MetLife Investment Management Regulatory Disclosures

Regulatory Disclosures

Best Execution Disclosure

Privacy Notices

Remuneration Policy

SFDR  - Incorporation of Sustainability Risks in the Investment Process

SRD II Statement

Strategy for the Exercise of Voting Rights

Best Execution Disclosure

In accordance with the regulatory requirements set out in the Markets in Financial Instruments Directive 2014/65/EU and the Delegated Regulation 2017/565 (“MiFID II”), on an annual basis, MetLife Investment Management Europe Limited (“MIMEL” or the “Company”) is required to summarise and make public, for each class of financial instruments, the top five execution venues in terms of trading volumes where MIMEL executed client orders in the preceding year, as well as information on the quality of the execution obtained.

In accordance with S.I. No. 352/2011 - European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 and the Commission Delegated Regulation (EU) No 231/2013, the Company must also make available appropriate information on its best execution policy to investors in a UCITS or AIF.

This disclosure thus summarises how MIMEL will seek to achieve best execution for its clients when providing investment services to Individual Portfolios or in its management of AIFs and UCITs.

For the purposes of this disclosure, ‘executing’ shall be taken to mean executing orders or placing orders for execution arising from decisions to deal by either MIMEL, a delegate (or sub-delegate) of MIMEL, or the reception and transmission of client orders by MIMEL with other entities for execution.

When the Company is acting as investment manager and decides to deal in financial instruments on behalf of a client and / or when the Company is providing the service of reception and transmission of orders, it must act in accordance with the best interests of the client when placing orders with other entities for execution.

The Company’s clients for the purposes are entities with which it has a segregated mandate, whether a discretionary investment management (“Individual Portfolios”, each being an “Individual Portfolio”) or non-discretionary investment advisory mandate, (collectively hereinafter “MiFID Services Clients”, which receive “MIFID Services”), AIF and UCITS collective investment schemes (“Funds”, each being a “Fund”), such activity also being referred to as collective portfolio management or “CPM”. 

Annual Publication of Data – Top Execution Venues and Execution Quality

MIMEL was authorised on 11 April 2022. In respect of the Individual Portfolios to which it provides investment services, on an annual basis, the Company will summarise and make public, for each class of financial instrument, the top five execution venues in terms of trading volumes where the Company executed client orders in the preceding year, as well as information on the quality of the execution obtained.

As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client, therefore no disclosures are currently available in respect of each class of financial instrument, the top five execution venues in terms of trading volumes where the Company executed client orders in the preceding year, as well as information on the quality of the execution obtained.

The Company will also publish on at least an annual basis and make public, data regarding the quality of execution of transactions in respect of Individual Portfolios, taking into account price, costs, speed, and likelihood of execution for individual financial instruments and provide confirmation of whether MIMEL has executed an average of less than one trade per business day in the previous year in that class of financial instruments.

As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client, therefore such data is not currently available for disclosure.

Scope and Application of Best Execution Requirements

Where it is established that a duty of best execution is owed to a particular client, including the nature of this duty, the obligation to deliver the best possible result when executing client orders applies in relation to all types of “Financial instruments” referenced in Annex I, Section C of Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU (recast) (“MiFID II”). 

However, given the differences in market structures or the structure of financial instruments, it may be difficult to identify and apply a uniform standard of and procedure for best execution that would be valid and effective for all classes of instrument. Best execution obligations will therefore be applied in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of financial instruments.

Order Execution Process and General Execution Factors

The Company has implemented an Order Execution Policy which establishes a process by which the Company, or appointed delegates, will determine the relative importance of the execution factors. The relative importance that the Company gives to those execution factors must be designed to obtain the best possible result for its client. The execution factors include: (i) price; (ii) costs; (iii) speed; (iii) likelihood of execution and settlement; (iv) size; (v) nature; (vi) any other consideration relevant to the execution of a client order.

The Company or delegate ensures that, when determining the relative importance of the above factors, it has regard to the objectives, investment policy and risks specific to a Fund (as indicated in the prospectus or, as the case may be, in the trust deed, deed of constitution or articles of the Fund), or any investment management or advisory agreement with a client.

(i) Price:

The market price at which the order is executed. This is usually the most important Execution Factor, which is therefore often assigned a high weighting for most client activity. This relates to the bid/offer price that is quoted for the value of the transaction to be executed.

(ii) Costs

This represents the cost covering the risks incurred by the Company by entering into a transaction, such as: a) capital requirements; b) liquidity costs; c) cost of hedging our risks resulting from those transactions. Margins and charges will be commensurate with the nature of the market, the characteristics of the transaction and the client. Costs shall also include any additional charges that may be incurred in executing the order in a particular way.

(iii) Speed of execution

In some markets, price volatility may mean that the timeliness of execution is a priority, whereas, in other markets that have low liquidity and high latency it may be necessary to execute your order over a longer period of time. This can be particularly important in fast moving markets.

(iv) Likelihood of execution and settlement

The likelihood that the Company can source adequate liquidity with sufficient depth of market, having necessary credit facilities in place to guarantee settlement, especially for some OTC products where there is no formalised market or settlement infrastructure.

(v) Size and nature of the transaction

Ensuring that orders are executed in a manner which is suitable to the size requested and does not result in an adverse effect on the market. The way the Company executes an unusual order (for example, one that is larger than the normal market size or has unusual features such as an extended or shortened settlement period) may differ from the way the Company executes a standard order.

In certain circumstances (e.g., for some client orders, financial instruments, or markets), the Company’s policy may appropriately determine that other execution factors are more important than price in obtaining the best possible execution result.

Approved Counterparty List and Execution Venues

The MetLife Global Risk Management Department (“GRM”) maintains a complete listing of approved broker/dealers and derivatives counterparties (the “Counterparty Approved List”). All counterparties must be approved in accordance with the MetLife Counterparty Approval and Monitoring Policy. The Counterparty Approved List specifies the types of transactions that can be conducted with each and any special limitations applicable to a counterparty.

In determining whether a particular broker, counterparty or execution venue is likely to provide best execution in a particular transaction, the factors below are taken into account, broken down per applicable asset class.

