Important Information

This website is presented by Amber Capital for information purposes only.

Amber Capital UK LLP is a limited liability partnership registered in England and Wales with registered number OC322586 and is authorised and regulated by the Financial Conduct Authority of the United Kingdom (with Firm Reference Number 467505). In addition Amber Capital Italia SGR SpA is regulated by the Bank of Italy.

The website is directed only at persons who fall within the definition of “professional client” within the FCA rules and by clicking the “I accept” button below, persons accessing this website confirm that they fall within this definition.

No information or opinions contained in this website constitute a solicitation or offer by Amber Capital to buy or sell any financial instrument or to provide any investment service or other service.

This website is intended as a general introduction to Amber Capital. It does not provide specific investment advice nor does it represent that the services described are suitable for any specific investor. Moreover, the information contained in this website does not provide a basis for making any investment decision, nor do the contents of this website constitute legal, tax or accounting advice or advice regarding the suitability or profitability of any transaction or investment.

The contents of this website are not intended for distribution to, or use by, any individual or entity in any jurisdiction where their distribution or use would be contrary to local law or regulation or which would subject Amber Capital to registration with the jurisdiction. You should be aware that any rules and/or regulations applicable to providing financial services (and the resultant investor protections that may be available), may not apply to persons who obtain information from the internet and its various applications, of which this material forms part.

Information contained on this website, including commentary or opinions, reflects Amber Capital’s analysis and other information available as at, either the time such information was posted in the website or as otherwise at the date indicate, and whilst believed to be reliable, Amber Capital cannot and does not guarantee its accuracy, timeliness or completeness, nor is Amber Capital under any obligation to update such information. Amber Capital has not reviewed unaffiliated sites to which this website is linked, and is not responsible for the content of off-site pages or any other site linked or linking to the site. Your linking to any off-site pages or other sites is at your own risk. Amber makes no representations whatsoever about the opinions of any third party appearing on a linked site, neither regularly monitors nor has control over the contents of such sites, and does not endorse, and disclaims all responsibility for, the content of such statements or websites.

Neither Amber Capital nor any of its directors, officers or employees, nor any third party vendor will be liable or responsible for any loss or damage that you may incur from any cause relating to your access to, inability to access, or use of the website or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Amber Capital or of any vendor providing software or services support. In no event will Amber Capital or any third party vendor be liable to you for any direct, special, indirect, consequential, incidental damages or any other damages of any kind even if Amber Capital or any other party had been advised of the possibility that these damages might occur.

SBAI Disclosure

No responsibility, duty of care or liability whatsoever (whether in contract or tort or otherwise including, but not limited to, negligence) is or will be accepted by the Standards Board for Alternative Investments Limited ("SBAI"), the Board of Trustees of the SBAI, any member of the SBAI's Investor Chapter (each an "Investor Chapter Member")  or a Core Supporter of the SBAI to Signatories, investors or any other person in connection with the Standards or any Conformity Statement or Disclosure Statement made by any Signatory. A Core Supporter can be a Signatory to the Standards, a member of the SBAI’s Investor Chapter or an investment consultant.

Neither the SBAI nor its Board of Trustees is a regulator of the alternative investment industry and their role does not extend beyond being a custodian of the Standards. None of the SBAI, its Board of Trustees, the Investor Chapter Members and the Core Supporters will seek to enforce compliance with the Standards by Signatories. The fact that a manager is a Signatory to the Standards is not and should not be taken as an endorsement of such manager by the SBAI, the Board of Trustees, any Investor Chapter Member or any Core Supporter or as a representation by the SBAI, the Board of Trustees, any Investor Chapter Member or any other Core Supporter that such Signatory operates in conformity with the Standards. In determining whether to accept a manager's application to become a Signatory (or whether to revoke a manager's status as a signatory), the Board of Trustees is entitled to rely on the information provided to it by such manager without further investigation or verification. Further, subject to any duties a Trustee may have under applicable law, it is not envisaged, or expected, that a Trustee will when participating in any such decision of the Board of Trustees take into consideration information which it may possess otherwise than in its capacity as a Trustee. For the avoidance of doubt, Trustees act as individuals.

