A I M P O RT FO LI O S

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1 AIM PORTFOLIOS

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3 CONTENTS PAGE WELCOME TO BLACKFINCH 5 WHAT IS THE ALTERNATIVE INVESTMENT MARKET? 6 HOW CAN WE HELP? 7 WHAT ARE THE BENEFITS? 8 WHAT ARE THE RISKS? 9 WORKING FOR YOU 10 CHELVERTON ASSET MANAGERS 11 WHERE IS MY MONEY INVESTED? 12 WHO ARE CHELVERTON? 13 WHAT IS THE INVESTMENT PROCESS? 14 WHAT COSTS ARE INVOLVED? 15 FURTHER INFORMATION 16 HOW DO I INVEST? 17 LET US HELP 18 IMPORTANT INFORMATION 19 3

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5 WELCOME TO BLACKFINCH Blackfinch s origins reach back over 20 years, throughout which the company and our services have evolved to meet the changing needs of our clients. Throughout this evolution, we have grown alongside our clients, and their advisers, and now have approximately 500 million of assets under administration and management within our group. Blackfinch are committed to delivering sensible investment strategies that target growth and tax efficiency. Our aim is to deliver transparent products and services which offer value to investors, investing in areas and opportunities which generate attractive returns. One area in which we deliver these benefits is through our AIM Portfolios a discretionary service where investors hold shares in Alternative Investment Market (AIM) listed companies which meet the qualification requirements for Business Property Relief (BPR). This can deliver a swift two year 100% Inheritance Tax (IHT) relief for investors, whilst also enabling them to maintain control over their assets and benefit from the potential attractive investment returns from the AIM market. Furthermore, following recent regulatory changes, AIM shares are now eligible to be held in ISAs. The Blackfinch AIM Portfolios can therefore combine the attractive tax benefits of an ISA with the IHT relief from BPR. Investing in smaller companies, including those on AIM, requires a great deal of skill and expertise. This is why for this service, we have teamed up with Chelverton Asset Management, to combine our in-house knowledge and experience with a team of Investment Managers that have a long and successful history of smaller company investment. Chelverton will act as Investment Adviser to Blackfinch in respect of this service. Please contact one of the team to discuss our services in more detail, or contact your financial adviser. RICHARD COOK CHIEF EXECUTIVE 5

6 WHAT IS THE ALTERNATIVE INVESTMENT MARKET? AIM was launched over 20 years ago by the London Stock Exchange as an alternative to listing on the main stock exchange. Since then it has established itself as the leading market for smaller, fast growing companies who are looking to access capital from the public market. Today, AIM includes over 1000 companies with a combined market capitalisation of over 72billion, diversified across 40 different sectors and operating in more than 100 countries. (Source: LSE Guide to AIM 2015) BIGGER THAN YOU WOULD E XPEC T While AIM is traditionally associated with smaller companies, the composition of the market has developed and it is now home to a number of sizeable and well-known businesses. AIM is a great market for the right investment manager to generate attractive investment returns. Examples of the types of companies listed on AIM and that we will consider for your portfolio include: ASOS THE UK S LARGEST INDEPENDENT ONLINE FASHION AND BEAUTY RETAILER SELLING OVER 60,000 BRANDED AND OWN LABEL PRODUCTS. YOUNG & CO ESTABLISHED AS A BREWING COMPANY IN THE 19TH CENTURY AND NOW HAS A PUB ESTATE OF 171 MANAGED AND 80 TENANTED PUBS. MULBERRY THE RENOWNED LUXURY FASHION HANDBAGS BRAND WITH A PRESENCE ACROSS EUROPE, NORTH AMERICA AND ASIA. NICHOLS THE GROUP BEHIND VIMTO, THE FRUIT CORDIAL DRINK. NOW A MULTI- MILLION POUND AND INTERNATIONAL SOFT DRINKS COMPANY. WHO MIGHT THE SERVICE APPEAL TO? Consider an investor who has accumulated a large ISA pot after years and years of careful saving and investing. ISAs are tax-efficient during the investor s lifetime but could be storing up a potential IHT liability. For example, transferring 100k into the Blackfinch AIM Portfolios could save 40k in IHT*, whilst also retaining the benefits of the ISA. The Blackfinch AIM Portfolios can be used for growth or as an additional income stream if needed. * ignoring the impact of fees and investment performance. 6