A list of the execution venues on which the Company places significant reliance for its Individual Portfolios will be published on an annual basis, as described above, or will be disclosed on this website where any material changes occur to the Company’s overarching arrangements to achieve best execution.

As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client, therefore such data is not currently available for disclosure. 

RTS 27 is not applicable as MIMEL is not an execution venue and will not use the output of a consolidated tape provider.

Execution Factors Particular to Equity and Public Fixed Income Securities Transactions

The guiding principle in selecting a counterparty or broker from the Approved Counterparty List for a particular securities transaction is to seek the best possible result for the client, taking into account:

  • the overall costs of the trade (i.e., net price paid or received) including commissions (if applicable), mark-ups, mark-downs or spreads in the context of the trader’s knowledge of current pricing and transaction costs the nature of the market for the security or instrument;
  • the nature of the market for the security or instrument;
  • the size and difficulty of the order; 
  • the execution experience of the counterparty with respect to specific markets or securities;
  • confidentiality
  • the competitiveness of the commission;
  • the certainty of execution;
  • the counterparty’s capital clearance and settlement capabilities;
  • desired timing of the trade;
  • reputation, financial strength, and stability;
  • block trading capabilities;
  • access to underwritten offerings and secondary markets

Execution Factors Particular to Derivatives Transactions

The selection of an execution venue can be contingent on market specific factors, client guidelines and investment strategy/product considerations. Execution venues may include, without limitation: principal traders and market makers (e.g., broker/dealers), multi-lateral trading facilities (including electronic trading platforms), regulated markets or other liquidity providers.

When selecting a counterparty or broker, traders must choose the counterparty or broker from the Approved Counterparty List and ensure that any other criteria agreed with a client have been satisfied.

The guiding principle in executing a derivatives transaction is to take all sufficient steps to achieve the best possible result for the client, with due regard to the factors listed below:

  • price and total costs of trade execution including exchange and clearinghouse fees and costs of collateralisation;the size and complexity of the derivative to be transacted;
  • the size and complexity of the derivative to be transacted;
  • the current market for the derivative instrument, including trading/market-making liquidity and desired timing of the derivative transaction;
  • confidentiality;
  • derivative product and execution venue; and
  • the following factors in relation to counterparties, brokers and execution venues:
    o applicable credit limits of the counterparty or broker with the execution facility;
    o reliability and promptness of trade executions, including the execution experience of the counterparty, broker or execution facility with respect to the derivative instruments to be traded; and
    o reliability of transaction processing and settlement.

Trading OTC derivatives outside a regulated market or multi-lateral trading facility may expose clients / funds to counterparty risk. Counterparty risk exposure is carefully managed by the Company’s risk procedures, including some of the mitigating controls identified above.

Other Assets

Other asset classes such as private debt, real estate and private equity are not “financial instruments” and therefore not within scope of best execution requirements. However, the Company acts in the best interests of its clients and seeks to maximise overall client results in the investment process, taking into account appropriate quantitative and qualitative factors.

Managing Conflicts of Interest

MIMEL takes all appropriate steps to prevent conflicts of interest from constituting or giving rise to a risk of damage to the interests of its clients or investors in its funds. Where the potential risk cannot be prevented, MIMEL must disclose this to its client before providing services.

Trading will be directed to counterparties that are demonstrably able to deliver best execution on a consistent basis, without external influence and no payments, rebates or non-monetary benefits will be derived from these trades.

The Company or its delegates do not have any “soft dollar arrangements.” Soft dollar arrangements are those arrangements in which a broker/dealer provides, or contracts with a third-party vendor to provide, research or other services to an investment advisor in exchange for the investment manager directing transactions to the broker/dealer. The Company or its delegates pay for its own research, where applicable.

MIMEL will conduct periodic monitoring to verify that its best execution arrangements are adequate and working effectively without prejudicing the interests of clients.

Ongoing Monitoring and Review

The Company, and its delegates as applicable, will monitor the execution quality obtained and the quality and appropriateness of its execution arrangements and policies, to identify circumstances under which changes may be appropriate.

MIMEL’s approach to the ongoing monitoring of the adequacy and effectiveness of its execution arrangements is set out in its Order Execution Policy. MIMEL will leverage transaction cost analytics and benchmarking tools, information flows and Committee structures within MIM, in addition to performing periodic testing. MIMEL will report on the outcome within the governance structure at local level.

The Company reviews its Order Execution Policy and framework on an annual basis, or more frequently if a material change occurs that may impact MIMEL’s ability to continue to obtain the best possible execution quality for its client on a consistent basis following the existing arrangements. Any deficiencies identified must be appropriately remediated.

The Company will notify all clients of any material changes to the Company’s execution arrangements or its Order Execution Policy.

Client Consent and Specific Instructions

The Company will obtain the prior consent of applicable clients to its Order Execution Policy. Where relevant, the client will be requested to specifically consent to the provision of information on the Company’s policy via an appropriate website. In this case, the client will be notified electronically of the address of the website, and the place on the website where the information may be accessed.

In addition, the Company will obtain the prior express consent of applicable clients before arranging to execute its orders outside a regulated market or a Multilateral Trading Facility. 

Certain fixed income instruments are listed but may trade off-exchange in a dealer market where more liquidity can be sourced, however this may increase the risk of failure by a dealer to deliver or settle orders.

If the Company or its delegate receives a specific execution instruction from a client, including to use a counterparty with which the client has established a derivatives trading agreement, the investment manager will execute the order in accordance with that specific instruction. Any specific instructions received from clients may prevent the investment manager from taking some or all of the steps (or consider the factors) set forth above in implementing its Order Execution Policy, and, therefore, the investment manager will use best efforts to obtain best execution after giving effect to that client’s instructions in such cases.

Order Execution Policy

A copy of MIMEL’s Order Execution Policy is available upon request.
For any queries, please contact Rory Caldwell (rory.caldwell@metlife.com), or by writing to: 
MetLife Investment Management Europe Limited
20 on Hatch,
Lower Hatch Street,
Dublin 2,
Ireland

 

Privacy Notices

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Europe Limited ("MIM Europe"). We are registered in Ireland and our registered address is 20 on Hatch, Lower Hatch Street, Dublin 2, Ireland.

