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When issued in or from the UK, the
information contained herein is issued by Wedge Alternatives Ltd
which is authorised and regulated by the Financial Services Authority
(“FSA”). Wedge Alternatives Ltd (and other companies
in the Wedge Alternatives group) market a range of funds all of
which are defined by UK law as “Unregulated Collective Investment
Schemes” (“UCIS”) and the promotion of a UCIS
either within the UK or from the UK is severely restricted by statute.
Consequently, this document is only made available to professional
clients, eligible counterparties and certain other professional
client categories as defined by the FSA. Past performance
of funds should not be seen as an indicator of future performance
and potential investors should note that investing in a UCIS may
carry significant risk.
SEC Registered Broker Dealer - All offerings
to U.S. investors are offered through Wedge Alternatives
LLC, an SEC registered broker-dealer, registered under the Securities
Exchange Act of 1934, and a member of FINRA and SIPC.
FINRA Public Disclosure Program
- FINRA requires that we notify you in writing of the availability
of an investor brochure that includes information describing FINRA’s
Public Disclosure Program. To obtain a brochure or more
information about the program or FINRA, contact the FINRA Public
Disclosure Program Hotline at
(800) 289-9999, or access the FINRA web site at www.finra.org.
Complaints - Any customer
wishing to contact Wedge Alternatives LLC regarding a complaint
should contact the Chief Compliance Officer, Sean O’Brien
at Wedge Alternatives LLC, 500 Fifth Avenue, New York, New York
or call (212) 730-9086.
The USA PATRIOT Act and other applicable regulations
require all financial institutions to obtain, verify and record
information that identifies each person or entity that establishes
a client relationship. We will ask you for your name, address, date
of birth and other information that will allow us to identify you.
We may also ask to see your driver’s license or other identifying
documents.
If you (as an institution) enter into a customer relationship
with Wedge Alternatives LLC and are subject to the definition of
customer as applied to AML rules, we will ask for corporate information
that identifies the name of the entity, its location, offices, types
of firm, regulatory filings and some other particular information.
The firm will then do a non-documentary verification to identify
the existence of the entity.
What happens if I don’t provide the information
requested or my identity can’t be verified? We may not
be able to establish or maintain a business relationship with you.
If you establish a relationship and refuse to provide this information,
we may be required to report this action
to appropriate governmental authorities.
Pursuant to Regulation S-P, Wedge Alternatives LLC
provides the following disclosure in relation to its use and protection
of customer information:
Wedge Alternatives LLC values its relationship with
you and considers your privacy an important priority in maintaining
that relationship. We are committed to protecting the security
and confidentiality of your personal information.
Sources of Information - We collect
nonpublic personal information about you from the following sources:
- Information we receive from you, or your broker-dealer,
investment adviser or financial representative through interviews,
applications, agreements or other forms;
- Information about your transactions with us;
and
- Information we receive from your inquiries by
mail, e-mail or telephone.
Information Collected - The type
of data we collect may include your name, address, social security
number, age, financial status, assets, income, tax information,
retirement and estate plan information, transaction history, account
balance, payment history, investment objectives, marital status,
family relationships and other personal information.
Disclosure of Information - We
do not disclose any nonpublic personal information about our customers
or former customers except as permitted by law. These permitted
uses include the disclosure of such information to unaffiliated
financial service providers and other companies for the following
reasons:
- In order to provide you with services and to
effect transactions in a private placement. We may disclose
your personal information as described above to unaffiliated
financial service providers and other companies that perform
administrative or other services on our behalf, such as transfer
agents, custodians and trustees, or that assist us in the distribution
of investor materials such as trustees, banks, financial representatives,
proxy services, solicitors and printers.
- We may also release such information about you
if you direct us to do so, if we are compelled by law to do
so, or in other legally limited circumstances (for example,
to protect your account from fraud).
Confidentiality and Security - With
regard to our internal security procedures, Wedge Alternatives
LLC, restricts access to your nonpublic personal information to
those Wedge Alternatives LLC employees who need to know that information
to provide products or services to you. We maintain physical,
electronic and procedural safeguards to protect your nonpublic
personal information. For disposal, records are shredded.
Policy Updates and Inquiries - As
required by federal law, we will notify you of our privacy policy
annually. We reserve the right to modify this policy at
any time, however, if we do change it, we will tell you promptly.
For questions about our policy, please contact us at 212 730 9086.
Wedge Alternatives, LLC has developed a Business Continuity
Plan to address how we will respond to events that significantly
disrupt our business. Since the timing and impact of disasters
and disruptions is unpredictable, we will have to be flexible in
responding to actual events as they occur. With that in mind,
we are providing you with this information on our business continuity
plan.
Contacting Us – If after
a significant business disruption you cannot contact us as you
usually do at (212) 730-9086, you should call our alternative
number at Wedge Alternatives Ltd, 33 Lowndes Street, London
SW1X 9HX : (011) 44 20 7245-1400 or go to our web
site at www.wedgealternatives.com.
Our Business Continuity Plan –
We plan to quickly recover and resume business operations after
a significant business disruption and respond by safeguarding
our employees and property, making a financial and operational
assessment, protecting the firm’s books and records, and
allowing our customers to transact business. In short, our
business continuity plan is designed to permit our firm to resume
operations as quickly as possible, given the scope and severity
of the significant business disruption.
Our business continuity plan addresses: data back
up and recovery; all mission critical systems; financial and operational
assessments; alternative communications with customers, employees,
and regulators; alternate physical location of employees; critical
supplier, contractor, and bank impact; regulatory reporting;
and assuring our customers prompt access to their transactional
information if we are unable to continue our business.
Wedge backs up its important records in a geographically
separate area. While every emergency situation poses unique problems
based on external factors, such as time of day and the severity
of the disruption, our objective is to restore operations and
be able to facilitate transactions within 1-5 days.
Varying Disruptions – Significant
business disruptions can vary in scope, affected our firm, a single
building housing our firm, the business district where our firm
is located, the city where we are located, or the whole region.
Within each of these areas, the severity of the disruption can
also vary from minimal to severe. In a disruption to only
our firm or a building housing our firm, we will transfer our
operations to a local site when needed and expect to recover and
resume business within 1-5 days. In a disruption affecting
our business district, city, or region, we will transfer our operations
to a site outside of the affected area, and recover and resume
business within 1-5 days. In either situation, we plan to
continue in business and notify you through our web site.
For more information – If
you have questions about our business continuity planning, you
can contact us at
(212) 730-9086 or email us at sean@wedgealternatives.com
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