Cookies Policy

This Cookies Policy describes how Rokos Capital Management LLP or its group companies handle certain of your personal information provided to us via by cookies. It applies generally to our site. In addition to the privacy practices set out in this Cookies Policy, we have Website Terms of Use which incorporate the terms of this Cookies Policy and a Privacy Notice. Some words used in this Privacy Policy are defined in our Terms of Use.  In this notice, “we”, “us” and “our” refers to Rokos Capital Management LLP or any of its group companies that may receive and use personal information from cookies.

1. What are cookies?

Cookies are small text files which are placed on the computer of a website user to provide the website operator with information about use of our site. They are used to enable websites to function or to provide information to the owners of a website.

Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. Alternatively, you can search the internet for other independent information on cookies.

2. Why do we use cookies?

In broad terms we use cookies on our site for the following purposes:

• Analytical purposes: Analytical cookies allow us to recognise, measure and track users of our site in anonymous form. The information collected includes the number of visitors to our site, where visitors have come to our site from and the pages that they have visited. This helps us to improve the way our site works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.

• Usage preferences: Some of the cookies on our site are activated when visitors to our sites make a choice about their usage of our site. The site then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of our site to the individual user.

• Disclaimer: We use cookies on our site to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to our Terms of Use/Disclaimer. This helps to improve the user’s experience of our site – for example, it avoids a user from repeatedly being asked to consent to the same terms.

• Session management: The software that runs our websites uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of our site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for our site to function.

• Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

3. Your cookie preferences

To make full use of our site, your computer or mobile device will need to accept cookies, as our site will not function properly without them. In addition, cookies are required in order to provide you with personalized features on our site.

4. Third party cookies

When you visit our website, you may receive cookies that are set by third parties. These may include cookies set by Google. These cookies are used for the purposes described in the “Why do we use cookies?” section of this policy. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

5. Amending cookie preferences

If you wish to remove cookies set by our site from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our site will impair the functionality of our site.

6. Information we may collect from you

We may collect and process the following data about you in accordance with this Cookies Policy:

1. information that you provide to us via our site;

2. if you contact us, we may keep a record of that correspondence and may record telephone calls for regulatory compliance and record keeping purposes; and

3. details of your visits to our site and the materials and information that you access.

7. Use of your information

1. We may use data held about you in the following ways:
   to support your interaction with us, including to ensure that the content of our site is presented in the most effective manner for you and your computer, to provide you with information or products you may have requested through our site, to notify you about changes to our site and to ensure the ongoing accuracy and relevance of such data;

2. to carry out any security or other verification activities to ensure the proper operation of our site or to ensure compliance with our regulatory obligations;

3. for general internal research purposes, including to identify and analyse the regularity of the use of our site and the nature of our site’s users; and

4. to design products and services for your use.

We may disclose your personal data to our affiliates, agents and contractors (including to parties located outside the European Economic Area) for the purposes stated above. We may also disclose your personal data to third parties (including to parties located outside the European Economic Area):

1. in the event that we sell or buy, or one or more of our affiliates sells or buys, any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

2. if we or our assets, or one or more of our affiliates or our affiliates assets’ are acquired by a third party, in which case personal data held by it about its clients may be one of the transferred assets;

3. if we, or one or more of our affiliates are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation; or

4. in order to enforce or apply our Terms of Use and other agreements or to protect our rights, our customers or others.

By using this site, you consent to processing of your personal data in accordance with our Website Terms of Use and this Cookies Policy and you warrant that all data provided by you is accurate.

TERMS OF USE

1. Rokos Capital Management LLP

1.1 The Website is operated and issued by Rokos Capital Management LLP (“RCM” or the “Company”, “we”, or “us”) which is authorised and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”) (Reference Number: 679721). You can gain access to the FCA's rules and guidance notes from the following link: http://www.fca.org.uk.

1.2 RCM is a limited liability partnership registered in England (Company Number: OC398894), with its principal business address at 23 Savile Row, London, W1S 2ET and its registered office at 4th Floor Reading Bridge House, George Street, Reading, Berkshire, United Kingdom, RG1 8LS.

