Simplified Prospectus

Transcription

1 Simplified Prospectus (Incorporating the ISA Terms & Conditions) Elite CAM Discretionary Portfolios Valid as at 1 st April 2016

2 Helping you decide What you should know before you invest This document gives you a summary of information to help you decide if you want to invest in Elite CAM Discretionary Portfolios and provides answers to some important questions. You should read this document carefully so that you understand what you are buying, and keep it safe for future reference. Because we are not registered with the relevant authorities in the United States we cannot sell Shares to people who are "US persons". If you think you may be a US person please see further details in the Prospectus, including a definition of what a US person is or call us on The Financial Conduct Authority (FCA) is the UK s independent financial services regulator. It requires us, WAY Fund Managers Limited, to give you this important information to help you decide whether our fund is right for you. This Simplified Prospectus contains key information in relation to Elite CAM Discretionary Portfolios (the Company ) which is an open-ended investment company with variable capital incorporated in England and Wales on 9 th August 2010 with registered number IC The Company is classified as a Non-UCITS Retail Scheme (NURS) under the rules of the Financial Conduct Authority ( FCA ). Investing The How Company do I buy/sell is structured my investment? as an umbrella company, in that different Funds may be established from time to time When and how? by the authorised corporate director with the approval of the Our FCA. administration The Company office currently deals has with two requests sub-funds for as follows: purchase and sale of shares, converting and switching, between 9am and 5pm on dealing days. Elite CAM Balanced Discretionary Portfolio; and You must fill in an application form and send it to us Elite CAM Cautious Discretionary Portfolio The assets of each Fund will be treated as separate from those of every other Fund and will be invested in accordance with the investment objective and investment policy applicable to that Fund. Potential investors are advised to read the full Prospectus (the Prospectus ) before making an investment decision. The rights and duties of investors as well as their legal relationship with the Company are laid down in the Prospectus.

3 The Company and its Head Office Elite CAM Discretionary Portfolios, Cedar House, 3 Cedar Park, Cobham Road, Wimborne, Dorset BH21 7SB. Authorised and regulated by the Financial Conduct Authority. WAY Fund Managers Limited and can be contacted at the address of the ACD below. Telephone: Sponsor City Asset Management Plc, New City Cloisters, 196 Old Street, London EC1V 9FR. Authorised and regulated by the Financial Conduct Authority. Authorised Corporate Director ( ACD ) WAY Fund Managers Limited, Cedar House, 3 Cedar Park, Cobham Road, Wimborne, Dorset BH21 7SB. Authorised and regulated by the Financial Conduct Authority and a member of the Investment Association ( IA ). WAY Fund Managers Limited is a subsidiary of Professional Partners Administration Limited ( PPAL ). Investment Adviser City Asset Management Plc, New City Cloisters, 196 Old Street, London EC1V 9FR. Authorised and regulated by the Financial Conduct Authority. Depositary Northern Trust Global Services Limited, 50 Bank Street, London, E14 5NT. Authorised and regulated by the Prudential Regulation Authority and the Financial Conduct Authority. Fund Accountant Apex Fund Services (UK) Limited, Veritas House, 125 Finsbury Pavement, London, EC2A 1NQ. Authorised and regulated by the Financial Conduct Authority. Administrator and Registrar: WAY Fund Managers, Cedar House, 3 Cedar Park, Cobham Road, Wimborne, Dorset, BH21 7SB. Authorised and regulated by the Financial Conduct Authority. Telephone: Facsimile: Auditor Deloitte LLP, Saltire Court, 20 Castle Terrace, Edinburgh EH1 2DB. Authorised and regulated by the Financial Conduct Authority. Competent Authority The Company is authorised and regulated by the Financial Conduct Authority. They can be contacted at 25 The North Colonnade, Canary Wharf, London E14 5HS or by calling (local call rates). Website