1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Regulation (EU) 2016/679 (General Data Protection Regulation or the "EU GDPR") and other applicable data protection laws within your EU Member State, we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with the EU GDPR and the applicable data protection laws within your EU Member State. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the EU GDPR. This Privacy Notice is issued on behalf of MIM Europe.

1.2 This Privacy Notice applies to directors, officers and employees of current, prospective and former clients (i.e., entities to which we provide investment management services) ("you", "your" or "data subject"). Investors or potential investors in any UCITS or AIF under the management of MIM Europe are directed to read and understand a separate Privacy Notice issued on behalf of the management body of the relevant UCITS or AIF.

2. PERSONAL DATA THAT WE COLLECT ABOUT YOU

2.1 We will collect and process the following personal data about you:

2.1.1 Information that you provide to us or one of our affiliates. This is information you provide us directly, for example in compliance or onboarding forms, through our website, or through any other forms we may ask you to complete, giving us a business card (or similar) or other means such as correspondence with us, face-to-face discussions, in an email, over the telephone or otherwise. This may include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, social security number or other identification number, signature, occupational history, job title, income, assets, other financial information, bank details, transaction and investment history, tax residency and tax identification information.

2.1.2 Information we collect or generate about you. This is information which we might generate ourselves in relation to you, such as emails (and related data), telephone conversations, website usage data, or other electronic communications with our employees and other staff members, through which our information technology systems may record details of for the purposes of entering into a contract with you. We may also record telephone conversations and communications (e.g. email) with you and your counterparties in relation to actual or potential transactions and client orders, as further outlined in paragraph 3.1.2. This processing will result in personal data, such as the names and contact details of individuals involved or mentioned in those communications, date, time and location of the communication, subject matter of the communication (e.g. potential transaction), being processed.

2.1.3 Information we obtain from third parties or other sources, such as public websites, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies and other public sources and information received from the investor's advisers or from intermediaries. This might include information obtained for the purpose of know-your-client procedures (which include, among other things, anti-money laundering procedures, terrorist financing procedures, Politically Exposed Person checks, and sanctions checks).

3 USES OF YOUR PERSONAL DATA AND LEGAL BASES

3.1 Your personal data may be processed by us for the following purposes. Where we process your personal data in relation to the below purposes, we do so by relying on one of a number of lawful bases under Article 6 EU GDPR, depending on the nature and purposes of processing carried out:

3.1.1 Purpose and Processing Operations: steps taken in order to verify and execute instructions from institutional investors, evidence your authority in relation to investors, general business administration, including liaising with you, communicating with investors, communicating with service providers and counterparties, investment decision-making, reporting, accountancy and audit services, and the administration of IT systems.

Categories of Data: Personal data that you provide directly to us or in connection with our dealings with you. See paragraphs 2.1.1 and 2.1.2 above for further details of the types of personal data we may collect.

Lawful Basis: The lawful basis of such processing is Article 6(1)(b) EU GDPR, namely processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

3.1.2 Purpose and Processing Operations: In order to comply with our obligations under applicable law including the European Union (Markets in Financial Instruments) Regulations 2017, MIM Europe is required to record telephone conversations and electronic communications (e.g. email) with clients and others involved in investment services which relate to transactions and client orders (whether or not such communications result in a transaction or order).

Categories of data: See paragraph 2.1.2 for further details of the types of personal data that we may collect.

Lawful Basis: The lawful basis for such processing is Article 6(1)(c) where such processing is necessary for compliance with an EU legal obligation to which we are subject to which in this case is the European Union (Markets in Financial Instruments) Regulations 2017. Where such processing is to comply with U.S laws or non-EU laws or regulatory obligations or guidance, the lawful basis for such is processing which is necessary for the purposes of our legitimate interests in complying with our legal and regulatory obligations and guidance provided that such interests are not overridden by your interests, fundamental rights and freedoms.

3.1.3 Purpose and Processing Operations: compliance with legal, tax and regulatory obligations and industry standards applicable to an investment management business, including know-your-client procedures, the automatic exchange of tax information and legal judgments.

Categories of Data: Please see paragraphs 2.1.1, 2.1.2 and 2.1.3 above for further details of the types of personal data that we may collect.

Lawful Basis: The lawful basis of such processing is processing which may be necessary to discharge a relevant EEA legal or regulatory obligation to which we are subject, including in order to:

(i) undertake our client and investor due diligence, and on-boarding checks including in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021;

(ii) carry out verification, 'know your client', terrorist financing, sanctions, and anti-money laundering and Politically Exposed Persons checks including in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021;

(iii) verify the identity and addresses of our investors and their directors, officers and employees (and, if applicable, their beneficial owners including under the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019);

(iv) comply with requests from EEA regulatory, governmental, tax and law enforcement authorities;

(v) comply with regulatory requirements applicable to carrying on the activities of fund management, portfolio management, investment advice and reception and transmission of orders, in particular under the European Union (Alternative Investment Fund Managers) Regulations 2013, the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011, and the European Union (Markets in Financial Instruments) Regulations 2017, as well as the Central Bank of Ireland’s AIF Rulebook, guidelines and policy updates issued by the Central Bank of Ireland from time to time;

(vi) maintain statutory registers including in accordance with Companies Act 2014;

(vii) comply with the Market Abuse Regulation (Regulation (EU) 596/2014) and all similar or related legislation applicable to market abuse; and

(viii) comply with EEA legal sanctions requirements.

3.1.4 Purposes: where processing is required to further our commercial interests and manage our risks, including:

(a) risk monitoring;

(b) safeguarding our reputation and integrity;

(c) monitoring and improving products; and

(d) business strategy, development and marketing.

