Who We Are

MAC Asset Management Limited ("MACAM", "we", "us" or "our") is the controller of personal information described in this notice. We are based at Berkeley Suite, 35 Berkeley Square, London W1J 5BF and can be contacted at info@mac-am.co.uk.

Information We Collect

We may collect identification and contact information, professional and financial information, client-classification and due-diligence records, communications, service and transaction records, and technical information generated when you use our website. We collect information directly from you, from organisations acting on your behalf, from service providers and counterparties, and from lawful public or regulatory sources.

How and Why We Use Personal Information

We process personal information to respond to enquiries; assess, establish and manage client relationships; provide investment management and advisory services; execute and administer transactions; comply with legal and regulatory obligations, including anti-money-laundering, sanctions, tax, record-keeping and reporting requirements; manage risk and security; establish, exercise or defend legal claims; and operate and improve our business.

Depending on the circumstances, our lawful bases may include performance of a contract, compliance with a legal obligation, our legitimate interests or those of a third party, and consent where specifically requested. Where we process special-category or criminal-offence information, we do so only where an additional lawful condition applies.

Sharing Personal Information

We may share information, where necessary, with custodians, brokers, trading venues, banks, administrators, professional advisers, technology and data providers, regulators, law-enforcement authorities and other parties involved in providing or supporting our services. We require service providers to protect personal information and use it only for authorised purposes.

International Transfers

Some recipients may be located outside the United Kingdom. Where required, we use an approved transfer mechanism or another lawful safeguard designed to protect personal information. Further information about relevant safeguards is available on request.

Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including to meet legal, regulatory, accounting and reporting requirements and to establish or defend legal claims. Retention periods vary according to the type of information, the relationship and applicable obligations.

Your Rights

Subject to applicable law and exemptions, you may have rights to request access to, correction or erasure of your information; restriction of or objection to processing; and portability of certain information. Where processing is based on consent, you may withdraw that consent at any time without affecting earlier processing. These rights are not absolute.

Cookies

We may use cookies and similar technologies that are necessary for the operation and security of this website. Any non-essential cookies should be used only in accordance with the choices presented through the website’s cookie controls. You can also manage cookies through your browser settings.

Questions and Complaints

To exercise your rights or ask a question, contact info@mac-am.co.uk. You also have the right to complain to the UK Information Commissioner’s Office at ico.org.uk.

Updates

We may update this notice to reflect changes in our activities or legal obligations. Last updated: 21 August 2026.

Documents & Disclosures

• Summary of Conflicts of Interest PolicyRead Document
• UK Stewardship Code DisclosureRead Document
• Summary of Order Execution PolicyRead Document
• Capital Requirement DisclosureRead Document

Introduction

MAC Asset Management Limited ("MACAM") is authorised and regulated by the Financial Conduct Authority. This summary describes the arrangements MACAM has in place to identify and manage conflicts of interest that may arise in the course of its regulated activities.

What is a Conflict of Interest?

A conflict of interest arises when the interests of MACAM, or individuals associated with it, diverge from the interests of a client, or where the interests of two or more clients diverge. MACAM is committed to identifying and managing such conflicts fairly.

Identification of Conflicts

MACAM has identified the following potential sources of conflict:

Own account dealing: Staff may hold personal investments that conflict with client interests. MACAM operates a personal account dealing policy that restricts and monitors such activity.

Remuneration arrangements: Remuneration arrangements may create actual or potential conflicts. MACAM maintains policies and controls designed to identify and manage such risks.

Multiple client relationships: MACAM may act for clients with competing interests in the same financial instruments or markets.

Gifts and inducements: Receipt of gifts or inducements from third parties could create conflicts. MACAM maintains a gifts and inducements register and policy.

Management of Conflicts

MACAM manages conflicts of interest through the following measures:

Information barriers: Restricting the flow of information between departments where conflicts may arise.

Independent supervision: Ensuring that individuals involved in activities giving rise to potential conflicts are supervised independently.