4 COMPANY INFORMATION Elite CAM Discretionary Portfolios What is the profile of the typical investor the Funds are designed for? The ACD considers that the Funds are suitable for investors seeking a medium to long term investment. It is anticipated that retail investors will typically invest in Class A shares and institutional investors will typically invest in Class B and Class C shares. All investors in the Company should understand and appreciate the risks associated with investing in shares in the Company, and must be able to accept losses. The ACD recommends that investors seek suitable advice from an authorised independent intermediary before investing in shares. Investors should also note the risk factors in the section below. What are the Funds general risk factors? We recommend that you contact a financial adviser if you are in any doubt about the suitability of an investment in any Fund, or if you are not confident that you fully understand the risks involved. Market risk - The investments of the Funds are subject to normal market fluctuations and other risks inherent in investing in securities. There can be no assurance that any appreciation in the value of investments will occur. The value of investments and the income derived from them may fall as well as rise and investors may not recoup the original amount they invest in the Funds. There is no certainty that the investment objective of any Fund will actually be achieved and no warranty or representation is given to this effect. performance is no guide to the future. Past Dilution levy - Investors should note that in certain circumstances a dilution levy may be applied to the price payable on the purchase or redemption of their shares. Where dilution levy is not applied the Fund in question may incur dilution which may constrain capital growth. concerned but may constrain capital growth. Currently both Funds of the Company charge expenses against capital. Suspension of dealings in shares - Investors are reminded that in certain circumstances their right to redeem shares (including a redemption by way of switching) may be suspended. Pricing and liquidity - Where a Fund has exposure to alternative asset classes there is a risk that the price at which an asset is valued may not be realisable in the event of sale. This could be due to a mis-estimation of the asset s value or due to a lack of liquidity in the relevant market. As a result, at times, the ACD may have to delay acting on instructions to sell investments, and the proceeds on redemption may be materially less than the value implied by the Fund s price. Liabilities of the Company - Under the OEIC Regulations, each Fund is a segregated portfolio of assets and those assets can only be used to meet the liabilities of, or claims against, that Fund. Whilst the provisions of the OEIC Regulations provide for segregated liability between Funds, the concept of segregated liability is relatively new. Accordingly, where claims are brought by local creditors in foreign courts or under foreign law contracts, it is not yet known whether a foreign court would give effect to the segregated liability and crossinvestment provisions contained in the OEIC Regulations. Therefore, it is not possible to be certain that the assets of a Fund will always be completely insulated from the liabilities of another Fund of the Company in every circumstance. Professional Liabilities Risks - As the Company is an 'Alternative Investment Fund' for the purposes of the Alternative Investment Fund Managers Directive ( AIFMD ), the ACD is required to ensure that certain Professional Liability Risks are covered at all times, either through additional own funds and/or through appropriate coverage of professional indemnity insurance. The ACD satisfies its obligations to cover Professional Liability Risks in relation to the Company by: (a) holding professional indemnity insurance (in accordance with the Regulations) and maintaining an amount of own funds to meet the capital requirements under the AIFMD; and (b) complying with the qualitative requirements in the AIFMD that address professional liability risks. Charges to Capital - Where the investment objective of a Fund is to treat the generation of income as a higher priority than capital growth, or the generation of income and capital growth have equal priority, all or part of the ACD s fee and other expenses may be charged against capital instead of against income. This treatment of the ACD s fee and other expenses will increase the amount of income (which may be taxable) available for distribution to Shareholders in the Fund Currency exchange rates - Currency fluctuations may adversely affect the value of a Fund s investments and, depending on an investor s currency of reference, currency fluctuations may adversely affect the value of his investment in shares. Emerging markets - Investments in emerging markets may be more volatile than investments in more developed markets. Some of these markets may have relatively 4

5 unstable governments, economies based on only a few industries and securities markets that trade only a limited number of securities. Many emerging markets do not have well developed regulatory systems and disclosure standards may be less stringent than those of developed markets. The risks of expropriation, nationalisation and social, political and economic instability are greater in emerging markets than in more developed markets. The following is a brief summary of some of the more common risks associated with emerging markets investment: Fraudulent securities Given the lack of a regulatory structure it is possible that securities in which investments are made may be found to be fraudulent. As a result, it is possible that loss may be suffered. Lack of liquidity The accumulation and disposal of holdings may be more expensive, time consuming and generally more difficult than in more developed markets. Also, due to the lack of liquidity, volatility may be higher. Many emerging markets are small, have low trading volumes, low liquidity and significant price volatility. Currency fluctuations Where a Fund makes investments, which are denominated in a currency other than the base currency of that Fund, there may be a significant change in the relative value of the investments currency against the base currency. These changes may impact the total return of the Fund to a significant degree. In respect of currencies of certain emerging countries, it is not possible to undertake currency hedging techniques. Settlement and custody risks - Settlement and custody systems in emerging markets are not as well developed as those in developed markets. Standards may not be as high and supervisory and regulatory authorities not as sophisticated. As a result there may be risks that settlement may be delayed and that cash or securities could be disadvantaged. Investment and remittance restrictions - In some cases, emerging markets may restrict the access of foreign investors to securities. As a result, certain equity securities may not always be available to a Fund because the maximum permitted number of or investment by foreign shareholders has been reached. In addition, the outward remittance by foreign investors of their share of net profits, capital and dividends may be restricted or require governmental approval. The Company will only invest in markets in which it believes these restrictions to be acceptable. However, there can be no guarantee that additional restrictions will not be imposed. Accounting Accounting, auditing and financial reporting standards, practices and disclosure requirements applicable to companies in emerging markets differ from those applicable in more developed markets in respect of the nature, quality and timeliness of the information disclosed to investors and, accordingly, investment possibilities may be difficult to properly assess. Smaller companies The Funds can invest in transferable securities relating to smaller companies which, as a result of inadequate trading volume or restrictions on trading, may be less liquid than the securities of larger companies. Securities in smaller companies may possess greater potential for capital appreciation, but also involve risks, such as limited product lines, markets and financial or managerial resources and trading in such securities may be subject to more abrupt price movements than trading in the securities of larger companies. Sub investment grade bonds - The Funds may hold subinvestment grade bonds. Such bonds have a lower credit rating than investment grade bonds and carry a higher degree of risk. Overseas bonds and currencies - From time to time, a Fund may invest in overseas bonds and currencies. These markets may respond to different influences to those that affect other underlying assets and accordingly carry a higher degree of risk. Performance risk - There will be a variation in performance between funds with similar objectives due to the different assets selected. The degree of investment risk depends on the risk profile of the fund chosen. Inflation Risk - Inflation will, over time, reduce the value of your investments in real terms. Counterparty Risk - If a Fund enters into a derivative contract it will be exposed to the credit of the other party (usually referred to as counterparty ) and their ability to wholly or partly satisfy the terms of the contract. In the event of a bankruptcy or insolvency of a counterparty, a Fund could experience delays in liquidating the position and may incur significant losses. The ACD may use one or more counterparties to undertake derivative transactions on behalf of a Fund and may be required to pledge a Fund s assets as collateral against these transactions. There may be a risk that a counterparty will be unable to meet its obligations with regards to the return of the collateral and may not meet other payments due to a Fund. Derivatives and Volatility Derivative instruments may be used in the Funds for the purposes of Efficient Portfolio Management (EPM). The use of derivatives for EPM should not lead to an increase in risk to the Fund. 5

