INTRODUCTION FROM THE PARTNERS
As part of our overall ethical values, in particular our guiding principle accountability, we are committed to no slavery or human trafficking. 
Therefore, we are looking to improving our practices to combat slavery and human trafficking.

MSA Statement 2017

The BRRD provides resolution authorities with a set of resolution tools and powers which can be used when firms are judged to be failing or likely to fail and use of such resolution tools is necessary in the public interest. The BRRD also introduces strict restrictions on bailouts of bank investors. As such, investors or potential investors must understand that financial instruments subject to the BRRD resolution regime, such as bank issued shares and bonds, are subject to the following risks (this list is not exhaustive) which differ from those arising from ordinary counterparty default or insolvency:

  • the instruments are unsecured and therefore subject to the resolution regime;
  • the impact on investors, in a resolution scenario, depends crucially on the rank of the liability in the resolution creditor hierarchy, which may have changed due to the introduction of depositor preference i.e. investors in unsecured debt instruments may find themselves in a less favourable position compared to holders of deposits when these are eligible for coverage by a national deposit guarantee scheme; 
  • in the event of resolution: 
    • the outstanding amount may be reduced to zero or the security may be converted into ordinary shares or other instruments of ownership for the purpose of stabilisation and loss absorption; 
    • a transfer of assets to a bridge bank or in a sale of business may limit the capacity of the firm to meet repayment obligations; 
    • the key terms of the investment could be amended by the resolution authority, including altering the maturity of instruments or the interest rate under these instruments and suspending the payments for a certain period; 
  • the liquidity of the secondary market in any unsecured debt instruments may be sensitive to changes in financial markets and could become exacerbated in conditions/situations of stress; 
  • existing liquidity arrangements (for example, re-purchase agreements by the issuing institution) might not protect investors from having to sell these instruments at substantial discount below their principal amount, in case of financial distress of the issuing firm; 
  • liability holders have a right to compensation if the treatment they receive in resolution is less favourable than the treatment they would have received under normal insolvency proceedings. This assessment must be based on an independent valuation of the firm. Compensation payments, if any, may be considerably later than contractual payment dates (in the same way that there may be a delay in recovering value in the event of insolvency). 

Consequently, investors could face full write down or partial loss of their investments in resolution.

Should you have any questions in relation to these risks or if you are otherwise unsure about whether your investments may be affected, please contact your Relationship Manager or usual Berenberg contact. 

At Berenberg we value our clients and endeavour to always achieve the highest possible standards in service. However, if you have a complaint, we will do our best to resolve the issue as quickly as possible. Your complaint will be evaluated and, as appropriate, investigated in accordance with our internal complaints handling procedure (for further information, please contact your Relationship Manager). During this process we will also give you the details of the Financial Ombudsman Service - an independent public body whose job is to resolve individual disputes between consumers and businesses fairly, reasonably, quickly and informally. For further information please visit the Financial Ombudsman Service

We recognise that bribery and corruption can undermine the rule of law, democratic processes and basic human freedoms, causing poverty and suffering, inhibiting economic growth, damaging businesses and reputation.
Please see below our policy which sets out our policies and procedures in relation to anti-bribery and corruption and reflects the statutory requirements applicable in the UK as derived from the United Nations and Organisation for Economic Co-operation and Development conventions on corruption.

Anti-Bribery and Corruption Policy

1. General
Berenberg will make any reasonable effort to update the information on its web pages on a regular basis. Despite all care, the data may have changed in the interim. Therefore Berenberg cannot assume either liability or warranty for the provided information being current, correct or comprehensive.

The same applies to all other web pages referenced by any hyperlink. Berenberg is not responsible for the content of any such other page.

Berenberg owns the copyright in all web pages including their layout and contents, except where explicit reference is made to any other provider, producer or trademark owner.

The web pages, their contents or any result generated or displayed through the presentation tools, whether as a whole or in any part, may not be called up, copied, saved, processed or modified for any commercial purpose.

Copyright notices and trademark designations may neither be modified nor be removed. Other or further actions shall require Berenberg’s prior written approval.

The information kept available may be called up only in a manner not impairing the use of the Berenberg online service by other visitors.