Disclosure: Where conflicts cannot be adequately managed, MACAM will disclose the nature of the conflict to the client before proceeding.

Declining to act: In certain circumstances, MACAM may decline to act where a conflict of interest cannot be adequately managed or disclosed.

Personal Account Dealing

MACAM operates a personal account dealing policy that requires staff to obtain pre-clearance before undertaking personal transactions in securities. Staff are prohibited from dealing in advance of client orders or using confidential client information for personal benefit.

Disclosure

Where MACAM determines that the arrangements in place are not sufficient to prevent a conflict of interest from adversely affecting a client's interests, MACAM will disclose the general nature and sources of the conflict to the client prior to carrying out business on their behalf.

Review

This policy is reviewed annually and updated as required to reflect changes in the business or regulatory environment. MACAM's Compliance function is responsible for overseeing its implementation.

Last reviewed: 21 August 2026  |  FCA Reference: 752141

Statement on the UK Stewardship Code

MAC Asset Management Limited ("MACAM") is an investment manager authorised and regulated by the Financial Conduct Authority. This disclosure summarises MACAM’s approach to stewardship in respect of assets managed on behalf of clients.

Our Approach to Stewardship

MACAM recognises the importance of stewardship and the role that investment managers can play in promoting long-term value creation for clients. MACAM's primary focus is on fixed income and structured products. Given the nature of these asset classes, traditional stewardship activities such as voting at shareholder meetings are largely not applicable to the majority of MACAM's activities.

Engagement

Where MACAM invests in equity instruments, it seeks to engage with issuers on matters of governance, environmental and social responsibility where this is considered relevant to the long-term value of the investment. MACAM may engage directly with company management or through intermediaries as appropriate.

Conflicts of Interest in Stewardship

MACAM manages conflicts of interest arising in the context of stewardship activities in accordance with its Conflicts of Interest Policy. Where a potential conflict is identified, MACAM will seek to manage it through disclosure, escalation or abstention as appropriate.

Monitoring Issuers

MACAM monitors investee companies and issuers on an ongoing basis, taking into account financial performance, strategy, capital structure, risk management and, where relevant, environmental, social and governance ("ESG") factors. Monitoring activities are conducted as part of MACAM's broader investment process.

UK Stewardship Code

MACAM is not currently presented on this website as a signatory to the UK Stewardship Code. Nevertheless, the firm recognises the importance of effective stewardship and considers relevant governance, financial and sustainability factors as part of its investment process, where appropriate to the asset class and client mandate.

Last reviewed: 21 August 2026  |  FCA Reference: 752141

Introduction

MAC Asset Management Limited ("MACAM") is required under applicable FCA rules to take all sufficient steps to obtain the best possible result for its clients when executing orders. This document provides a summary of MACAM’s order-execution arrangements.

Scope

This policy applies to all orders executed by MACAM on behalf of its professional clients in financial instruments including fixed income securities, equities, structured products and other instruments.

Best Execution Factors

When executing client orders, MACAM takes into account the following factors to achieve best execution:

Price: The price at which the transaction is executed, including any commissions or fees.

Costs: All explicit costs borne by the client, including commissions, exchange fees and clearing costs.

Speed: The speed at which an order can be executed in the prevailing market conditions.

Likelihood of execution and settlement: The probability that the order will be executed at the required size and settled in a timely manner.

Size and nature: The size of the order and the nature of the financial instrument, including whether it is traded on a regulated market or OTC.

Market impact: The potential impact that executing the order may have on the market price of the instrument.

Execution Venues

MACAM operates its own trading desk, which provides a significant advantage in terms of execution quality, speed and liquidity access. MACAM maintains relationships with a range of counterparties including major investment banks, specialist brokers and electronic trading platforms. Execution venues are selected on the basis of their ability to deliver consistent best execution across relevant asset classes.

Monitoring and Review

MACAM monitors the effectiveness of its order execution arrangements on an ongoing basis and reviews this policy at least annually. Where deficiencies are identified, corrective action will be taken promptly.