7 HOW CAN WE HELP? The AIM market offers many attractive investment opportunities but requires a highly skilled investment manager to find the right companies whilst avoiding the potential pitfalls and risks associated with investments in smaller companies. This is why we have partnered with Chelverton Asset Management, a highly acclaimed and award winning Fund Manager, which has specialised in this area of the market and AIM stocks in particular for many years. HOW IT WORKS WHAT IS BPR? To meet the increasing demand for IHT planning solutions, Blackfinch has created the AIM Portfolios to offer a simple, yet swift solution that exempts assets from IHT after a 2 year qualifying period. It allows you to stay in control of the invested capital, whilst also offering the potential for attractive investment returns. Since 2013 AIM shares have been eligible to be held in ISAs. ISAs offer valuable benefits during an investor s lifetime but assets held within them could be subject to IHT like most other investments. This could be a concern for investors who have accumulated large amounts in ISAs after years of saving and investing. Blackfinch AIM Portfolios only invest in BPR qualifying AIM companies, which target IHT relief after 2 years. TOM DAVIES INVESTMENT MANAGER BLACKFINCH INVESTMENTS IHT is currently paid on assets and possessions upon death. The first 325,000 of your estate is exempt from IHT (referred to as the nil-rate-band) and everything beyond this amount is subject to tax at 40%. Business Property Relief (BPR) is a tax relief that was introduced by the UK government in 1976, meaning that qualifying property is exempt from IHT after 2 years. HMRC even has a generous replacement property rule which says that if someone sells an asset that qualifies for BPR, they can reinvest the proceeds of the sale in a new BPR investment within three years and qualify for BPR immediately. This is one of the most important reliefs available within the scope of IHT as it reduces the value of certain assets liable by up to 100%. Relief is available for certain investments including shares in qualifying unlisted and AIM-listed companies. BPR is now well established and has been used since its inception to assist individuals and their families to mitigate IHT liabilities. BLACKFINCH AIM PORTFOLIOS HELD OUTSIDE AN ISA INSIDE AN ISA TAX-FREE CAPITAL GAINS TAX-FREE INCOME IHT RELIEF AFTER 2 YEARS ATTRACTIVE INVESTMENT OPPORTUNITIES ACCESS TO A PROVEN INVESTMENT PROCESS INCOME AND GROWTH PORTFOLIOS AVAILABLE ACCEPT IN-SPECIE TRANSFERS 7

8 WHAT ARE THE BENEFITS? Blackfinch AIM Portfolios combine a number of benefits and our service will appeal to a variety of investors. SPEED INVESTMENT OPPORTUNITIES Traditional forms of IHT planning (such as gifts or trusts) can take up to seven years to reach full exemption. In contrast, once qualifying AIM shares have been held for two years their value will be exempt from IHT. The AIM market is home to many successful and established businesses. With the right investment manager this market offers great opportunities for attractive investment returns. CONTROL INCOME AND GROWTH PORTFOLIO OPTIONS Trust planning or gifting will often involve giving up control or restricting access to your capital, which could cause complications should your personal or tax circumstances change. With the Blackfinch AIM Portfolios you have access to your investments at all times. We offer the choice of either an Income or Growth portfolio, giving you the flexibility to choose a portfolio that best suits your investment objective. ELIGIBLE FOR ISAs EXPERTISE Our service combines the proven expertise of two established and leading investment firms. This partnership has been established specifically for this service. Since 2013 qualifying AIM-listed shares have been eligible to be held via an ISA wrapper. This means a portfolio of AIM shares held within an ISA will not only mitigate an IHT liability, but will also offer tax-free dividends and will attract no Capital Gains Tax on any investment growth. Furthermore, Stamp Duty at a rate of 0.5% is no longer charged on AIM share purchases, further improving the tax efficiency and returns of the portfolio. 8