Lawful Basis and Processing Operations: The lawful basis of such processing is processing which is necessary for the purposes of our legitimate interests or those of a third party such as a transaction counterparty or lender, except where such interests are overridden by your interests, fundamental rights and freedoms which require protection of personal data, including:

(i) carrying out the ordinary or reasonable business activities of MIM Europe, or other persons, or other activities previously disclosed to our investors or referred to in this Privacy Notice;

(ii) sending updates, information and notices or otherwise corresponding with you in connection with your investments;

(iii) preventing and detecting fraud;

(iv) monitoring and improving our relationships with investors;

(v) carrying out audit checks and investigations;

(vi) ensuring compliance with legal, tax and regulatory obligations (beyond the EEA) and industry standards;

(vii) assisting our transaction counterparties to comply with their regulatory and legal obligations (including anti-money laundering, 'know your client' and sanctions checks);

(viii) assisting with internal compliance with our policies, processes and record keeping activities;

(ix) seeking professional advice, including legal advice;

(x) complying with requests from regulatory, governmental, tax and law enforcement authorities beyond the EEA;

(xi) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and

(xii) ensuring the security of information systems.

Categories of Data: Personal data that may be processed in connection with the interests and processing operations outlined above including the personal data set out in Section2 including: identification data, contact data, professional information data, services and transactions data, details of instructions given and marketing and communications data.

3.2 Where we process sensitive personal data, including 'special categories of personal data' defined in Article 9(1) EU GDPR, such as any personal data relating to the political opinions of a Politically Exposed Person, or 'personal data relating to criminal convictions and offences' as defined in Article 10(1) EU GDPR, such processing will be necessary for reasons of substantial public interest such as the prevention of fraud, terrorist financing and money laundering.

Generally, we do not rely on your consent as a legal basis for processing your personal data.

3.3 We do not currently carry out third party direct marketing.

4 DISCLOSURE OF YOUR PERSONAL DATA TO OTHERS

4.1 We may from time to time, in accordance with the purposes described above, disclose your personal data to our affiliates, for the purposes of:

4.1.1 direct marketing, such as offers of products and services to you by us or our affiliates. In connection with this, we may share your email, name and other contact details and your marketing preferences. You may prevent this type of sharing by contacting us as described below (see "Contacting Us"). We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. If you are a new investor, we can begin sharing your information thirty (30) days from the date we sent this Privacy Notice. When you are no longer our investor, we may, in accordance with applicable law and our data retention policies, continue to share your information as described in this Privacy Notice. We do not share your information with non-affiliates for them to market to you. We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent.

4.1.2 sanctions screening, adverse media screening and other checks and screening.

4.2 We may also share your personal data with third parties for the following purposes:

4.2.1 to third party agents and contractors for the purposes of providing services to us, including IT and communications service providers, law firms, accountants, auditors, administrators, reference providers, and background check providers. These third parties will be subject to confidentiality requirements and they will only process your personal data as described in this Privacy Notice (or as otherwise notified to you);

4.2.2 to the extent required by law, regulation or court order (for example, if we are under a duty to disclose your personal data in order to comply with any legal obligation);

4.2.3 to establish, exercise or defend our legal rights, property, or the safety of MIM Europe, our customers, or others;

4.2.4 to regulators where we or the regulator may deem appropriate in the context of the regulatory regimes in which it operates;

4.2.5 in connection with investments in, or the sale of, our business or assets or an acquisition of our business by a third party and such data may include the fact that you are a client; and

4.2.6 in connection with telephone and other communications recording, MIM Europe’s affiliates and service providers may process such data and it may disclose such to professional advisors, auditors, affiliates and competent regulatory authorities (e.g. Central Bank of Ireland).

4.3 Some recipients will process your personal data on our behalf as processor. Others will determine the purposes and means of processing of your personal data, acting as separate controllers, and may be permitted to disclose your personal data to other parties in accordance with applicable law.

5. PERSONAL DATA OF THIRD PARTIES

5.1 To the extent that you provide us with personal data of third parties, you agree and acknowledge that you have informed them of, and they have agreed to, our use, collection and disclosure of their personal data including the purposes of such use, collection and disclosure of personal data as set out in this notice.

6. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE EEA

6.1 Your personal data may be transferred to, or stored in, a destination outside the EEA, in countries which may not have similarly strict data protection and privacy laws. It may also be processed by individuals operating outside of the EEA who work for us or for one of our service providers.

6.2 To the extent required by law, where personal data is transferred outside the EEA, we will ensure that our arrangements to transfer such personal data are governed by appropriate safeguards or data transfer agreements, designed to ensure that your personal data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission). When personal data is transferred to the United Kingdom, we rely on an adequacy decision from the European Commission which recognises the UK as ensuring an adequate level of protection for personal data transferred to it. When personal data is transferred to the United States, we rely on Standard Contractual Clauses approved by the European Commission. For a copy of the Standard Contractual Clauses or other safeguards used, please contact MetLifeInvestmentsEUPrivacyChampion@metlife.com.

6.3 Companies outside the EEA with whom we may share your personal data include our other group companies, IT providers and other suppliers.

7. RETENTION OF PERSONAL DATA

7.1 Subject to applicable law, we retain your information for (as the case may be):

7.1.1 as long as it is required for our legitimate purposes;

7.1.2 as long as it is required to perform our contractual obligations;

7.1.3 as long as we have your consent; or

7.1.4 such period as is required or required by law or regulatory obligations which apply to us; and

7.1.5 we will delete or anonymise your personal data when it is no longer required.

8. AUTOMATED DECISION-MAKING (INCLUDING PROFILING)

We do not currently use any processing systems which make decisions and produce legal effects for you, or which may otherwise significantly affect you, based solely on automated processing of your personal data.