6 Leverage - Leverage of the Company s assets is limited to the permanent borrowing referred to in the Borrowing and Leverage section of Schedule 1 (Investment and Borrowing Powers) in the Prospectus. Further details of the investment risks may be found in the Prospectus. FUND INFORMATION Elite CAM Balanced Discretionary Portfolio What is the Fund s investment objective and policy? Aims of the Fund The investment objective of the Fund is to provide a total return with an emphasis on providing capital appreciation over the investment period of 3 years. Capital invested in the Fund is at risk and there is no guarantee that the investment objective will be met over the 3 year investment period or in respect of any other period. How the Aims are Achieved Investments will be made on a multi-asset basis through a portfolio of transferable securities (including investment trusts), collective investment schemes, deposits, money market instruments and derivatives. Subject to the requirements of the Regulations, the portfolio will normally remain fully invested. There will, however, be no restrictions on the underlying content of the investments held, in terms of investment type, geographical or economic sector, other than those imposed by the Regulations. This means that the Investment Adviser has the absolute discretion to weight the portfolio towards any investment type or sector, including cash, at any time provided such investment is compatible with the investment objective and policy of the Fund as a whole. Unregulated collective investment schemes may be used to the fullest extent permitted by the Regulations. The portfolio will be actively managed. The Fund may invest in derivatives and forward transactions for investment purposes as well as for efficient portfolio management purposes (including hedging). Elite CAM Cautious Discretionary Portfolio What is the Fund s investment objective and policy? Aims of the Fund The investment objective of the Fund is to provide a real return* throughout the prevailing economic cycle. How the Aims are Achieved Investments will be made on a multi-asset basis, whilst focusing on capital preservation and the limiting volatility, through a portfolio of transferable securities (including investment trusts), collective investment schemes, deposits, money market instruments and derivatives. Subject to the requirements of the Regulations, the portfolio will normally remain fully invested. There will, however, be no restrictions on the underlying content of the investments held, in terms of investment type, geographical or economic sector, other than those imposed by the Regulations. This means that the Investment Adviser has the absolute discretion to weight the portfolio towards any investment type or sector, including cash, at any time provided such investment is compatible with the investment objective and policy of the Fund as a whole. Unregulated collective investment schemes may be used to the fullest extent permitted by the Regulations. The portfolio will be actively managed. The Fund may invest in derivatives and forward transactions for investment purposes as well as for efficient portfolio management purposes (including hedging). *"Real return" is the return over and above the prevailing rate of inflation as measured in the UK being the Consumer Price Index (the "CPI" the measure adopted by the Government for its UK inflation target). Inflation is the percentage change in the index compared with the same month one year previously. The natural fluctuations of the economy between periods of expansion (growth) and contraction (recession). What specific risk factors affect the Funds? Specific risks relating to these Funds are as follows: Non-UCITS Retail Schemes (NURS) The Company and the Fund is classed as a NURS for the purposes of the rules in the FCA Handbook. Such funds can have wider investment and borrowing powers than UCITS schemes with higher investment limits in various areas. They can also invest to a greater extent in areas such as property and unregulated schemes and have the option to borrow on a permanent basis. Such additional powers can increase potential reward, but may also increase risk. Past performance is not a guide to the future. The value of shares and the income derived from them can go down as well as up and as a result the investor may not get back the amount originally invested. This can be as a result of market movements and also of variations in the exchange rates between currencies. 6

