Disclosures

“GreensLedge” is the marketing name used by GreensLedge Capital Markets LLC, GreensLedge Capital Markets Europe LLP, The GreensLedge Group LLC, GreensLedge Asia Limited, GreensLedge Korea Ltd., GreensLedge Advisors LLC, and GreensLedge Asset Management LLC. Certain business activities described on this website have been or may be conducted by one or more of these entities as appropriate and as required by law.

GreensLedge Capital Markets LLC (“GLCM”) is a U.S. registered broker-dealer and member of FINRA and SIPC. More information on GLCM may be viewed by visiting https://brokercheck.finra.org/

GreensLedge Capital Markets Europe LLP is authorised and regulated by the Financial Conduct Authority (“FCA”) under FCA FRN 603935.

GreensLedge Asia Limited (“GAL”) is a registered Type 1 and Type 2 Financial Instruments Business Firm under Financial Instruments and Exchange Law of Japan and is ultimately regulated by the Financial Services Agency of Japan and the Kanto Local Finance Bureau. GAL is also a member of Japan Securities Dealers Association, a self-regulatory organization of financial instruments dealers, and a member of Japan Investor Protection Fund.

GAL is a wholly-owned subsidiary of GLCM. GAL has an office in Tokyo, which is not a branch office of GLCM. Neither GAL nor its Tokyo office are registered in the U.S. or are members of FINRA. GAL may act as an introducing broker to GLCM as appropriate.

GreensLedge Advisors LLC (“GLA”) is a wholly owned subsidiary of GreensLedge Group LLC, and is registered as an investment adviser with the U.S. Securities and Exchange Commission.

GreensLedge Asset Management LLC (“GLAM”) is a wholly owned subsidiary of GreensLedge Group LLC, and is registered as an investment adviser with the State of Connecticut, U.S.A.

Copies of the most recently filed Form ADV for each of GLA and GLAM are available through the Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/.

The information, tools and materials presented on this website are provided for general informational purposes only. No material at this website shall be used or considered as an offer to sell or a solicitation of any offer to buy securities. Offers can only be made where lawful under, and in compliance with, applicable law.

GreensLedge does not use this website to provide investment or other advice, and no information or material available through the website is to be relied upon for the purpose of making or communicating investment or other decisions. GreensLedge does not represent that any securities, financial instruments, products or services contained on the site are suitable or appropriate for all any particular investor or type of investor. This website does not constitute an offer, invitation or solicitation to buy or sell any securities, financial instruments, investments or other services or engage in any other transaction, and may not be relied upon in connection with any potential investment. An offer, invitation or solicitation will be made only through a final private placement memorandum, subscription agreement and other related documents with respect to a particular investment opportunity, and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor.

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.

This notice answers some questions about our firm’s Customer Identification Program.

What types of information will I need to provide?

When you transact securities business with us, we are required to collect the following information:

• Legal entity name
• Address
• Identification number
  • U.S. citizen: taxpayer identification number (employer identification number)
  • Non-U.S. citizen: taxpayer identification number or alternative identifying documents

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or trust agreement.

U.S. Department of the Treasury, SEC, and FINRA rules already require you to provide most of this information. These rules may require you to provide additional information.

What happens if I don’t provide the information requested or my identity can’t be verified?

We may not be able to carry out transactions for you.

Overview – GreensLedge has created and implemented a business continuity plan (“BCP”) in an effort to mitigate the effects related to unforeseen business interruptions. This BCP is designed to enable the Firm to continue or resume trading operations in the event of an emergency or significant business disruption (“SBD”).

Communications and Locations of Employees During a Disruption – In the event of an SBD, GreensLedge will communicate with its employees in several different ways. GreensLedge will employ a calling tree, which would be implemented by management in the event of an SBD. The BCP also addresses the relocation of staff to an alternative back-up location in the New York area, which would be immediately available with the equipment and facilities necessary for GreensLedge’s professionals to be able to conduct business for a temporary or extended period of time. Recovery time for most of the applications and relocation to the alternate location is expected to range from immediate to 24 hours. GreensLedge’s BCP also addresses the relocation of staff to work remotely from home for an indefinite period of time.