9. YOUR RIGHTS

9.1 You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

9.1.1 the right to obtain information regarding the processing of your personal data and access to the personal data that we hold about you;

9.1.2 in some circumstances, the right to receive personal data in a structured, commonly-used and machine-readable format and/or to request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;

9.1.3 the right to request that we rectify your personal data if it is inaccurate or incomplete;

9.1.4 in some circumstances, the right to request that we erase your personal data. Please note that your right to erasure that applies in certain circumstances under the EU GDPR and other applicable data protection laws within your EU Member State is not likely to be available in respect of the personal data we hold, given the purposes for which we collect such data, as described above. Additionally, please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled or required to retain it;

9.1.5 in some circumstances, the right to object to our processing of your personal data. Again, there may be circumstances where you object to our processing of your personal data but we are legally entitled or required to continue processing your personal data;

9.1.6 in some circumstances, the right to request that we restrict our processing of your personal data;

9.1.7 the right not to be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect on you; and

9.1.8 the right to lodge a complaint with the data protection authority (details of which are provided below) if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details set out under "Contacting Us" below. When exercising any of these rights, we may request specific information from you to prove your identity to our satisfaction so that we can safeguard your personal data from unauthorised access by someone impersonating you.

9.3 You can lodge a complaint or find out more information about your rights by contacting your EU Member State's data protection supervisory authority. For a list of these authorities and their contact details, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

9.4 We review and verify data protection rights requests. We apply non-discriminatory principles when we action requests relating to your data, in accordance with applicable data protection laws and principles.

10. CONTACTING US

10.1 If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, or to exercise of any of the rights listed above, please address questions, comments and requests to MetLifeInvestmentsEUPrivacyChampion@metlife.com.

11. UPDATES

We may amend this Privacy Notice from time to time. Any material changes we make to this Privacy Notice in the future will be posted to our website (https://investments.metlife.com/regulatory-disclosures/metlife-investment-management-europe-limited/). This Privacy Notice was last updated on 22 April 2022.

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Europe Limited ("MIM Europe"). We are registered in Ireland and our registered address is 20 on Hatch, Lower Hatch Street, Dublin 2, Ireland.

1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Regulation (EU) 2016/679 (General Data Protection Regulation or the "EU GDPR") and other applicable data protection laws within your EU Member State, we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with the EU GDPR and the applicable data protection laws within your EU Member State. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the EU GDPR. This Privacy Notice is issued on behalf of MIM Europe.  

This Privacy Notice applies to:

1.2.1 visitors to our website: investments.metlife.com (the "website");

1.2.2 visitors to our premises; and

1.2.3 officers, directors, employees, advisors, intermediaries and other representatives of our suppliers, advisers and other service providers,("you", "your" or "data subject").

2. PERSONAL DATA THAT WE COLLECT ABOUT YOU

2.1 We will collect the following personal data about you:

2.1.1 Information that you provide to us or one of our affiliates. This includes information that you provide us directly, through face-to-face discussions, giving us a business card (or similar), during a telephone conversation, through our website or any other means of correspondence, such as email or forms we may ask you to complete.

2.1.2 Information we collect or generate about you. This is information which we might generate ourselves in relation to you, such as emails (and related data), telephone conversations, website usage data, or other electronic communications with our employees and other staff members, through which our information technology systems may record details of for the purposes of entering into a business arrangement with you.

2.1.3 Information that the website collects about you. If you visit the website, it will automatically collect some information about you and your visit, including internet or other network activity such as the internet protocol (IP) address used to connect your device to the internet and some other information such as yourbrowser type and version and the pages on the site that you visit. The sites may also download "cookies" to your device or place cookies onto your browser. For a description of the cookies that we use on the sites, please refer to our separate cookie policy.

2.1.4 Information that our other systems collect about you. If you exchange emails or other communications with us, our information technology systems may record details of those conversations, sometimes including their content. Some of our premises have CCTV systems which may record audio and visual information about you if you visit our premises, for security and safety purposes.

2.1.5 Information collected from other sources. We may collect some information from other sources. For example, if we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.

2.2 Examples of the personal data that we may collect about you:

2.2.1 identifiers: for example, name, postal address, email address, telephone number;

2.2.2 internet or other network activity: for example, browsing or search history, information regarding interaction with the website or related applications or advertisements, as well as online identifiers such as cookies;

2.2.3 professional or work-related information: for example, your professional role, occupational history, business relationship with MIM Europe, and any other personal data which may be incidentally processed if you contact us; and

2.2.4 identification information: information we need in order to identify you and complete necessary security checks if you visit our physical premises.

3. USES OF YOUR PERSONAL DATA

3.1 Your personal data may be processed by us for the following purposes:

3.1.1 Purpose and Processing Operations: to provide you with information, products and services that you request from us.

Categories of Data: Personal data that you provide directly to us or in connection with our dealings with you. See paragraphs 2.1.1, 2.1.2, 2.1.4, 2.1.5, 2.2.1 and 2.2.3 above for details of the types of personal data that we may collect.

Lawful Basis: The lawful bases of such processing are:

(i) Article 6(1)(b) GDPR where the processing is necessary to take steps at your request prior to entering into a contract with you; or

(ii) Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in managing our relationship with you. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights.

3.1.2 Purpose and Processing Operations: to operate, manage, develop and promote our business and, in particular, our business relationship with you or the organisation you represent.

Categories of Data: Personal data that you provide directly to us or in connection with our dealings with you or that we generate about you. See paragraphs 2.1.1, 2.1.2, 2.1.4, 2.1.5, 2.2.1 and 2.2.3.

Lawful Bases: The lawful bases of such processing are:

(i) Article 6(1)(b) GDPR where the processing is necessary to enter into or perform a contract for a product or service with you; or

(ii) Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in managing our relationship with you and your organisation and promoting our business. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights.

3.1.3 Purpose and Processing Operations: to operate, administer and improve our website and premises, including to protect the security of our website and premises.

Categories of Data: Personal data that we may process in connection with this purpose is set out in paragraphs 2.1.2, 2.1.3, 2.1.4, 2.2.2 and 2.2.4.

Lawful Basis: The lawful basis for such processing is Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in improving our website and security and fraud prevention protections in order to safeguard our website, premises and customer data. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights.

3.1.4 Purpose and Processing Operations: to monitor the quality of our products and services.

Categories of Data: Personal data that we may collect in connection with this purpose is set out in paragraphs 2.1.1, 2.1.2, 2.1.3 and 2.2.2.

Lawful Basis: The lawful basis for such processing is Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in monitoring and improving the quality of our products and services and in carrying out market research, to develop predictive and analytical models concerning products and services and data insights. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights

3.1.5 Purpose and Processing Operations: to train our staff. In connection with this, we may record or otherwise process your calls and other interactions with us for training purposes.