9 WHAT ARE THE RISKS? Blackfinch want to help investors understand the risks that are involved with this type of investment. If you have any questions regarding the risks involved, please speak to one of our experienced team members who will be happy to help you. YOUR CAPITAL IS AT RISK THE ASSETS MAY BE HARD TO SELL Share prices and their values can go down as well as up. Investors capital may be at risk and investors may get back less than their original investment. An investment in smaller companies should be deemed higher risk than other investments. TAX RELIEFS MAY CHANGE The tax reliefs referred to are not guaranteed and may be subject to change at short notice. Tax treatment will also depend on your individual financial situation. TAXATION RULES MAY CHANGE Any changes to the taxation environment or HMRC practice may affect investment returns. Accordingly, you will have your own tax position to consider and must take your own independent professional advice in this matter. You may be liable to make tax payments on any amounts you withdraw from the investment. AIM stocks can be small and illiquid and it may prove difficult for investors to realise immediately or in full, the proceeds from the sale of such shares. BPR ASSESSMENT OF A COMPANY MAY CHANGE We will invest in companies which we reasonably believe qualify for BPR, but we can give no commitment that any such investment will remain a qualifying investment at all times in the future. The relief is assessed by HMRC on a case-by-case basis at the time of death of the investor, as part of the probate process, and therefore cannot be guaranteed. The proportion of the investment that is deemed to qualify at that time, assuming it has been held for at least two years and is still held at time of death, can be passed to beneficiaries free of IHT. The two-year timeframe begins when HMRC deems the investment has become BPR qualifying, which may be later than the investment date. 9

10 WORKING FOR YOU Our Investment Team consists of senior management at Blackfinch who are responsible for the review and approval of all underlying investment opportunities that are considered for our AIM Portfolios. Each member of our team has a wealth of industry expertise within the specific asreas in which we invest. Below are some of our Investment Team. RICHARD COOK Chief Executive Richard has been Chief Executive since 2009 and has been involved in the structuring and management of tax-efficient investment assets for over 11 years. He has overseen the growth and expansion of the company within the UK retail market and has evolved the company to where it is today. Previously, Richard has worked in senior banking roles within Merrill Lynch and the Bank of New York. RICHARD SIMMONDS Chief Investment Officer Richard has 12 years senior experience in financial services, specialising in asset-backed fund management. Richard has extensive project, corporate finance and fund management experience across multiple asset classes such as property, renewable energy, asset-backed lending and capital protected insurance investments. Richard holds a Masters Degree from the London School of Economics, the Certificate in Discretionary Investment Management and the Diploma in Financial Planning. TOM DAVIES Investment Manager Tom has a decade of fund management experience. He joined Blackfinch from Wesleyan Assurance Society, where he managed a number of investment funds. Before that he worked at Investec Wealth & Investment where he managed tax efficient investments, including AIM portfolios for high net worth individuals. Tom is a CFA charterholder. 10

11 DAVID HORNER Managing Director David is an acclaimed fund manager, specialising in small and mid-cap quoted investment and SME unquoted investment. With more than 30 years experience in corporate finance assignments, identifying, structuring and managing investments as well as purchasing and managing private equity, specialist listed and AIM portfolios. Qualified as a chartered accountant with Deloittes and has held senior positions in 3i Corporate Finance and Strand Partners, with numerous public and private company directorships. In 1998, David set up Chelverton Asset Management to provide the investment management for Chelverton Growth Trust PLC, and was responsible for launching, in 1999, Small Companies Dividend Trust PLC; both funds he still manages. He has co-managed MI Chelverton UK Equity Income Fund since its launch, the success of which consistently earns him a Citywire AAA fund manager rating. DAVID TAYLOR Fund Manager David is an award winning fund manager, with specialist expertise investing in companies with sub- 1bn market capitalisations. He began his career as an analyst in the research department at Wedd Durlacher, moving into fund management in 1987 with the Merchant Navy Officers Pension Fund. He joined Gartmore Investment Limited in 1991, where he ran a combination of institutional funds and investment trusts. In 1995, he moved to LGT to manage small-cap retail funds and latterly spent nearly seven years as head of UK smaller companies at HSBC Asset Management. David joined Chelverton Asset Management in January 2006 and has co-managed MI Chelverton UK Equity Income Fund and MI Chelverton UK Equity Growth since launch. He also co-manages Small Companies Dividend Trust PLC and his work on MI Chelverton UK Equity Income Fund consistently earns him a AAA Citywire Fund Manager rating. JAMES BAKER Fund Manager James joined Chelverton Asset Management in June 2014 to manage MI Chelverton UK Equity Growth Fund. A history graduate from Cambridge University, he has over 30 years of equity market experience on both buy and sell sides, specialising for all of his career in UK small and mid-cap stock selection. He has worked for several organisations over the years, but most notably spent from 1999 to 2011 as part of the ABN Amro, small mid cap sales team, which was consistently top ranked by Extel. Prior to joining Chelverton he worked as the assistant fund manager on the Rathbone UK Recovery Fund. EDWARD BOOTH Assistant Fund Manager Edward joined Chelverton Asset Management in 2016 as an Assistant Fund Manager. Having graduated from the London School of Economics with a degree in Economics with Economic History, Edward qualified as a Chartered Accountant at Deloitte, where he focused on the Insurance sector. Prior to joining Chelverton, he worked as a Business Analyst for Barclays, focusing on a number of areas including Investment Bank Revenue and Group Capital performance. 11