7 The capital value and the income from shares issued by the Fund can fluctuate and the price of shares and the income from them can go down as well as up and are not guaranteed. The charges and expenses attributable to the Funds may be treated as a capital expense in accordance with the Regulations, which may have the effect of eroding capital or constraining capital growth; In certain circumstances, for the purpose of efficient portfolio management including hedging, the Fund may enter into certain derivatives transactions, including, without limitation, forward transactions, futures and options. The value of these investments may fluctuate significantly. By holding these types of investments there is a risk of capital depreciation in relation to certain Fund assets. There is also the potential for capital appreciation of such assets. The ACD does not anticipate that the use of derivatives in this way will change or alter the overall risk profiles of the Fund; Derivatives may also be used by the Fund for investment purposes in order to achieve the investment objective of the relevant sub-fund and the net asset value of the Funds may therefore, at times, be volatile. However, owing to the portfolio composition or portfolio management techniques used, it is not intended that the use of derivatives in this way will have a significant effect on the risk profile of the sub-funds and the sub-funds will not be subject to significant volatility when compared with the general market volatility of the markets of the underlying investments; The sub-funds may invest in unregulated collective investment schemes (including hedge funds). Investment in unregulated collective investment schemes carries additional risks as these schemes may not be under the regulation of a competent regulatory authority, may use leverage techniques and may carry increased liquidity risk as units/shares in such schemes may not be readily realisable. The ACD s Initial Charge is deducted from an investment at the outset and various other charges accrue daily, therefore an equivalent rise in the value of the shares is required before the original investment can be recovered. Investment in the Fund should be regarded as longterm, which is upwards of three to five years. There can be no guarantee that the objectives of the subfunds will be achieved. Exemptions, thresholds and rates of tax may change in the future. For complete details of the investment risks, please refer to the full Prospectus for the Elite CAM Discretionary Portfolios. What limits apply to investing in the Funds? Fund Share Class Minimum Initial Investment Minimum Subsequent Investment Minimum Holding Minimum Redemption Regular Savings Facility* Regular Withdrawal Facility Class A Accumulation & Income Shares 1,000 1,000 1,000 1,000 Yes, minimum of 100 per month No All Funds Class B Accumulation and Income Shares Class C Accumulation and Income Shares 50,000 50,000 50,000 50,000 No No 1,000 1,000 1,000 1,000 No No *Collection date for the Regular Savings Plan is the first business day of each month. 7

8 How do I buy/sell my investment? General The dealing office of the Administrator is normally open from 9am to 5pm (UK time) on each Dealing Day to receive requests by post or fax on for the purchase, sale and switching of shares. Requests to deal in shares may also be made by telephone on on each Dealing Day (at the ACD s discretion) between 9am and 5pm (UK time) directly to the office of the Administrator. The initial purchase must, at the discretion of the Administrator, be accompanied by an application form. Buying shares Shares may be bought directly from the ACD or through a professional adviser or other intermediary. Where permitted by the rules in the FCA Handbook, an intermediary who recommends an investment in the Company to Shareholders may be entitled to receive commission from the ACD, which may include ongoing commission based on the value of shares held by a Shareholder. For details of dealing charges see the Prospectus for further details. Application forms may be obtained from the ACD. Investors wishing to purchase Gross Shares, where available, must complete a Declaration of Eligibility and Undertaking, which may be obtained from the ACD. Valid applications to purchase shares in a Fund received before 12pm on any business day (the Valuation Point ) will be processed at the share price calculated, based on the Net Asset Value per share of that Fund, at the next Valuation Point following receipt of the application, except in the case where dealing in shares of a Fund has been suspended. denomination share is equivalent to one thousandth of a larger denomination share. Applicants who have received advice may have the right to cancel their application to buy shares at any time during the 14 days after the date on which they receive a cancellation notice from the ACD. If an applicant decides to cancel the contract, and the value of the investment has fallen at the time the ACD receives the completed cancellation notice, they will not receive a full refund as an amount equal to any fall in value will be deducted from the sum originally invested. Investors who invest through the Regular Savings Plan will be entitled to receive back the full amount they invested if they cancel. The ACD may extend cancellation rights to other investors but is under no obligation to do so. A confirmation giving details of the number and price of shares bought will be issued no later than the end of the business day following the later of receipt of the application to buy shares and the Valuation Point by reference to which the price is determined, together with, where appropriate, a notice of the applicant s right to cancel. Settlement, in cleared funds, is due within four business days of the Valuation Point. An order for the purchase of shares will only be deemed to have been accepted by the ACD once it is in receipt of cleared funds for the application. If settlement is not made within a reasonable period, then the ACD has the right to cancel any shares issued in respect of the application. Share certificates will not be issued in respect of shares. Ownership of shares will be evidenced by an entry on the Register. Statements in respect of periodic distributions on shares will show the number of shares held by the recipient. The ACD, at its discretion, has the right to cancel a purchase deal if settlement is materially overdue and any loss arising on such cancellation shall be the liability of the applicant. For postal applications payment in full must accompany the instruction. At the ACD s discretion, payment for large purchases of shares may be made by telegraphic transfer. A purchase of shares in writing or by telephone or any other communication media made available is a legally binding contract. Applications to purchase once made are, except in the case where cancellation rights are applied, irrevocable. However, subject to its obligations under the Regulations, the ACD has the right to reject, on reasonable grounds relating to the circumstances of the applicant, any application for shares in whole or part and in this event the ACD will return any money sent, or the balance of such monies, at the risk of the applicant. Any subscription monies remaining after a whole number of shares have been issued will not be returned to the applicant. Instead, smaller denomination shares will be issued. A smaller The Company has the power to issue bearer shares but there are no present plans to do so. Selling Shares Investors are entitled on any Dealing Day to redeem their shares. Valid instructions to the ACD to redeem shares in a Fund received before 12pm on any business day (the Valuation Point ) will be processed at the share price calculated, based on the Net Asset Value per share of that Fund, at the next Valuation Point following receipt of the redemption instruction, except in the case where dealing in shares of that Fund has been suspended. A redemption instruction in respect of shares in writing or by telephone or any other communication media made available is a legally binding contract. However, an instruction to the ACD to redeem shares, although irrevocable, may not be settled by either the Company or the ACD if the redemption represents shares where the money due in respect of an earlier purchase of those shares has not yet been received or if insufficient documentation or anti-money laundering 4