2. Stock exchange information
Price and index information is derived from information provided by third parties and has not been verified by Berenberg. Despite due skill and care being exercised in obtaining such information, Berenberg assumes no liability for any information kept available or displayed being correct, comprehensive, or accurate. As for the rest, all and any price and index information is subject to a time delay varying for individual stock exchanges and/or types of securities but as a rule a minimum of 15 minutes.

The index designations “Dow Jones Stoxx 50, Dow Jones Euro Stoxx 50, Dow Jones Industrial Average" are trademarks of Dow Jones & Company Inc.

Recommendations given concerning individual shares shall constitute neither investment advice nor any offer to enter any contract for advice or information. Such recommendations shall serve information purposes only.

The processed information has been derived from sources we regard as reliable, the correctness and comprehensiveness of which however we cannot guarantee in any way. The judgements made in such recommendations reflect the personal appraisal of individual analysts and may be changed at any time without prior notice. Moreover they are based on assumptions underlying continuous change and may therefore subsequently turn out to have been incorrect. Therefore

Berenberg can assume no liability for any direct or indirect damage or loss suffered as a result of using individual statements, estimates and/or projections.

3. Foreign users
The information contained on Berenberg’s web pages is destined exclusively for personal use by individuals domiciled in Germany. Berenberg assumes no liability with regard to whether the information on these web pages may be suitable or usable for any use in any other location. Users accessing these web pages from other locations do so at their own initiative and at their own risk. Berenberg assumes neither warranty nor liability for these web pages or the information contained on them being in compliance with the laws at any such other location.

4. Client Log-in:
Please note that the provided data are subject to certain time delays. As a rule, securities holdings are valued at the closing quotation of the previous day. Account balances as a rule refer to the last accounting cutoff on the previous day and therefore do not reflect the actual current balance.
Newsletter:

By sending off this notice, you agree to your personal data being stored at Berenberg. Berenberg will use such data only for purposes of processing your enquiries and will not transmit them to any third party.

Berenberg takes the protection of your personal data very seriously and abides strictly by the rules of data protection. Under no circumstances will the data collected be forwarded to third parties without the agreement of the persons concerned. The following description provides an overview of how Berenberg guarantees the protection of your data, what type of data is collected, and for what purpose.

Data processing on this website
When you access the website, data are saved on our servers for backup purposes which might possibly allow identification (e.g. IP address, date, time, pages viewed). Apart from the statistical evaluation of data sets that have been made anonymous, no use is made of personal information. We save IP addresses for a period of 28 days. This is done for data security reasons, to ensure the stability and operational reliability of our system. These data are not combined with any other data sources.

Collection, processing and use of personal data
Personal data are only collected on this website to the extent that is technically necessary. In order to send out the newsletter offered on our website and ordered by you, we ask for your name and your e-mail address, using an order form. This information is only saved and used for sending out the newsletter. It is not forwarded to any third parties. When you enter your data (name, e-mail address) in the form, you are agreeing to allow us to store your data and to use it to send out the information requested. The personal data provided by you so that you can receive the newsletter is saved until you cancel the subscription.

Cookies
When you visit our website, we sometimes use cookies which are placed on your computer and which your browser stores. Their purpose is to make what we offer you more user-friendly, effective and safe. Passwords are not saved in cookies. Most of the cookies used by us are what we call "session cookies". Once you have ended your visit, they are automatically reset as soon as you log out. If you end the session by closing your browser, the cookie continues to exist for a while. You can define the length of this period of time by changing the settings on your computer. Afterwards, the cookie is either overwritten or deleted by the client. Our cookies do not cause any harm to your computer and do not contain any viruses. You can block the storage of cookies by setting your browser software accordingly; however, we must point out that, if you do this, you may not be able to make full use of all the functions of this website. 

Web tracking
This website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics uses "cookies", text files that are saved on your computer and which allow us to analyse the use of the website, The information generated by the cookie about your use of this website is generally sent to a Google server in the USA and saved there. Because IP addresses are made anonymous on this website, however, your IP address is abbreviated first by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and abbreviated there. Google will use this information on our behalf to evaluate your use of the website, compile reports about website activities and to provide other services associated with the website use and internet use to us. Google Analytics has informed us that the IP address forwarded from your browser within Google Analytics is not brought together with other data by Google. You can also block the storage of cookies here by setting your browser software accordingly; however, we must point out that, if you do this, you may not be able to make full use of all the functions of this website. In addition, you can block the capture of the data generated by the cookie and relating to your use of the website (including your IP address) at Google and the processing of such data by Google by downloading and installing the browser plugin available under the link:  
You will find further information on the conditions of use and data protection here: Google-Analytics-Terms and here: Google-Analytics-Privacy Overview

Right of information
You have the right at any time to information about your stored personal data, its recipients and the purpose of the data processing. We are also available any time if you have any questions about the processing and use of your personal data. If you require any further information that has not been provided in this data protection declaration, or would like information about the data stored on you, please contact Berenberg's data protection officer at any time: datenschutz@berenberg.de.