12 WHERE IS MY MONEY INVESTED? The Blackfinch AIM Portfolios is a discretionary investment management service. Whilst this means that Blackfinch will make investment decisions on your behalf, you will retain beneficial ownership of all the investments within your investment portfolio. Your portfolio will typically consist of AIM listed companies which have been carefully selected by the experts at Blackfinch and Chelverton Asset Management (more on the proven and rigorous investment process later on). Investors have the choice between an Income or Growth portfolio. These portfolio options will differ in both the selection of underlying investee companies and the treatment of any dividends received into your account. BLACKFINCH AIM FOR INCOME The Income portfolio will have a bias to companies with attractive dividend yields. Dividends received can be paid out on a quarterly basis or investors may elect to draw a defined income from the portfolio. A small cash float will be retained to meet the cost of the service. The Blackfinch AIM Portfolios bring together the expertise of two highly specialist investment management teams. The structure and responsibilities of both Blackfinch and Chelverton are outlined below: Blackfinch will act as a Discretionary Investment Manager, responsible for the day to day management of investor portfolios. This will include making the final investment decisions, allocating stock to individual client accounts and client administration. Blackfinch will also be the main point of contact for you and your financial adviser. Chelverton acts as Investment Adviser to Blackfinch and we will use their expertise and disciplined investment process to construct a portfolio of AIM listed companies. BLACKFINCH AIM FOR GROWTH The Growth portfolio will be designed to focus on the preservation and modest growth of your capital. The dividends received from this portfolio of stocks are likely to be fairly small. Any dividends received will either be retained in your account to meet the ongoing costs of the service or will be reinvested into the portfolio. Your portfolio will be diversified by investment sector and we will ensure that you are not overly exposed to any one company or industry. RICHARD SIMMONDS CHIEF INVESTMENT OFFICER BLACKFINCH INVESTMENTS PORTFOLIO INCOME GROWTH CAN BE HELD IN AN ISA IHT RELIEF AFTER 2 YEARS OPPORTUNITIES FOR ATTRACTIVE INVESTMENT RETURNS ACCESS TO A PROVEN INVESTMENT PROCESS 12

13 WHO ARE CHELVERTON? Founded in 1998, Chelverton are a specialist investor in sub-ftse 100 quoted equities and unquoted small and medium-sized enterprises, with an investment approach based on fundamental value, cash generation and dividends / loan interest. Chelverton s expertise in the mid and small-cap areas of the market makes them ideal partners for the Blackfinch AIM Portfolios. THEIR EXPERIENCE The experienced Fund Management Team manages over 500m across four Open Ended Investment Company funds and Investment Trusts, including the award winning MI Chelverton UK Equity Income Fund. The fund range contains both growth and income orientated mandates, and Chelverton s expertise in both of these areas will be applied to both the growth and income portfolio options offered by the Blackfinch AIM Portfolios. Chelverton s performance record proves that the application of a rigorous investment discipline, combined with patience and a long-term outlook, can produce outstanding returns for investors. Indeed, this performance has led to a number of industry accolades and awards. David Horner and David Taylor, are AAA rated by Citywire for their 3 year risk adjusted performance for the period 30/04/ /04/