Categories of Data: Personal data that we may process in connection with this purpose is set out in paragraphs 2.1.1, 2.1.2, 2.1.4, 2.2.1 and 2.2.3.

Lawful Basis: The lawful basis for such processing is Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in training our staff, measuring our performance, creating efficiencies in our business and delivering organisational benefits. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights.

3.1.6 Purpose and Processing Operations: to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes.

Categories of Data: Personal data that we may process in connection with this purpose is set out in paragraphs 2.1.1, 2.1.2, 2.1.3, 2.1.4, 2.1.5, 2.2.1, 2.2.2, 2.2.3 and 2.2.4.

Lawful Bases: The lawful bases for such processing is:

(i) Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in protecting our business from fraud, any breach of confidentiality or misappropriation of our intellectual property, confidential information or other assets and protecting and vindicating our legal rights and ensuring compliance with our legal obligations. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights; or

(ii) Article 6(1)(c) GDPR namely the processing is necessary to discharge a relevant legal or regulatory obligation to which we are subject including under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021.

3.1.7 Purpose and Processing Operations: to confirm your identity and to comply with our legal and regulatory obligations and bring and defend civil, regulatory and criminal claims or respond to queries and other lawful requests received from regulatory authorities, law enforcement and other governmental agencies such as the Central Bank of Ireland.

Categories of Data: Personal data that we may process in connection with this purpose is set out in paragraphs 2.1.1, 2.1.4, 2.1.5 and 2.2.4.

Lawful Bases: The lawful bases for such processing is:

(i) Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in protecting our business from fraud, complying with our legal and regulatory obligations, co-operating with and responding to requests and investigations from regulatory authorities, law enforcement and other governmental agencies and protecting and vindicating our legal rights. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights; or

(ii) Article 6(1)(c) GDPR namely the processing is necessary to discharge a relevant legal or regulatory obligation to which we are subjectincluding under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019, the Companies Act 2014, European Union (Alternative Investment Fund Managers) Regulations 2013, the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011, the European Union (Markets in Financial Instruments) Regulations 2017, as well as the Central Bank of Ireland’s AIF Rulebook, guidelines and policy updates issued by the Central Bank of Ireland from time to time.

3.1.8 Purpose and Processing Operations: to investigate any complaint you may make.

Categories of Data: Personal data that we may process in connection with this purpose may include that set out in paragraphs 2.1.1, 2.1.2, 2.1.4, 2.1.5 and 2.2.3.

Lawful Bases: The lawful basis for such processing is Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in investigating and resolving complaints. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights. We may also be required to address a complaint as a matter of law (including under the European Union (Alternative Investment Fund Managers) Regulations 2013, the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011, the European Union (Markets in Financial Instruments) Regulations 2017 and any such processing will be based on Article 6(1)(c) GDPR as is necessary for compliance with a legal obligation;

3.1.9 Purpose and Processing Operations: to provide evidence in any dispute or anticipated dispute between you and us.

Categories of Data: Personal data that we may process in connection with this purpose may include that set out in paragraphs 2.1.1, 2.1.2, 2.1.4 and 2.1.5 and any other personal data that may be relevant to the dispute.

Lawful Basis: The lawful basis for such processing is Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in providing information or evidence as part of legal and/or regulatory investigations, proceedings or processes and to comply with orders made in the context of civil or criminal proceedings. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights.

3.1.10 Purpose and Processing Operations: Unless you have opted-out, we will use relevant personal data to enable us to provide you with information about products and services that may be of interest to the organisation you work for, represent, or similar.

Categories of data: Personal data processed may include your contact details and marketing preferences.

Lawful Basis: The lawful basis for such processing is Article 6(1)(f) GDPR where the processing is necessary on the basis of our legitimate interests in promoting our business and its products and services. In doing so, we will consider your interests and ensure that our interests are not overridden by yours and that there is a fair balance between our legitimate interests and your fundamental rights.

3.2 Where you use our website, we will process your personal data collected by using cookies in accordance with our cookie policy.

4. DISCLOSURE OF YOUR PERSONAL DATA TO OTHERS

4.1 We may share your personal data with affiliates or third parties for the following purposes:

4.1.1 the other members of the MetLife group of companies;

4.1.2 third party agents and contractors, including IT and communications service providers, law firms, accountants, auditors, and administrators. These third parties will be subject to confidentiality requirements and they will only process your personal data as described in this notice (or as otherwise notified to you);

4.1.3 governmental, judicial, or prosecution bodies, tax authorities, regulators and courts;

4.1.4 third parties for the purposes of establishing, exercising or defending our legal rights;

4.1.5 third parties in connection with investments in, or the sale of, our business or assets or an acquisition of our business (or a part of our business) by a third party; and

4.1.6 your colleagues within the organisation that you represent.

4.2 Some recipients will process your personal data on our behalf as processor. Others will determine the purposes and means of processing of your personal data, acting as separate controllers, and may be permitted to disclose your personal data to other parties in accordance with applicable law.

4.3 You should be aware that when you are on the website, you could be directed to other websites that are beyond our control. Our website may contain links to other websites operated by third parties. We cannot guarantee that the privacy policies of these third parties meet our standards. You should read the privacy notice of any new website you visit.

5. PERSONAL DATA OF THIRD PARTIES

5.1 To the extent that you provide us with personal data of third parties, you agree and acknowledge that you have informed them of, and they have agreed to, our use, collection and disclosure of their personal data including the purposes of such use, collection and disclosure of personal data as set out in this notice.

6. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE EEA

6.1 Your personal data may be transferred to, or stored in, a destination outside the EEA, in countries which may not have similarly strict data protection and privacy laws. It may also be processed by individuals operating outside of the EEA who work for us or for one of our service providers.

6.2 To the extent required by law, where personal data is transferred outside the EEA, we will ensure that our arrangements to transfer such personal data are governed by appropriate safeguards or data transfer agreements, designed to ensure that your personal data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission).