None of the SBAI, the Board of Trustees of the SBAI, the Investor Chapter Members and the other Core Supporters accept any responsibility or liability for any loss or damage caused to any person who acts or refrains from acting as a result of anything contained in or omitted from the Standards or any Conformity Statement or Disclosure Statement made by any Signatory or in reliance on the provisions of or material in the Standards or any Conformity Statement or Disclosure Statement made by any Signatory, whether such loss or damage is caused by negligence or otherwise.

I accept

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Amber Capital UK LLP (“Amber”) is required to disclose in an accessible form a statement about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.

Amber pursues a multi-strategy approach to investing that, among other matters, involves it trading in global equities, including some UK equities. The Code is therefore relevant to some aspects of Amber’s trading. While Amber generally supports the objectives that underlie the Code, Amber has chosen not to commit to the Code. Amber invests in a variety of asset classes and in a variety of jurisdictions globally. Amber’s policies in relation to engagement with issuers and their management are determined globally on group-wide basis. The group takes a global approach to engagement with issuers and their management in all of the jurisdictions in which it trades and, consequently, Amber does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

Shareholder Rights Directive

Amber Capital UK LLP is currently considering whether it will adopt an engagement policy pursuant to Article 3g of the amended EU Shareholder Rights Directive (Directive 2007/36/EC). When that decision has been made, this webpage will be updated accordingly.

RTS28 Disclosures

Amber Capital UK LLP Annual Best Execution Disclosure 2017

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Amber Capital UK LLP Annual Best Execution Disclosure 2018

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Amber Capital UK LLP Annual Best Execution Disclosure 2019

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Amber Capital Italia SGR SPA Annual Best Execution Disclosure 2017

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Amber Capital Italia SGR SPA Annual Best Execution Disclosure 2018

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Amber Capital Italia SGR SPA Annual Best Execution Disclosure 2019

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Privacy Notice

This Privacy Policy explains how we use the personal information that Amber Capital generally collects or generates in relation to our products and services. This Privacy Policy applies to you if:

(A) You are a client or potential client of Amber Capital;

(B) You have requested to receive any Amber Capital marketing material including performance information and newsletters; and/or

(C) You have given your Personal Data to Amber Capital for any other purposes, for example including but not limited to as a current, former or prospective service provider, vendor, employee or partner.

If you are an existing investor in a fund managed by Amber Capital you will have received separate notification (“Investor Privacy Notice”) that includes, but is not limited to, a description of the personal data that is collected, how the information is used and your rights. Potential investors will also receive a copy of the Investor Privacy Notice prior to investment. Please contact IR@ambercapital.com for further information in relation to the Investor Privacy Notice.

1. BACKGROUND

1.1 Amber Capital UK LLP with its registered office at 14-17 Market Place, London W1W 8AJ, UK (“Amber UK”) and other companies in the Amber Capital group, including Amber Capital Italia SGR S.p.A whose registered office is at Piazza del Carmine 4, 20121 Milan, Italy (“Amber Italy”) each acts as a data controller and/or data processor in respect of your Personal Data for the purposes of the European Union General Data Protection Regulation (“GDPR”). Amber Capital is responsible for ensuring that it uses your Personal Data in compliance with GDPR and applicable data protection laws.

1.2 At Amber Capital we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Amber Capital in the course of carrying on commercial activities.

1.3 We use the following definitions in this Privacy Policy:

“Amber Capital”, “we or “us” means Amber UK, Amber Italy and other companies in the Amber Capital group.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Amber Capital (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Amber Capital or any other person in respect of an individual.