9 information has been received by the ACD. A confirmation giving details of the number and price of shares redeemed will be sent to the redeeming Shareholder (or the first named Shareholder, in the case of joint Shareholders) together with (if sufficient written instructions have not already been given) a form of renunciation for completion and execution by the Shareholder (or, in the case of a joint holding, by all the joint Shareholders) no later than the end of the business day following the later of the request to redeem shares or the valuation point by reference to which the price is determined. Payment of redemption proceeds will normally be made by cheque to the first named Shareholder (at their risk), or, at the ACD s discretion, via bank transfer in accordance with any instruction received (the ACD may recover any bank charge levied on such transfers). Instructions to make payments to third parties (other than intermediaries associated with the redemption) will not normally be accepted. Such payment will be made within four business days of the later of (a) receipt by the ACD of the form of renunciation (or other sufficient written instructions), duly signed and completed by all the relevant Shareholders, together with any other documentation and appropriate evidence of title and any required anti-money laundering related documentation; and (b) the Valuation Point following receipt by the ACD of the request to redeem. Can I convert my shares for another share Class in the same Fund? Subject to any restrictions on the eligibility of investors for a particular share class, an investor may at any time Convert all or some of his shares ( Original shares ) of one Class in a Fund for shares in another Class ( New shares ) in the same Fund. There is no charge for Converting between share Classes. Investors wishing to Convert into gross shares (if they are available) must first complete a Declaration of the Eligibility and Undertaking, which may be obtained from the ACD. Can I Switch between the different Companies and Funds operated by the ACD? Subject to any restrictions on the eligibility of investors for a particular Company, Fund or share class, a Shareholder may at any time Switch all or some of his shares ( the Original shares ) for shares of another Company or Fund ( the New shares ) operated by the ACD. The ACD may at its discretion make a charge on the switching of shares between Companies and Funds. Any such charge on Switching does not constitute a separate charge payable by a Shareholder, but is rather the application of any redemption charge on the Original shares and any initial charge on the New shares, subject to certain waivers. A Switch of shares in one Company or Fund for shares of any Class in any other Company or Fund is treated as a redemption and purchase of New shares and will, for persons subject to taxation, be a realisation for the purposes of capital gains tax. Investors wishing to Switch into gross shares (if they are available) must first complete a Declaration of the Eligibility and Undertaking which may be obtained from the ACD. When will my investment be made? Where an application or telephone instruction is received before the Valuation Point on any business day, the investment will normally be made at that Valuation Point. Instructions received after the Valuation Point will be carried over to the next business day s Valuation Point. How can I keep track of the price of the Funds? The previous day s dealing prices of shares in the Funds are available at or via a link at The prices of Funds may also be obtained by calling the ACD on during the ACD s normal business hours. As the Funds deal on a forward pricing basis, the prices that appear in these sources will not be the same as those at which investors can currently deal. Table of Accumulation and Distribution Dates The ACD may also, at its sole discretion, decide to publish certain share prices on third party websites or publications but the ACD does not accept responsibility for the accuracy of the prices published in, or for the non-publication of prices by, these sources for reasons beyond the control of the ACD. When are distributions of income made? The Elite CAM Discretionary Portfolios offer both Accumulation and Income shares. Income will be accumulated in the price of Accumulation shares and the share price will be increased to reflect this. Holders of Accumulation shares will be sent an Accumulation Statement giving details of the amount accumulated during the relevant period. Holders of Income shares will receive distributions of income where available, by BACS direct credit and will also receive a Tax Voucher giving details of the amount distributed during the relevant period. Details of the distribution and accumulation dates are shown below. 5