6.3 We will ensure that any such transfers are carried out in compliance with applicable law, including, where necessary, being governed by data transfer agreements (such as the European Commission approved Standard Contractual Clauses) designed to ensure that your personal data is protected on terms approved for this purpose by the European Commission or as otherwise required under EU GDPR, including that appropriate safeguards are implemented. When personal data is transferred to the United Kingdom, we rely on an adequacy decision from the European Commission which recognises the UK as ensuring an adequate level of protection for personal data transferred to it. When personal data is transferred to the United Kingdom, we rely on an adequacy decision from the European Commission which recognises the UK as ensuring an adequate level of protection for personal data transferred to it. When personal data is transferred to the United States, we rely on Standard Contractual Clauses approved by the European Commission. If you want to request a copy of any such agreements or information about the safeguards used, please contact us using the details set out in "Contacting Us" below.

7. RETENTION OF PERSONAL DATA

7.1 Subject to applicable law, we retain your information for (as the case may be):

7.1.1 as long as it is required for our legitimate purpose;

7.1.2 as long as it is required to perform our contractual obligations;

7.1.3 as long as we have your consent; or

7.1.4 such period as is required or required by law or regulatory obligations which apply to us; and

7.1.5 we will delete or anonymise your personal data when it is no longer required.

8. AUTOMATED DECISION-MAKING (INCLUDING PROFILING)

We do not currently use any processing systems which make decisions and produce legal effects for you, or which may otherwise significantly affect you, based solely on automated processing of your personal data.

9. YOUR RIGHTS

9.1 You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

9.1.1 the right to obtain information regarding the processing of your personal data and access to the personal data that we hold about you; in some circumstances, the right to receive personal data in a structured, commonly-used and machine-readable format and/or to request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;

9.1.2 the right to request that we rectify your personal data if it is inaccurate or incomplete;

9.1.3 in some circumstances, the right to request that we erase your personal data. Please note that your right to erasure that applies in certain circumstances under the EU GDPR is not likely to be available in respect of the personal data we hold, given the purposes for which we collect such data, as described above. Additionally, please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled or required to retain it;

9.1.4 in some circumstances, the right to object to our processing of your personal data. Again, there may be circumstances where you object to our processing of your personal data, but we are legally entitled or required to continue processing your personal data;

9.1.5 in some circumstances, the right to request that we restrict our processing of your personal data;

9.1.6 the right not to be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect on you; and

9.1.7 the right to lodge a complaint with the data protection authority (details of which are provided below) if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details set out under "Contacting Us" below. When exercising any of these rights, we may request specific information from you to prove your identity to our satisfaction so that we can safeguard your personal data from unauthorised access by someone impersonating you.

9.3 You can lodge a complaint or find out more information about your rights by contacting your EU Member State's data protection supervisory authority. For a list of these authorities and their contact details, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

9.4 We review and verify data protection rights requests.

We apply non-discriminatory principles when we action requests relating to your data, in accordance with applicable data protection laws and principles.

9.5 If you do not want MIM Europe to send you e-mail or postal mail, you can opt out at any time by contacting MIM Europe by e-mail at MetLifeInvestmentsEUPrivacyChampion@metlife.com.

10. CONTACTING YOU

10.1 We may contact you through one or more of the following communications channels: by telephone, mail, email, text (SMS) message, instant messaging or other electronic means.

10.2 We record some telephone calls and other electronic communications for regulatory reasons and for audit purposes. We store call and other communication recordings securely in accordance with our retention policies and applicable data protection laws. Access to those recordings is restricted to those individuals who have a need to access them for the purposes set out in this notice.

11. CONTACTING US

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, or to exercise of any of the rights listed above, please address questions, comments and requests to MetLifeInvestmentsEUPrivacyChampion@metlife.com.

12. UPDATES

We may amend this Privacy Notice from time to time. Any material changes we make to this Privacy Notice in the future will be posted to our website (https://investments.metlife.com/regulatory-disclosures/metlife-investment-management-europe-limited/). This Privacy Notice was last updated on 22 April 2022.

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Europe Limited ("MIM Europe"). We are registered in Ireland and our registered address is 20 on Hatch, Lower Hatch Street, Dublin 2, Ireland.

1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Regulation (EU) 2016/679 (General Data Protection Regulation or the "EU GDPR") and other applicable data protection laws within your EU Member State, we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with the EU GDPR and the applicable data protection laws within your EU Member State. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the EU GDPR. This Privacy Notice is issued on behalf of MIM Europe. We use the term “investee” to refer to projects, businesses or organizations to which we make or arrange an investment or provide financing.

1.2 This Privacy Notice applies to directors, officers, employees and beneficial owners of current, prospective and former investees ("you", "your" or "data subject").

2. PERSONAL DATA THAT WE COLLECT ABOUT YOU

2.1 We will collect and process the following personal data about you:

2.1.1 Information that you provide to us or one of our affiliates. This is information you provide us directly, for example in compliance or onboarding forms, through our website, or through any other forms we may ask you to complete, giving us a business card (or similar) or other means such as correspondence with us, face-to-face discussions, in an email, over the telephone or otherwise. This may include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, social security number or other identification number, signature, occupational history, job title, income, assets, other financial information, bank details, transaction and investment history, tax residency and tax identification information.

2.1.2 Information we collect or generate about you. This is information which we might generate ourselves in relation to you, such as emails (and related data), telephone conversations, website usage data, or other electronic communications with our employees and other staff members, through which our information technology systems may record details of for the purposes of entering into a contract with you. We may also record telephone conversations and communications (e.g. email) with you and your counterparties in relation to actual or potential transactions and client orders, as further outlined in paragraph 3.1.2. This processing will result in personal data, such as the names and contact details of individuals involved or mentioned in those communications, date, time and location of the communication, subject matter of the communication (e.g. potential transaction), being processed.

2.1.3 Information we obtain from third parties or other sources, such as public websites, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies and other public sources and information received from the investee's advisers or from intermediaries. This might include information obtained for the purpose of know-your-client procedures (which include, among other things, anti-money laundering procedures, terrorist financing procedures, Politically Exposed Persons checks, and sanctions checks).