1.3 General enquiries about this Website should be sent to info@rokoscapital.com  
Enquiries about investments in any RCM managed product should be sent to ir@rokoscapital.com 

2. These Terms

2.1 These Terms set out the terms on which you may use this Website, and apply to all pages, even where they are not individually disclaimed. These Terms also incorporate our Cookies Policy and Privacy Notice (please refer to paragraph 3 below) and all other policies and procedures that we may publish from time to time on this Website. Each of these is incorporated by reference and may be updated from time to time without notice.

2.2 By using this Website, you confirm that you accept these Terms, and that you will comply with them. If you do not agree to these Terms, you are not permitted use this Website.

3. Cookies and Privacy

3.1 This Website uses cookies. By continuing to use this Website you are giving consent to cookies being used. For information on cookies and how you can disable them, please visit our Cookies Policy.

3.2 For information on how RCM uses certain other types of personal data, please refer to our Privacy Notice.

4. The Financial Reporting Council’s Stewardship Code

4.1 Under the rules of the FCA Handbook, RCM is required to include on this Website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the “Stewardship Code”) or, where it does not commit to the Stewardship Code, its alternative investment strategy.

4.2 RCM’s Stewardship Code disclosure statement is available on this Website at the following link: Stewardship Code.

5. Intended Audience of the Website

5.1 This Website is directed only at persons who are professional investors (for the purposes of the Alternative Investment Fund Managers Directive (2011/61/EU) (“AIFMD”)) (“Professional Investors”); professional clients or eligible counterparties (for the purposes of the Markets in Financial Instruments Directive (Directive 2004/39/EC) (“MiFID”)) (“Professional Clients” or “Eligible Counterparties”); or as otherwise defined under applicable local regulations and at whom this site and the information on it may lawfully be directed in any relevant jurisdiction. Please contact us at info@rokoscapital.com if you require any further information on your status.

5.2 By accepting these Terms, you hereby certify that you are a Professional Investor, a Professional Client or an Eligible Counterparty.

5.3 It is your responsibility to inform yourself, and to comply with, all relevant legal or regulatory requirements of any jurisdiction of which you are a citizen, in which you are resident, or in which you are accessing this Website which may affect your eligibility to access the Website or subscribe to any investment services that RCM offers. In particular, it may be illegal to view and/or download the information contained on this Website in certain countries and we disclaim all responsibility if you access or download any information from this Website in breach of any law or regulation of the country in which you are a citizen, or in which you are resident or domiciled.

5.4 The services, funds, and products described on this Website are not available in all countries or to all investors. As such, this Website and the information on it are not addressed to any person resident in the territory or country or jurisdiction where such distribution would be contrary to local law or regulation. Some funds are not available, and offering materials relating to them will not be distributed, to persons resident in any country where such distribution would be contrary to local law or regulation.

5.5 Any person subscribing for an investment, product, or service referred to on this Website must be able to bear the risks involved with such investment, product, or service, and must meet the applicable suitability requirements relating to such investment, product or service. Some or all investment programs offered by RCM may not be suitable for certain investors.

5.6 If you are not clear about the meaning of anything on this Website or other information provided by RCM, you should seek professional advice.

6. Right to Deny Access

6.1 RCM reserves the right to deny you access to this Website. We may immediately suspend or terminate your access to this Website or disable any username or password (whether chosen by you or allocated to you by us), at any time, and at our sole discretion.

6.2 We may have reason to update the Website from time to time, though we are not under any obligation to do so. We may update or remove information from the Website without notice. From time to time, we may restrict or suspend access to some parts of the Website, or the entire Website, for example for maintenance purposes. As such, access to the Website is not necessarily permanent or guaranteed.