14 WHAT IS THE INVESTMENT PROCESS? All Chelverton managed funds share the same quantitative screening process which has been designed to identify certain characteristics, or put another way, the companies have to pass important tests before they are looked at in any detail. These include filtering for companies that are highly cash generative, which enables them to fund their own growth and/or distribute cash to shareholders. BPR qualification is a key criteria our investee companies must meet. To be confident your investments qualify for BPR we will be in close contact with the senior management at each company and we will seek independent advice to support this. THE STAGES Typically, these companies will have some form of sustainable competitive advantage, such as a unique product or dominant position in a particular market leading to high margins. The balance sheet is also tested to ensure that debt is not too burdensome and that the amount of working capital is not too high. These first stage tests will identify those companies that qualify for further assessment. The second stage is all about gaining a better understanding of the company beyond these basic statistics. Chelverton start by looking at sales, to what extent they are repeatable, and how broad the customer base is. Margins are then looked at to examine how likely it is that they are sustainable. Finally, Chelverton favour sensible, pragmatic management teams who share a long-term vision of what the company can reasonably achieve and who act in the best interests of shareholders. A summary of this proven process is shown below: STAGE ONE STAGE TWO STAGE THREE INITIAL TESTS A MORE THOROUGH ANALYSIS FINAL CHECKS CASH FLOW Attractive cash flow PREDICTABILITY OF SALES Recurring revenues Customer concentration FINALLY, ARE THE SHARES ATTRACTIVELY VALUED? GROWTH Good revenue growth BALANCE SHEET Not too much debt MARGINS High and preferably industry-leading margins SUSTAINABILITY OF MARGINS Competitive advantage Funding own growth MANAGEMENT Consistency of strategy and message Capital allocation ON COMPLETION OF CHELVERTON S PROCESS A RECOMMENDED LIST OF SUITABLE SECURITIES WILL BE MADE TO THE INVESTMENT COMMITTEE AT BLACKFINCH. THIS COMMITTEE WILL THEN MAKE THE FINAL INVESTMENT DECISIONS AND COMPLETE THE CONSTRUCTION OF YOUR INVESTMENT PORTFOLIO. SELF FUNDING Simple businesses with sensible financing 14

15 WHAT COSTS ARE INVOLVED? The charges for the Blackfinch AIM Portfolios are outlined below. Please note we only accept investments via authorised advisers and will not accept applications directly from investors. NO INITIAL FEE ANNUAL MANAGEMENT FEE DEALING FEE 0% ENTRY FEE FOR ALL APPLICATIONS WE WILL CHARGE AN ANNUAL MANAGEMENT FEE OF 1.5% OF THE PORTFOLIO VALUE PLUS VAT. WE WILL PAY THE INVESTMENT ADVISER FROM THIS AMOUNT A DEALING FEE OF UP TO 1% OF THE CONSIDERATION PLUS FIXED SETTLEMENT COSTS WILL APPLY WHAT IS THE MINIMUM INVESTMENT? The minimum subscription for the Blackfinch AIM Portfolios is 15,000. This is also the minimum for any additions to your portfolio. HOW WILL I BE KEPT INFORMED? We will send you a formal valuation of your portfolio every six months. You will also receive a contract note for every transaction undertaken. After each tax year end, you will also be sent a consolidated tax voucher listing all dividends, interest and related tax credits received on your behalf. WHERE WILL MY INVESTMENTS BE HELD? We have appointed Jarvis Investment Management Limited as custodian for the Service. Accordingly, the Application Form includes an agreement for you to appoint Jarvis to take on this role. Jarvis is authorised and regulated by the FCA to hold your cash and securities and all your investments will be held within their nominee service. Additional Custody and Settlement charges will apply. Please speak to your adviser or see our rate card included in the Application Form for further details. HOW MUCH WILL MY ADVISER BE PAID? At your request, we can facilitate any upfront or ongoing advice fees that you have agreed with your FCA authorised adviser. Upfront advice fees are deducted from the amount invested, whereas ongoing advice fees are deducted from your portfolio every 3 months and then paid to your adviser. Ongoing fees will reduce your net return. PLEASE SPEAK TO YOUR ADVISER OR SEE OUR RATE CARD INCLUDED IN THE APPLICATION FORM FOR FURTHER DETAILS. 15