In the case of transfers abroad and of separately commissioned express transfers the data contained in the transfer are remitted to the beneficiary's financial institution by the only financial messaging network active worldwide, the Society for Worldwide Interbank Financial Telecommunication (SWIFT) based in Belgium. For reasons of safeguarding the system's reliability SWIFT temporarily saves the transaction data in its data processing centres in the Netherlands and in the US. The motive for this information is a decision by data protection supervisory authorities taken in November 2006 with which these react to access by US authorities to transfer data in the data processing centre of SWIFT in the US for the purpose of combatting international terrorism.

Under the European Bank Recovery and Resolution Directive (BRRD), investors who have acquired bail-in-capable receivables or debt securities (eligible liabilities) may be held liable for the restructuring or liquidation of the repayable institution. This is carried out by converting the value of the receivable or debt instrument into equity or by write-down. An illustration of a potential order of liability (liability cascade) can be found on the BaFin website.

These webpages are issued by Berenberg. The European Market Abuse Regulation (MAR) applies from 3 July 2016 and principally aims to strengthen the fight against market abuse. MAR imposes requirements on certain communications to clients and requires persons disseminating Investment Recommendations to ensure information is objectively presented, and to provide certain disclosures, including any conflicts of interest concerning the financial instruments to which that information relates. You will find the relevant important disclosures here.

Any Investment Recommendation made by Berenberg, or any of its employees or officers is only valid when read or received in conjunction with the disclosures.

The information contained on these webpages is for information only. The recommendations referred to in the webpages are historic in nature and are not, nor shall they be construed as, investment advice by Berenberg under MAR. Berenberg accepts no responsibility and no representation or warranty, express or implied, is made as to the accuracy, reliability or completeness of the source of information on these webpages. To the fullest extent permitted by law, Berenberg accepts no responsibility for and shall have no liability for any loss (including without limitation direct, indirect, consequential and loss of profit), damages, or for any liability to a third party however arising in relation to the information on these webpages. Berenberg has no obligation to update, modify or amend the information. You should not construe the content of any material or disclosures provided on these webpages as legal, financial, tax, accounting or other advice, and you should consider consulting your professional advisors for such advice. Nothing on these webpages shall constitute a bid or offer, or a solicitation of a bid or offer, to initiate or conclude any transaction.

NOTHING IN ANY DISCLOSURE STATEMENT MADE ON THESE WEBPAGES AMENDS OR SUPERSEDES THE EXPRESS TERMS OF ANY TRANSACTION TERMS BETWEEN YOU AND BERENBERG OR ANY RELATED GOVERNING DOCUMENTATION.

The information provided on these webpages is provided on a confidential basis and may not be reproduced, redistributed or transmitted, in whole or in part, without Berenberg’s consent. Any unauthorised use is strictly prohibited.

Joh. Berenberg, Gossler & Co. KG (“Berenberg”) is a Kommanditgesellschaft (a German form of limited partnership) established under the laws of the Federal Republic of Germany registered with the Commercial Register at the Local Court of the City of Hamburg under registration number HRA 42659 with its registered office at Neuer Jungfernstieg 20, 20354 Hamburg, Germany. A list of partners is available for inspection at our London Branch: 60 Threadneedle Street, London EC2R 8HP, United Kingdom.

Joh. Berenberg, Gossler & Co. KG is authorised by the German Federal Financial Supervisory Authority (BaFin) and subject to limited regulation by the Financial Conduct Authority, the firm reference number 222782. Details about the extent of our regulation by the Financial Conduct Authority are available from us on request. For further information as well as specific information on Joh. Berenberg, Gossler & Co. KG, its head office and its foreign branches in the European Union please refer to http://www.berenberg.de/en/corporate-disclosures.html.