7. Your Responsibilities

7.1 When you use this Website, you agree that you will not:

(A) use the Website for any unlawful, improper or illegal purpose or activity, nor will you use this Website to damage our name or reputation, or that of any third party;

(B) misuse the Website by knowingly introducing viruses, Trojan horses, worms, logic bombs or other material which is malicious or technologically harmful. You must not try to gain unauthorised access to the Website, the server on which the Website is stored, or any server, computer or databases connected to our website. You must not attack the Website using a denial-of-service attack or a distributed denial-of service attack;

(C) violate our, or any third party’s copyright, trademark, proprietary or other intellectual property rights, as outlined further below;

(D) access, copy, or otherwise use the Website, except as authorised by these Terms or as otherwise authorised in writing by RCM in its sole and absolute discretion; and/or

(E) impersonate any person or entity, use a fictitious name, or misrepresent your affiliation with a person or entity.

8. Use of Website Content

8.1 In the United Kingdom, the issue and communication of this Website has been approved by RCM. If you are in the United Kingdom or elsewhere in the EEA, you should note that this Website may contain information or documents which constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and the FCA Rules. This Website is issued only to and/or is directed only at persons who are Professional Clients, Eligible Counterparties or Professional Investors.

8.2 The information in this Website does not constitute an offer of, or an invitation to apply for or purchase any securities, investments, products or services. RCM does not provide investment advice to, nor receive and transmit orders from, investors in any funds, nor do we carry on any other activities with or for such investors that constitute ‘MiFID or equivalent third country business’ for the purposes of the FCA Rules.

8.3 The information and opinions on this Website do not constitute an investment recommendation, or other information recommending or suggesting an investment strategy.

8.4 The information and opinions contained on this Website have been compiled, or arrived at, by us from sources believed by us to be reliable as at the date of publication, however it is subject to change with no notice. The information and opinions do not in any way constitute investment, legal, tax or other advice and are for background purposes only.

8.5 This Website is not intended to provide a sufficient basis on which to make any investment decision and you should not solely rely on it in evaluating the merits of investing in any investments, products or services referred to on this Website. Any decision to purchase securities or interests with respect to any funds must only be made having thoroughly read the relevant prospectus or offering memorandum for the relevant fund, including any supplements, which must be received and reviewed prior to any investment decision and which may contain information which is different from the information and opinions contained on this Website.

8.6 There is no way to invest through the Website. Enquiries about investments in any RCM managed product should be sent to ir@rokoscapital.com 

9. Accuracy of Information

9.1 We have taken reasonable care to ensure that the information on this Website is accurate, current, fit for its intended purpose and compliant with applicable law and regulation. However, errors and omissions may occur due to circumstances beyond our control, and neither RCM nor its affiliates offer any warranties or representations regarding the accuracy, validity or completeness of the information on this Website.

9.2 As such, RCM and its affiliates expressly exclude liability and responsibility arising from your reliance on the information and other materials on the Website, or the reliance of anyone with whom you share the materials.

9.3 You must conduct your own due diligence and investigations rather than relying on any information on this Website. Any person who acts on, or changes their investment position in reliance on, the information contained on this Website does so entirely at their own risk.

10. Our Liability

10.1 Further to paragraph 9, neither we nor our affiliates accept any responsibility for any reliance which is placed by any visitor to this Website, or by anyone who may be informed of any of its contents, on any information or opinions which are expressed herein and, to the extent permitted by law, expressly exclude all conditions, warranties, representations, undertakings and other terms which might otherwise be implied by statute, common law or in equity.

10.2 RCM and its affiliates shall have no liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to, any direct, indirect or consequential damage, arising out of the use of our Website or other services.

10.3 Further, you agree that if you transmit confidential or proprietary information through the Website, you do so entirely at your own risk.

11. Your Indemnity

You agree to indemnify, defend, and hold harmless RCM, its affiliates and our respective officers, partners, employees, and agents from and against all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your breach of the Terms and/or access to or use of this Website.

12. Third Party Websites

12.1 At times this Website may contain links to or from other websites over which RCM has no control. These links are solely for your convenience or information, and may be subject to their own terms and conditions. We cannot verify the accuracy of any information contained in third party websites, nor does the inclusion of these links represent an endorsement or a recommendation of the third-party websites. RCM accepts no liability for the content of any website to which the Websites link.

13. Investment Performance

You should note that investments do involve risk and past performance is not a guide to future performance. The value of your investments and the income from them may go down as well as up, and returns are not guaranteed. Tax reliefs may change as per the UK budget from time to time, as they have done previously, and rates of exchange may cause the value of investments to go up or down.