16 FURTHER INFORMATION CAN I MAKE IN SPECIE TRANSFERS OF EXISTING PORTFOLIOS INTO THE BLACKFINCH AIM PORTFOLIOS? Yes, we can accept in specie transfers of existing portfolios. Shortly after receiving any assets, we will undertake a review to assess BPR eligibility and compliance with our stock selection criteria. Any sales will then be made and the proceeds invested into our chosen stocks. A Stock Transfer Form is included in the Application Pack. CAN I MAKE WITHDRAWALS FROM MY PORTFOLIO? Yes. The minimum amount for withdrawals is 5,000. Due to the illiquidity of some AIM stocks any necessary sales may take a few weeks to complete. Under normal market conditions we would expect these to be completed within 2 weeks. WILL I HAVE TO PAY TAX ON WITHDRAWALS? For any assets held outside ISAs, tax may be payable on both income and capital gains. Income Tax, regardless of whether the income is distributed, will be charged at the prevailing rate and Capital Gains Tax will be charged on any gains in excess of your annual exemption (net of accumulated capital losses). WHAT HAPPENS WHEN I DIE? Provided the portfolio has been invested in qualifying companies for at least two years, the prevailing market value will be exempt from your estate for IHT purposes. After your death, a claim will be made by your executors to confirm eligibility for BPR. At this point, they may instruct us to sell the assets or to continue managing your portfolio on behalf of your beneficiaries. Should an investor die within two years of ownership, the portfolio can be transferred to a surviving spouse or civil partner without restarting the qualifying period. 16

17 HOW DO I INVEST? Here is a simple diagram to show how investing in the Blackfinch AIM Portfolios works. If you have any questions, please speak to your financial adviser or call us on APPLICATION PROCESS 1 SEND YOUR COMPLETED APPLICATION FORM AND INVESTMENT CHEQUE TO BLACKFINCH. Please make cheques payable to Blackfinch Investments Ltd. We will acknowledge receipt of your application within 48 hours. 2 BLACKFINCH WILL PROCESS YOUR APPLICATION FORM AND PLACE YOUR MONEY INTO A CLIENT BANK ACCOUNT. Please note that no interest is paid on this account. The client account will be managed in line with FCA rules. 3 WHEN THE CHEQUE HAS CLEARED, BLACKFINCH WILL INVEST YOUR MONEY INTO A PORTFOLIO OF AIM SHARES WHICH WILL BE HELD BY A NOMINEE COMPANY ON YOUR BEHALF. Any in specie transfer will be assessed. Initial fees and any agreed upfront adviser fees are deducted prior to deploying your capital into selected investments. We start investing your funds as soon as possible. However, due to the inherent illquidity of your AIM shares, the full investment process can often take several weeks. You will receive contract notes for each purchase made. 17

18 LET US HELP At Blackfinch our goal is to deliver a service to advisers and their clients which is second to none. We offer a range of support and our team is always on hand to assist you. Product training Presentations Technical support Case studies Illustrations PLEASE CONTACT US AND TELL US HOW WE CAN HELP. T E SUPPORT@BLACKFINCH.COM 18

19 IMPORTANT INFORMATION This Brochure is being issued by Blackfinch Investments Limited, which is authorised and regulated by the Financial Conduct Authority ( FCA ) (FCA number: ). Registered Address: Blackfinch House, Chequers Close, Malvern, Worcestershire, WR14 1GP. Any decision to invest in this service should be made on the basis of the information contained in this Brochure, and the terms and conditions. Prospective Investors must rely on their own examination of the legal, taxation, financial and other consequences of investing and the risk involved. Prospective Investors should not treat the contents of this Brochure as advice relating to legal, taxation or other matters and, if in any doubt about the proposal discussed in this brochure, its suitability, or what action should be taken, should consult their own advisers. Whilst Blackfinch Investments Limited has taken all reasonable care to ensure that all the facts stated in this Brochure are true and accurate in all material respects, and that there are no other material facts or opinions which have been omitted where the omission of such would render this Brochure misleading, no representation or warranty, express or implied, is given as to the accuracy or completeness of the information or opinions contained in this Brochure and no liability is accepted by Blackfinch Investments Limited, or any of their directors, members, officers, employers, agents or advisers, for any such information or opinions. All statements of opinion and/or belief contained in this Brochure and all views expressed and all projections, forecasts or statements relating to expectations regarding future events represent Blackfinch Investments Limited s own assessment and interpretation of information available as at the date of this Brochure (December 2016). This Brochure does not constitute, and may not be used for the purposes of, an offer or invitation to treat by any person in any jurisdiction outside the United Kingdom. This Brochure and the information contained in it are not for publication or distribution to persons outside the United Kingdom. It does not constitute a public offering in the United Kingdom. The Blackfinch AIM Portfolios may not be suitable for all investors and we would recommend that prospective investors seek independent advice before making a decision. 19

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