10 Table of Accumulation and Distribution Dates Fund Final Accounting Date Interim Accounting Dates Ex-dividend Dates Income Distribution/ Accumulation Dates All Funds 31 May 30 November 1 June 1 December 31 January; 31 July Income will be distributed to holders of income shares who will receive a Tax Voucher (Distribution Notification for ISA investors) giving details of the amount distributed during the relevant period. Income will be accumulated in the price of accumulation shares and the share price will be increased to reflect this. Holders of accumulation shares will be sent a Tax Voucher (Distribution Notification for ISA investors) giving details of the amount accumulated during the relevant period. Charges & Expenses What fees and expenses apply to a Fund s Shares? Fees paid directly by you: Initial Charge: Fund Share Class A Class B Class C Class All Funds 5% 0% 6% Switch Charge: Nil Redemption Charge: Nil Fees paid out of the Funds assets: Annual Management Charge (see table below) Fund Share Class A Class B Class C Class All Funds 1.50% 1.50% 0.70% The Depositary s fees and expenses; The Custodian s fees and expenses; The Auditor s fees and expenses; Other fees and expenses related to the management and administration of the Fund for which the ACD is permitted to be reimbursed as detailed in the Prospectus (see section entitled Other Payments of the Company ). 4

11 How much will any advice cost? Should you decide to take advice about the Fund your adviser will give you details about the cost. The amount will depend on the size of your investment and, in the case of regular savings, the period for which you make them. How will charges and expenses affect my investment? Shares in a Fund are purchased and sold at the Fund s share price based on its Net Asset Value. The initial charge paid as detailed above is deducted from an investor s subscription monies before shares are purchased. All fees and expenses for the Funds will be deducted from capital. Where fees are charged to capital this can constrain capital growth. The possible effect of charges and expenses on an investment in the Funds are illustrated in the following table, which has been compiled in accordance with FCA regulatory guidelines. These calculations are based on the assumption that the investment is growing at a rate of 4.5% per year for a direct investment and 5% per year for an ISA Investment into Class A shares. All ACDs use the same rates of growth for illustrations but their charges vary. These figures are not guaranteed and are only used to provide an illustration of the effect that expenses and charges may have on the growth of an investment. What you will get back will depend on how your investment grows. You could get more or less than the figures shown. Do not forget that inflation will reduce what you can buy in the future with the amount shown. Illustration of the possible effect of charges and expenses on your Investment Fund Name Elite CAM Balanced Discretionary Portfolio Elite CAM Cautious Discretionary Portfolio Share Class A A Lump Sum Invested 10,000 10,000 Illustrative Growth Rate per Annum 4.50% (Direct investment) 5.00% (ISA investment) 4.50% (Direct investment) 5.00% (ISA investment) Initial Charge 5.00%* 5.00%* 5.00%* 5.00%* At End of Year Acc Inc Acc Inc Acc Inc Acc Inc Income to date: N/A N/A N/A N/A Effect of Deductions to date: ,554 2,376 4, ,554 2,376 4, ,577 2,433 5, ,577 2,433 5, ,474 2,238 4, ,469 2,221 4, ,495 2,292 4, ,490 2,275 4,693 What you might get back: This line shows that over 10 years the effect of total charges and expenses could amount to: Putting it another way this would have the same effect as bringing investment growth from 4.5% a year down to: 9,634 9,857 10,086 10,682 9,634 9,857 10,086 10,682 9,680 9,999 10,330 11,204 9,680 9,999 10,330 11,204 9,660 9,938 10,224 10,975 9,614 9,796 9,982 10,462 9,706 10,081 10,470 11,511 9,660 9,938 10,224 10,975 4,848 4,848 5,085 5,085 4,555 4,474 4,778 4, % 0.6% 1.1% 1.1% 0.9% 1.0% 1.4% 1.4% **of the net amount invested (equivalent to approximately % of the gross amount invested).

12 What is the total expense ratio ( TER )? The TER is a measure used to show the annual operating expenses of the relevant Fund. The TER is the accepted standard used in the European Union for the comparison of these costs. Certain costs are excluded from the calculation of the TER. They include: The initial charge; Interest on borrowing; Payments incurred due to financial derivative instruments; Entry/exit commissions or any fees paid directly by the investor; and Commission sharing arrangements. Table of charges and expenses Fund Share Class Initial Charge AMC TER** A Accumulation 5%* 1.50% 3.25% A Income 5%* 1.50% 3.25% Elite CAM Balanced Discretionary Portfolio B Accumulation 0%* 1.50% 3.25% B Income 0%* 1.50% 3.25% C Accumulation 6%* 0.70% 2.45% C Income 6%* 0.70% 2.45% A Accumulation 5%* 1.50% 2.98% A Income 5%* 1.50% 2.98% Elite CAM Cautious Discretionary Portfolio B Accumulation 0%* 1.50% 2.98% B Income 6%* 0.70% 2.98% C Accumulation 6%* 0.70% 2.18% C Income 6%* 0.70% 2.18% *of the amount invested by an investor **TER calculated as at 30 th November 2015