Communications with Clients and Customers – GreensLedge currently communicates with its clients and customers using the telephone, email, fax, US Mail, and in person. In the event of an SBD, GreensLedge will assess which means of communication are still available and use the means closest in speed to the means used in the past. Additionally, if traditional communications are not available, GreensLedge representatives will use the best available means to contact GreensLedge’s clients and customers in order to make contingent plans for the duration of the SBD. In the event of an SBD that may affect GreensLedge’s ability to communicate with its clients and customers, GreensLedge’s senior management may elect to place emergency contact information and/or instructions on the website of its affiliated companies (www.greensledge.com) as an additional means of communication with GreensLedge’s clients.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do or using the main GreensLedge New York phone line at 212-792-5270, you should call our alternative number 203-241-3943. If you cannot access us through any of those means, you should contact our clearing firm, Pershing LLC at 201-413-3776 for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.

Books & Records – GreensLedge maintains its hard copy books and records and electronic records primarily at its Main Office and back-up books and records at alternate locations for the prescribed retention periods required by the applicable regulatory body. If records are lost as the result of a business disruption, GreensLedge has the means to physically recover data from both physical and electronic back-up locations.

Vendors and Counterparties – GreensLedge’s BCP may need to rely upon the recovery and restoration of services provided by various critical business constituents and counterparties both at its primary and alternate locations. GreensLedge has considered the extent to which GreensLedge may be able to depend upon these business relationships during an SBD as a part of its decision to do business with the constituents. Where possible GreensLedge has engaged and/or vetted alternate arrangements in order to avoid business disruptions in the case of a business constituent not being able to provide needed goods or services in an emergency.

Disclosure – GreensLedge’s BCP is designed to address the continued operation of GreensLedge in the event of an emergency situation or SBD. However, all risks of business interruption cannot be eliminated and GreensLedge cannot guarantee that systems will always be available or recoverable following an SBD. Furthermore, GreensLedge has no control over and must rely upon the disaster recovery plans of its various critical business constituents, vendors, clearing firms and counterparties. In the event that material changes are made to this BCP, GreensLedge will send an updated copy to all of its clients.

The information contained in this disclosure is provided by GreensLedge for informational purposes only, and nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any customer agreement between you and GreensLedge.

The contents of the Site are provided for informational purposes only and are not intended to provide legal, tax, investment, or financial planning advice. To the extent that the Site contains or links to any economic calculator, forecasting, investment tool or model, or similar device, you acknowledge and understand that the information resulting from the use of any such device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from an investment professional. YOU SHOULD NOT RELY ON THE SITE AS ANY BASIS FOR INVESTMENT DECISIONS. You should not rely on the Site as the primary basis for your investment decisions.

References to investment objectives, target returns or other goals GreensLedge seeks to achieve in managing a fund or account are aspirational only and should not be considered a guarantee that such results will be achieved.

Any portfolio risk management processes discussed include an effort to monitor and manage risk, but should not be confused with and do not imply low risk or the ability to control risk.

Any performance data or commentary on performance expressed on this website are an indication of past performance. PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS, and no representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided. Future returns are not guaranteed and a loss of principal may occur. The website may contain statements that are forward looking. These statements include, but are not limited to, those related to GreensLedge’s expectations regarding performance of its business and other non-historical statements in discussion and analysis. These forward-looking statements are based on GreensLedge’s beliefs, as well as assumptions made by, and information currently available to, management. The words “believe,” “anticipate,” “estimate,” “expect,” “intend” and similar expressions may identify forward-looking statements. GreensLedge can give no assurance that any of its expectations will prove to have been correct and actual results may differ materially from expected results. GreensLedge undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future developments or otherwise, except as required by applicable law. The investment return and principal value of an investment may fluctuate significantly. Opinions and/or estimates reflect a judgment at the original date of publication by GreensLedge and are subject to change without notice.