14. Calls Recorded            

For the protection of all parties, telephone calls to RCM or its affiliates may be recorded.

15. Intellectual Property

15.1 We are the owner of all intellectual property rights in the Website, and the material published on it, including, among other things, all trade marks, logos, service marks and service names, whether they are registered or not. These works are protected by, among other things, copyright laws and treaties around the world.  We reserve all such rights.

15.2 You may use, download, and reproduce in hard copy, the Website and any materials located on it for your own reference only. You must not otherwise copy, reproduce, republish, disassemble, decompile, reverse engineer, download, post, broadcast, transmit, make available to the public, or otherwise use Website content in any way without licence from us. You also agree not to adapt, alter or create a derivative work from any Website content.

15.3 Nothing on this Website should be construed as granting any licence or right in relation to any of our trademarks, or any third party.

16. Changes to Terms

We may revise these Terms from time to time by updating this page. The revised Terms will take effect when they are posted. You are expected to check this page from time to time and to take notice of any changes we may have made, as by using this Website you acknowledge that you have accepted any such amendments.

17. Severability

In the event that any provision of these Terms is determined to be unlawful, void or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed to be severed from these Terms (such determination shall not affect the validity and enforceability of any other remaining provisions). When used in these Terms the words ‘includes’, and ‘including’ shall be deemed to be followed by the phrase ‘without limitation’.

18. Material Interests

We and our partners, officers and/or employees may have holdings in the investment funds referred to on this Website and may otherwise be interested in transactions that you effect in those funds.

19. Term and Termination

19.1 These Terms will apply to you as soon as you access the Website and will continue to have effect until they are terminated or if you are no longer interacting with us.

19.2 We may terminate your right to use the functions of our Website at any time, including if you violate or breach these Terms or if allowing you to access and use the Website or its related functions would violate any applicable local, state, provincial, national and other laws, rules and regulations, or would expose RCM to any legal liability whatsoever.

19.3 If these Terms are terminated or you are no longer interacting with RCM, these Terms may no longer apply. However, any provisions of the Terms that by their nature should continue to apply after termination of these Terms will do so. This includes, without limitation, all limitations on liability, choices of law and judicial forum and intellectual property protections and licences. 

20. No Waiver

No waiver by us shall be construed as a waiver of any preceding or succeeding breach of any provision.

21. Third parties

We shall have the benefit of the rights conferred on us by these Terms but otherwise no person who is not a party to these Terms may enforce its terms under the Contracts (Rights of Third Parties) Act 1999.

22. Entire agreement

These Terms (incorporating our Cookies and Privacy Policy) and our Disclaimer shall form the entire agreement between you and us in relation to your use of this Website.

23. Governing Law

These Terms and any non-contractual obligations arising from or connected with them shall be governed by and shall be construed in accordance with English law. English courts will have exclusive jurisdiction over any dispute arising from, or related to, use on this Website (whether arising out of or in connection with contractual or non-contractual obligations) (‘proceedings’) and it is a condition of using this Website that you waive any objection to proceedings in such courts on the grounds of venue or that proceedings have been brought in an inconvenient forum, although we retain the right to bring proceedings against you for breach of these Terms in your country of residence or any other relevant country.

UK Stewardship Code

Under Rule 2.2.3R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, Rokos Capital Management LLP (“Rokos Capital” or “the Firm”), to the extent it is managing investments for a professional client (as defined by the FCA), is required to disclose the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, explain its considered choice based on the Firm’s investment approach. The Code is a voluntary code and sets out a number of principles relating to engagement by investors in UK-listed companies.

Rokos Capital pursues a global macro investment strategy and as such invests across a variety of asset classes and markets globally. Exposure to UK listed issuers as part of that strategy is limited and where such exposure is taken it is not typically through investment directly into individual equities. Therefore, whilst Rokos Capital generally supports the objectives that underlie the Code, the nature of its investment strategy is such that its provisions are not materially relevant. The Firm has therefore chosen not to commit to the Code at this time.