13 Do you apply a dilution levy? The actual cost of purchasing, selling or Switching assets and investments in the Funds may deviate from the mid-market value used in calculating the share price due to dealing charges, taxes and any spread between the buying and selling prices of the relevant Fund s underlying investments. These costs could have an adverse effect on the value of an interest in a Fund. In order to mitigate the effect of dilution, and in order to protect the interests of existing/continuing Shareholders, the ACD has the power to charge a dilution levy on the purchase and/or redemption or Switching of shares. In cases where a dilution levy is made the value of the capital of the property of the relevant Fund will not be adversely affected by dilution. Where charged, the dilution levy will be shown in addition to (but not part of) the price of shares when they are issued by the ACD or as a deduction when they are redeemed by the ACD. The ACD has no entitlement to the dilution levy, which will be paid into relevant Fund. The need to charge a dilution levy will depend on the volume of Net purchases or redemptions, as described below. The ACD may charge a discretionary dilution levy on any sale or redemption of shares if, in its opinion, the existing Shareholders (for sales) or continuing Shareholders (for redemptions) might otherwise materially be adversely affected. A dilution levy must be imposed only in a manner, that so far as practicable, is fair to all Shareholders or potential Shareholders. In particular, the dilution levy may be charged in the following circumstances: (i) where a Fund is in continual decline; (ii) on a Fund experiencing large levels of Net sales (i.e. sales less redemptions) relative to its size; (iii) on large deals. For these purposes, a large deal is defined as a sale or a redemption of 2 per cent or more of the value of Fund; (iv) in any other case where the ACD is of the opinion that the interests of existing/continuing Shareholders and potential Shareholders require the imposition of a dilution levy. In the event that a Shareholder requests the redemption or cancellation of Shares representing over 5% of the property of a Fund then, the Company can effect an in specie cancellation, by cancelling the shares and transferring relevant Scheme Property to the Shareholder (see full Prospectus). Should the Shareholder not wish to receive Scheme Property upon the redemption of shares then the ACD may arrange to sell the shares and will pay the consideration, less expenses incurred, to the Shareholder. A dilution levy is currently charged where a fund is deemed to be in continual decline (with the prior agreement of the Depositary) or on large repurchases. Should a dilution levy be required then, based upon historical data it is estimated that the dilution levy will not exceed 2%. The ACD may alter its dilution policy either by Shareholder consent pursuant to the passing of a resolution to that effect at a properly convened meeting of Shareholders and by amending this Prospectus or by giving the Shareholders notice and amending the Prospectus 60 days before the change to the dilution policy is to take effect. Further details on this policy are available in the full Prospectus. What is the Portfolio Turnover Rate ( PTR )? The PTR shows the level of trading activity in the Company over the previous 12 months. The formula used to calculate the PTR is as follows: (purchases + sales) - (subscriptions + redemptions) x 100 The PTR (average for each of Fund the Funds value over as at December months) The PTRs for the Funds as at 30 th November 2015 were as follows: Fund Elite CAM Balanced Discretionary Portfolio Elite CAM Cautious Discretionary Portfolio Economic Information PTR 31.37% 66.71% What about tax? The information below is a general guide based on current United Kingdom law and HM Revenue and Customs practice, which are subject to change. It summarises the tax position of the Funds and of investors who are United Kingdom residents and who hold shares as investments. Prospective investors who are in any doubt about their tax position, or who may be subject to tax in a jurisdiction other than the United Kingdom, are recommended to take professional advice.

14 How are the Funds themselves treated for tax purposes? Each Fund is treated as a separate entity for United Kingdom tax purposes. The Funds are generally exempt from United Kingdom tax on capital gains realised on the disposal of investments (including interest-paying securities and derivatives, but excluding on non-reporting offshore funds) held within them. Dividends from both United Kingdom and non-united Kingdom companies are received by a Fund with a tax credit and no further tax is payable by the Fund on that income. The Funds will each be subject to corporation tax at 20% on most other types of income but after deducting allowable management expenses. Where a Fund suffers foreign tax on income received, this may normally be treated as an expense or deducted from any United Kingdom tax due payable on that income. How does tax affect an investor? Income from the Funds For the purposes of tax, the Funds will normally pay any distributable income as dividend distributions, (which will automatically be retained in the case of accumulation shares). Dividend distributions will be paid with a 10% tax credit. United Kingdom resident individuals liable to income tax on investment income at the basic rate will have no further liability to tax. Higher rate taxpayers will have to pay an additional amount of income tax, as will additional rate taxpayers. Non-taxpayers cannot reclaim the tax credits on dividend distributions paid. Corporate Shareholders who receive dividend distributions may have to divide them into two (in which case the division will be indicated on the reverse of the tax voucher). Any part representing dividends received will be treated as dividend income (that is, franked investment income) and no further tax will be due on it. The remainder will be received as an annual payment after deduction of income tax at the basic rate, and corporate Shareholders may, depending on their circumstances, be liable to tax on the grossed up amount, with the benefit of the 20% income tax credit attached or to reclaim part of the tax credit as shown on the tax voucher. Non-United Kingdom resident Shareholders will generally not be entitled to reclaim any part of the tax credit on the dividend distribution from HM Revenue & Customs although it will normally satisfy their United Kingdom tax liability on that income. They may also be able to offset the tax credit against their liability to tax in their country of domicile. Gains Investors who are resident in the United Kingdom for tax purposes may, depending on their personal circumstances, be liable to capital gains tax or, if a corporate investor, corporation tax on gains arising from the redemption, transfer or other disposal of shares (but not usually on Conversions between classes within a Company or Fund). Part of any increase in value of accumulation shares represents the accumulation of income (including income equalisation but excluding tax credit). These amounts may be added to the acquisition cost when calculating the capital gain realised on their disposal. Client Money Delivery versus payment (DVP) exemption We are required to comply with the FCA s client money rules, as set out in Chapter 7 of the FCA s Client Assets sourcebook (CASS) (the Client Money Rules ). We are making use of the DVP exemption available under the Client Money Rules when handling money for you in connection with the buying or selling of units/shares in our funds. Under the DVP exemption your money need not be treated by us as client money for the purposes of the Client Money Rules in the following two scenarios: (1) where money is received from you that relates to your subscription to units/shares in one of our funds; and (2) where money is held by us that relates to the redemption of your units/shares in one of our funds. While we are operating under the DVP exemption, your money will not be subject to the protections conferred by the Client Money Rules and, if we were to fail, the FCA s client money distribution rules as set out in Chapter 7A of CASS (the Client Money Distribution Rules ) will not apply to these sums and you will not be entitled to share in any distribution under the Client Money Distribution Rules in respect of these sums. Where we have not paid any money belonging to you to the trustee (in respect of a unit trust), the depositary (in respect of an OEIC) or to you, as the case may be, by close of business on the business day following receipt, we will stop operating under the DVP exemption for that transaction and will treat the relevant sum of money as client money for the purposes of the Client Money Rules. Any redemption proceeds paid to you by cheque will be held as client money under the Client Money Rules until such time as the cheque is presented. By buying units/shares in one of our funds through us, you agree to our use of the DVP exemption as set out above. Should we cease at any time to make use of the DVP exemption, you will be notified in advance in writing.