Client Consent

Clients receive information regarding MACAM’s order-execution arrangements as part of the onboarding and contractual process. Any consent required under applicable rules is obtained in the appropriate form. Clients may request further information on the firm’s execution arrangements and venues used.

Last reviewed: 21 August 2026  |  FCA Reference: 752141

Introduction

MAC Asset Management Limited ("MACAM") is subject to the FCA’s Investment Firms Prudential Regime and the applicable requirements of the MIFIDPRU sourcebook. This disclosure summarises the firm’s approach to capital adequacy and prudential risk management.

Regulatory Capital

The firm assesses its prudential classification and own-funds requirements in accordance with applicable MIFIDPRU rules. Its minimum own-funds requirement is determined by the relevant permanent minimum capital requirement, fixed overhead requirement and, where applicable, K-factor requirement. The firm’s precise regulatory classification and disclosure obligations are reviewed through its compliance and prudential processes.

Capital Resources

MACAM maintains own funds designed to meet its applicable regulatory requirements and internal risk assessment. The composition and adequacy of regulatory capital are monitored as part of the firm’s prudential governance framework.

Capital Adequacy

MACAM monitors its financial resources and assesses potential harms arising from its business through its Internal Capital Adequacy and Risk Assessment ("ICARA") process, in accordance with applicable FCA requirements.

Remuneration Policy

MACAM maintains remuneration arrangements designed to support sound and effective risk management and to avoid incentives that could encourage excessive risk-taking. The firm applies the remuneration requirements relevant to its prudential classification.

Contact

For further information regarding MACAM’s prudential disclosures, please contact: info@mac-am.co.uk

Last reviewed: 21 August 2026  |  FCA Reference: 752141

Legal Information

This website is issued by MAC Asset Management Limited ("MACAM"), a company incorporated in England and Wales and authorised and regulated by the Financial Conduct Authority under reference number 752141. The investment services described on this website are intended solely for professional clients and eligible counterparties and are not directed at retail clients.

No Offer, Solicitation or Advice

The content of this website is provided for general information only. It does not constitute investment, legal, tax or accounting advice, an investment recommendation, an offer or an invitation to buy or sell any financial instrument. Nothing on this website creates a client relationship or should be relied upon as the basis for an investment decision.

Jurisdictional Restrictions

The information and services described may not be available in every jurisdiction or to every person. Users are responsible for observing applicable local laws and restrictions. MACAM does not represent that this website or its content is appropriate for use in every jurisdiction.

Past Performance

Past performance is not a reliable indicator of future results. Forecasts, targets and forward-looking statements are not guarantees. The value of investments and the income from them may fall as well as rise, and investors may lose some or all of the amount invested. Certain investments may be illiquid, difficult to value or subject to significant market, credit, currency or counterparty risk.

Accuracy of Information

Information is obtained from sources believed to be reliable, but MACAM gives no representation or warranty as to its accuracy, completeness or timeliness. Content may be changed without notice. To the fullest extent permitted by law, MACAM accepts no liability arising from reliance on this website or any interruption, error, malicious code or unauthorised access affecting it.

Third-Party Websites

Links to third-party websites are provided for convenience only. MACAM does not control or endorse those websites and is not responsible for their content, availability, security or privacy practices.

Copyright

Copyright, trademarks and other intellectual-property rights in this website and its content belong to MACAM or its licensors. Content may be viewed and printed for personal, non-commercial reference only and may not otherwise be reproduced, distributed or modified without prior written permission.

Data Protection

Information about how MACAM handles personal information and cookies is set out in our Privacy Notice.

Complaints

Professional clients may contact MACAM at info@mac-am.co.uk for information about the firm’s complaints procedure. Eligibility to refer a complaint to the Financial Ombudsman Service depends on the complainant’s status and applicable rules.

Governing Law

These notices and use of this website are governed by the laws of England and Wales. The courts of England and Wales have jurisdiction, subject to any mandatory rights available under applicable law.

Last updated: 21 August 2026.