2. THE TYPES OF PERSONAL DATA THAT CAN BE USED

2.1 We might collect and process the following Personal Data about you:

  • Information that you provide to us: This includes information about you that you provide to us. Although the kind of Personal Data will vary depending on the nature of the interaction and service, information that might be provided in the normal course of doing business with you includes, but is not limited to:
    • basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
    • any information that you choose to share face-to-face, by telephone, by email or otherwise. This may include residential addresses or other contact details, signature, nationality, date and place of birth, tax identification number, copies of identification documents, bank account details, but may also include information about assets or net worth, credit history, source of funds details, as well as special categories of data, such as information about a person’s family, ethnic origin, religious beliefs, or other which may be considered sensitive information.
  • Information that we collect or generate about you: This may include information relating to your investment or potential investment in an Amber Capital managed fund or an account with us, emails, call recordings, website usage data, records of our interactions with you and minutes and notes in relation to our contact with you.
  • Information we obtain from other sources: This might include information from public websites, credit reference agencies and other public sources and information received from any of your advisers, intermediaries or agents.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

(A) Assessing eligibility as a potential investor in a fund managed by Amber Capital or providing other investment services to you;

(B) General business administration, including communicating with you, communicating with service providers on your behalf where necessary and any counterparties, accountancy and audit services, risk monitoring and administration of IT systems;

(C) Compliance with legal and regulatory obligations and industry standards;

(D) Providing Amber Capital marketing and investment material and recording interactions with you for marketing purposes;

(E) For future employment purposes if you or your agent has sent us a resume or other personal information; or

(F) To assess your services if you are a vendor and you or your representative has sent us information about your goods or services. We are entitled to process your Personal Data in these ways for the following reasons:

(A) Processing may be necessary to discharge a relevant legal or regulatory obligation;

(B) The processing will, in all cases, be necessary for Amber Capital’s legitimate business interests such as:

(1) carrying out Amber Capital’s business activities, including investment services and direct marketing;

(2) ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;

(3) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and

(4) ensuring the security of information systems.

(C) We have your consent;

(D) In respect of any processing of sensitive Personal Data falling within special categories, such as any Personal Data relating to political opinions of a politically exposed person, the processing will be necessary for reasons of substantial public interest.

3.2 We will take steps to ensure that the Personal Data is accessed only by employees of Amber Capital that have a need to do so for the purposes described in this Privacy Policy.

4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

4.1 We may share your Personal Data within the Amber Capital group of companies for the purposes described above.

4.2 We may also share your Personal Data outside of the Amber Capital group for the following purposes:

  • With other third parties for the purposes of providing services to you, including a fund managed by Amber Capital and its service providers, agents and delegates including for example its administrator and/ or alternative investment manager and their respective affiliates, professional advisers such as law firms, accountancy firms and tax advisers, other service providers, including technology service providers and counterparties. These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
  • To the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights or if a regulator or tax authority has reasonably requested such information; and
  • If we sell some or all of our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

5. INTERNATIONAL TRANSFERS OF PERSONAL DATA

5.1 Amber Capital is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we transfer and store your Personal Data outside the European Economic Area (“EEA”)

5.2 Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of EEA, for example, this may be done in one of the following ways:

  • The country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
  • The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  • Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  • In other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.

6. HOW LONG WE KEEP YOUR PERSONAL DATA

6.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:

  • The purpose for which we are using it – as it will need to be kept for as long as is necessary for any of those purposes; and
  • Legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

7. YOUR RIGHTS

7.1 You have a number of legal rights in relation to the Personal Data that we hold about you, in most cases, you can exercise them free of charge. These rights include:

  • The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
  • In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Amber Capital;
  • The right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
  • The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

7.2 You can exercise your rights by contacting us using the details set out under “Questions and Concerns” below. You can find out more information about your rights by contacting an EU data regulator such as the UK’s Information Commissioner’s Officer, or by searching their website at ico.org.uk.

8. QUESTIONS AND CONCERNS

8.1 If you have any questions or concerns about Amber Capital’s handling of your Personal Data, or about this Policy, please address questions and requests to: IR@ambercapital.com.