargoed goods.

11. Ownership and copyright

The copyright and other intellectual property rights contained in the website and (unless otherwise indicated) its contents, including all information, graphics, code, text and design, are owned by Newton. All material on this website is Copyright © Newton Investment Management Limited, Newton Investment Management North America LLC and Newton Investment Management Japan Ltd. All rights reserved. Unauthorised distribution or use of this material is strictly forbidden.

In the event of a professional financial adviser wishing to publish or distribute written marketing or other promotional material based upon the content of this website he/she may only do so having first obtained the prior written consent of Newton. Newton prohibits any website linking to, or framing of, this website without its prior written permission.

12. Trademarks

This website contains names and logos which are trademarks of Newton and The BNY Mellon Corporation. Unauthorised use of any Newton or BNY Mellon Corporation name and logo is strictly forbidden.

13. Severability

In the event that any part of these Terms is held by a court of competent jurisdiction to be invalid or unenforceable then the remainder of these Terms shall remain valid and enforceable. If any part of these Terms is found by a court of competent jurisdiction to be invalid, then you nevertheless agree that the court shall endeavour to give effect to Newton’s intentions as reflected in the Terms.

14. Regulatory Information

UK and US

NIM is registered in England No. 01371973 and its registered office is at BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA, United Kingdom. VAT registration number GB: 577 7181 95. The LEI of NIM is VMMM74BJK67DIRDE9J26. NIM is authorised and regulated by the Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN and is a subsidiary of The Bank of New York Mellon Corporation. NIM is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940.

NIMNA is a registered investment adviser and subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). NIMNA was established in 2021, Newton’s investment business is described in NIM and NIMNA’s Form ADV, Part 1 and 2, which can be obtained from the website or obtained upon request.

NIMJ was established in March 2023. NIMJ is authorised and regulated by the Japan Financial Services Agency (JFSA).

Personnel of certain of our BNY Mellon affiliates may act as: (i) registered representatives of BNY Mellon Securities Corporation (in its capacity as a registered broker-dealer) to offer securities, (ii) officers of the Bank of New York Mellon (a New York chartered bank) to offer bank-maintained collective investment funds, and (iii) Associated Persons of BNY Mellon Securities Corporation (in its capacity as a registered investment adviser) to offer separately managed accounts managed by BNY Mellon Investment Management firms, including Newton.

All companies cited above are subsidiaries of The Bank of New York Mellon Corporation. BNY Mellon is the corporate brand of The Bank of New York Mellon Corporation and may also be used as a generic term to reference the Corporation as a whole or its various subsidiaries generally. Products and services may be provided under various brand names and in various countries by subsidiaries, affiliates and joint ventures of The Bank of New York Mellon Corporation where authorised and regulated as required within each jurisdiction. Unless you are notified to the contrary, the products and services mentioned are not insured by the Federal Deposit Insurance Corporation (or by any governmental entity) and are not guaranteed by or obligations of The Bank of New York Mellon Corporation or any of its affiliates. The Bank of New York Corporation assumes no responsibility for the accuracy or completeness of the above data and disclaims all expressed or implied warranties in connection therewith.


NIM is availing itself of the International Adviser Exemption (“IAE”) in the following Canadian Provinces: Alberta, British Columbia, Ontario and Quebec and the foreign commodity trading advisor exemption in Ontario.

NIMNA is availing itself of the IAE in the following Canadian Provinces: Alberta, British Columbia, Ontario and Manitoba and the foreign commodity trading advisor exemption in Ontario. The IAE is in compliance with National Instrument 31-103, Registration Requirements, Exemptions and Ongoing Registrant Obligations.


NIM is providing financial services to wholesale clients in Australia in reliance on ASIC Corporations (Repeal and Transitional) Instrument 2016/396, a copy of which is on the website of the Australian Securities and Investments Commission, The Instrument exempts entities that are authorised and regulated in the UK by the FCA, such as NIM, from the need to hold an Australian financial services license under the Corporations Act 2001 for certain financial services provided to Australian wholesale clients on certain conditions. Financial services provided by NIM are regulated by the FCA under the laws and regulatory requirements of the United Kingdom, which are different to the laws applying in Australia. This information is made available by NIM and Emesco Agents Pty Ltd. This information is confidential and is only provided to Australian wholesale clients (as that term is defined in section 761G of the Corporations Act 2001 (Cth)). This is not an offering or the solicitation of an offer to purchase an interest in any financial product referred to in this website. This content is for general purposes only and should not be relied upon as financial product advice. This content has been prepared without taking into account the objectives, financial situation or needs of any person. Before making an investment decision an investor should consider the appropriateness of the information in this website having regard to these matters and read the disclosure document relating to a financial product. Investors should also consider obtaining independent advice before making any investment decisions. Investments can go up and down and to the extent that this website contains any past performance information, past performance is not a reliable indicator of the future performance of the relevant investment or any similar investment strategy. NIM is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to wholesale clients in Australia and is authorised and regulated by the FCA of the UK under UK laws, which differ from Australian laws. To visit this website users must qualify as a “wholesale client” as that term is defined in section 761G of the Corporations Act 2001 (Cth).

15. Risk warnings

The opinions expressed in this website are those of Newton and should not be construed as investment or any other advice and are subject to change. This website is for information purposes only and does not constitute an offer or solicitation to invest. Other content on this website may have been provided by external sources which is believed to be accurate and complete but cannot be guaranteed as such. Assets under management include assets managed by NIM, NIMNA and NIMJ and assets managed by Newton personnel acting as dual officers of affiliated companies.