TERMS AND CONDITIONS

Legal Notice

This website is issued by Spark Impact Limited and is for informational purposes only. Use of this website is subject to the following terms. By using this website, you are deemed to have accepted these terms.

This Site is not directed at, or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to applicable law or regulation or which would subject the firm to any registration or licensing requirement within such jurisdiction, such as the United States (but not limited to). Neither this website as a whole nor any part hereof shall constitute an offer of or the solicitation of an offer to invest, or the sale of securities, nor shall there be any sale of any investments or commitments in connection with this website in any jurisdiction in which such offer, solicitation or sale would be unlawful including the United Kingdom and the United States. The contents of this website do not constitute investment, legal, tax or other advice and should not be taken as such. Spark Impact Limited acts as fund manager to funds on behalf of institutional clients or local goverments and does not offer investment advice to retail clients as defined in the FCA handbook COBS 3.4. The regulated services provided by Spark Impact Limited are only accessible to Eligible Counterparties or Professional clients as defined in COBS 3.5 & 3.6 or in the case of Fund investors COBs 4.12 of the Financial Conduct Authority handbook. As the firm is not permitted to deal with Retail clients this means that the same levels of protection afforded to Retail Clients would not be available to perspective regulated activity clients of the firm.  Please seek independent professional financial and legal advice if you are unsure of your categorisation or if you wish to find out more about the products or services on this website.

Risk Warning

The investments communicated relate to investments in unlisted securities which carry a high degree of risk due to their illiquid nature, Investments may fall as well as rise and you may not get back all you have invested. Past performance should not be seen as an indication of future results, you may lose some, part or all of your original capital invested.

No representation or warranty is given that the information or opinions contained in this website are accurate, reliable or complete. Any information contained within this website is subject to amendment, revision or updating. Spark Impact Limited reserves the right to suspend or withdraw access to the pages of this site without notice at any time and accepts no responsibility for these pages not being available at all times.

Users of this website must not transmit any virus, 'worm', 'Trojan horse', or other item of a destructive nature to this site and it is the user's responsibility to ensure that whatever is downloaded or selected for use from the site is free from such items.

This site is governed in accordance with the laws of England and Wales. By accessing the site, you agree to submit to the exclusive jurisdiction of the Courts of England and any adjudication they make in respect of litigation arising in connection with the site.

This site does not ask for, retain or share any user’s data including.

This site does not use or store Cookies.

Confidentiality

Information is an asset and Spark Impact Limited acknowledges that there is a corporate responsibility to safe guard such information provided to us by our clients. Spark Impact Limited has in place policies and procedures with regards to office and Data security and Data protection and we are fully committed to comply with our obligations as set out in the Data Protection Act 1998 and the forthcoming GDPR. If you require full details of the information on what type of information we hold on our clients and how we safeguard this information, please contact the firm’s Compliance Officer “Rebecca Hume”.

Complaints

We are committed to working with our clients to achieve best client outcomes, and we welcome feedback and the opportunity to improve our service. Please direct any complaints or queries to the firm’s compliance officer in writing in the first instance as follows:

Rebecca Hume, Compliance Officer, Spark Impact Limited, Liverpool Science Park131 Mount Pleasant Liverpool MerseysideL3 5TF

Although the firm does not have eligible complainants as defined in the FCA handbook DISP 2.7.3R, the firm is committed to achieving best client outcomes. The firm has a complaints policy and procedures and as such we will acknowledge receipt of your compliant / inquiry, in writing, and endeavour to resolve any issues as soon as is practicably possible, however sometimes matters may take longer to investigate, in this instance we will keep you informed and will provide you with our final written response within eight weeks of compliant receipt.

TCF Policy Statement

The firm is committed to Treating customers fairly and as such has a TCF policy which sets out the firm’s procedures and obligations. Although the firm does not have Retail clients, it does have a duty to achieve best client outcomes and adhere to the FCA handbook rule PRIN 2.1.1R, and the TCF initiative which as per principle 6 states “A firm must pay due regard to the interests of its customers and treat them fairly”.

Anti-Bribery and Corruption Policy

Spark Impact Limited is committed to apply the highest standards of ethical conduct and integrity in its business activities.  Every employee and individual acting on behalf of Spark Impact Limited is responsible for conducting business honestly and professionally.

Spark Impact Limited benefits from carrying out business in a transparent and ethical way and by helping to ensure that there is honest, open and fair competition in our sectors.  Where there is a level playing field Spark Impact Limited can lead the market through innovation and by delivering excellent services to its customers.

Spark Impact Limited does not tolerate any form of bribery by, or of, its employees or any persons or companies acting for it or on its behalf. The Board and senior management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

Spark Impact Limited has issued an Anti Bribery policy in order to prevent and prohibit bribery and corruption.  The Anti Bribery policy applies to all employees and they are required to familiarise themselves and comply with the policy.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of Spark Impact Limited are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its Anti-bribery measures, Spark Impact Limited is committed to engage only in transparent, proportionate, reasonable and legitimate hospitality and promotional expenditure.

A breach of Spark Impact Limited anti bribery policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.  Employees and other individuals acting for Spark Impact Limited should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for Spark Impact Limited.

Spark Impact Limited will not conduct business with service providers, agents or representatives that do not support the firm’s anti-bribery and corruption objectives.

The success of Spark Impact Limited’s anti-bribery measures depends on everyone playing their part in helping to detect and eradicate bribery.  Therefore, all employees and others acting for, or on behalf of Spark Impact Limited are encouraged to report any suspicious activity to the Whistle Blowing Officer Marc d’Abbadie. Spark Impact Limited Board members will support any individuals who make such a report in good faith. Spark Impact Limited does not hold any responsibility for contractors or agents whom act on their own initiative and do not comply with the firm’s anti bribery policy despite agreeing to do so, and reserves the right not to deal with any persons or firms who do not agree to the firm’s anti bribery policy. Acceptance of our policy is deemed as acceptance of compliance with the firm’s policy.

Spark Impact Limited is authorised and Regulated in the UK by the Financial Conduct Authority – FRN 143361, Spark Impact Limited is registered in England and Wales Liverpool Science Park 131 Mount Pleasant Liverpool Merseyside L3 5TF, registered number 02323420