15 Interest We will not pay to you any interest earned on money we hold for you as client money under the Client Money Rules. General Information What other information can I access? The annual short report of the Company will normally be sent to the Shareholders within four months of each annual accounting period end. The half-yearly (interim) short report will be despatched within two months of each interim accounting period end. The short reports and a report containing the full accounts of the Company (the long report) are available to any person free of charge on request to the ACD. The relevant accounting end dates are detailed in the Table of Accumulation and Distribution Dates section. Manager s reports and Company s Prospectus Copies of the Prospectus and the latest annual and halfyearly reports may be obtained free of charge, before or after you invest with the ACD, at the administration address quoted within the directory at the front of this document. In addition the latest annual and half-yearly short reports may be downloaded from the ACD s website at Distance Marketing Directive If an investor has not had a face to face discussion with a representative of the company through which they are making this investment, which could, for example, be the ACD or a company providing financial advice, then the investor is entering into this transaction at a distance. In this situation an investor does not have a right to cancel this investment unless the ACD decides to extend such a right to them. An investor who has bought shares at a distance can still sell those shares, as they are able to do at any time. However, they cannot recover any initial charges incurred in the purchase of the shares. This Simplified Prospectus contains all of the information required for an investment made directly through the ACD. Where shares are purchased through an agent, investors should ask that agent for details of their identity, geographical address and the capacity in which they are acting. The main service we provide to investors is the management and administration of the Company. Details of all fees and expenses associated with the provision of this service are provided in this document. There are no additional costs levied by the ACD for investing at a distance, but there may be other taxes or third party costs that may apply to investors depending on their personal circumstances. The investment contract between an investor and the ACD is governed by English Law and, by purchasing shares, the investor agrees that the Courts of England have exclusive jurisdiction to settle any disputes. All communications in connection with this investment will be in the English language. Any information in this document is valid only at the date of publication which is stated on the front cover. All such information can change at any time and it will not necessarily be possible for us to notify you of any such changes in advance. Please contact the ACD for updates on any of the enclosed information. Cancellation An investor does not have the right to cancel their application to invest in a Fund if the application has been made directly by the investor or if the investor did not meet their adviser or agent face to face though the ACD may, at its discretion, extend cancellation rights to such an investor. If an investor has received face to face advice on the investment they will have a right to change their mind under rules made by the FCA under the Financial Services and Markets Act The investor will be able to exercise the right to cancel within 14 days of receipt of the cancellation notice from the ACD and they will receive a refund of the amount invested either in full, or less a deduction to reflect any fall in the Fund s price in the intervening period. UK Money Laundering Regulations As a result of legislation in force in the UK to prevent money laundering, the ACD is responsible for compliance with antimoney laundering regulations. In order to implement these regulations, in certain circumstances investors may be asked to provide proof of identity when buying or redeeming shares. Until satisfactory proof of identity is provided, the ACD reserves the right to refuse to issue shares, pay the proceeds of a redemption of shares, or pay income on shares to the investor. In the case of a purchase of shares where the applicant is not willing to provide the information requested within a reasonable period, the ACD also reserves the right to sell the shares purchased and return the proceeds to the account from which the subscription was made. proceeds may be less than the original investment. These Governing Law The Company, the Instrument of Incorporation, this Prospectus and any matters arising out of or in connection