3. USES OF YOUR PERSONAL DATA AND LEGAL BASES

3.1 Your personal data may be processed by us for the following purposes. Where we process your personal data in relation to the below purposes, we do so by relying on one of a number of lawful bases under Article 6 EU GDPR, depending on the nature and purposes of processing carried out:

3.1.1 Purpose and Processing Operations: steps taken in order to: verify and execute instructions from you or your organization; evidence your authority in relation to your organization; or administer our business, including liaising with you, communicating with investees, communicating with service providers and transactional counterparties, making investment decisions, receiving accountancy and audit services, and the administration of IT systems.

Categories of Data: Personal data that you provide directly to us or in connection with our dealings with you. See paragraphs 2.1.1 and 2.1.2 above for further details of the types of personal data we may collect.

Lawful Basis: The lawful basis of such processing is Article 6(1)(f) EU GDPR, namely processing which is necessary for the purposes of our legitimate interests or those of a third party except where such interests are overridden by your interests, fundamental rights and freedoms which require protection of personal data. Such interests include:

(a) ensuring compliance with legal, tax and regulatory obligations and industry standards;

(b) carrying out business and managing risk;

(c) ensuring that we do not accept the proceeds of criminal activities or assist in fraudulent or other unlawful activities; and

(d) operating our business including receiving professional services and IT services.

3.1.2 Purposes and Processing Operations: compliance with legal, tax and regulatory obligations and industry standards applicable to investment or financing transactions, including know-your-client procedures, the automatic exchange of tax information and legal judgments.

Categories of Data: Please see paragraphs 2.1.1, 2.1.2 and 2.1.3 above for further details of the types of personal data that we may collect.

Lawful Basis: The lawful basis of such processing is processing which may be necessary to discharge a relevant EEA legal or regulatory obligation to which we are subject, including in order to:

(i) undertake our client and investee due diligence, and on-boarding checks including in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021;

(ii) carry out verification, 'know your client', terrorist financing, sanctions, and anti-money laundering and Politically Exposed Persons checks including in accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021;

(iii) verify the identity and addresses of our investees and their directors, officers and employees (and, if applicable, their beneficial owners including under the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019);

(iv) comply with requests from EEA regulatory, governmental, tax and law enforcement authorities;

(v) comply with regulatory requirements applicable to carrying on the activities of fund management, portfolio management, investment advice and reception and transmission of orders, in particular under the European Union (Alternative Investment Fund Managers) Regulations 2013, the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011, and the European Union (Markets in Financial Instruments) Regulations 2017, as well as the Central Bank of Ireland’s AIF Rulebook, guidelines and policy updates issued by the Central Bank of Ireland from time to time;

(vi) maintain statutory registers including in accordance with the Companies Act 2014;(vii) comply with the Market Abuse Regulation (Regulation (EU) 596/2014) and all similar or related legislation applicable to market abuse; and

(viii) comply with EEA legal sanctions requirements.

 3.1.3 Purposes: where processing is required to further our commercial interests and manage our risks, including:

(a) risk monitoring;

(b) safeguarding our reputation and integrity;

(c) monitoring and improving products; and(d) business strategy, development and marketing.

Lawful Basis and Processing Operations: The lawful basis of such processing is processing which is necessary for the purposes of our legitimate interests orthose of a third party such as a transaction counterparty or lender, except where such interests are overridden by your interests, fundamental rights and freedoms which require protection of personal data, including:

(i) carrying out the ordinary or reasonable business activities of MIM Europe or other persons, or other activities previously disclosed to investees or referred to in this Privacy Notice;

(ii) sending updates, information and notices or otherwise corresponding with you in connection with funding and investments;

(iii) preventing and detecting fraud;

(iv) monitoring and improving our relationships with investees;

(v) carrying out audit checks and investigations;

(vi) ensuring compliance with legal, tax and regulatory obligations (beyond the EEA) and industry standards;

(vii) assisting our transaction counterparties to comply with their regulatory and legal obligations (including anti-money laundering, 'know your client' and sanctions checks);

(viii) assisting with internal compliance with our policies, processes and record keeping activities;

(ix) seeking professional advice, including legal advice;

(x) complying with requests from regulatory, governmental, tax and law enforcement authorities beyond the EEA;

(xi) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and

(xii) ensuring the security of information systems.

Categories of Data: Personal data that may be processed in connection with the interests and processing operations outlined above including the personal data set out in Section 2 including: identification data, contact data, professional information data, services and transactions data, details of instructions given and marketing and communications data.

3.2 Where we process sensitive personal data, including 'special categories of personal data' defined in Article 9(1) EU GDPR, such as any personal data relating to the political opinions of a Politically Exposed Person, or 'personal data relating to criminal convictions and offences' as defined in Article 10(1) EU GDPR, such processing will be necessary for reasons of substantial public interest such as the prevention of fraud, terrorist financing and money laundering.

3.3 Generally, we do not rely on your consent as a legal basis for processing your personal data.

3.4 We do not currently carry out third party direct marketi

4. DISCLOSURE OF YOUR PERSONAL DATA TO OTHERS

4.1 We may from time to time, in accordance with the purposes described above, disclose your personal data to our affiliates, for the purposes of:

4.1.1 direct marketing, such as offers of products and services to you by us or our affiliates. In connection with this, we may share your email, name and other contact details and your marketing preferences. You may prevent this type of sharing by contacting us as described below (see "Contacting Us"). We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. If you are a new investee, we can begin sharing your information thirty (30) days from the date we sent this Privacy Notice. When you are no longer our investee, we may, in accordance with applicable law and our data retention policies, continue to share your information as described in this Privacy Notice. We do not share your information with non-affiliates for them to market to you. We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent; and

4.1.2 sanctions screening, adverse media screening and other checks and screening.

4.2 We may also share your personal data with third parties for the following purposes:

4.2.1 to third party agents and contractors for the purposes of providing services to us, including IT and communications service providers, law firms, accountants, auditors, administrators, investment managers, reference providers, and background check providers. These third parties will be subject to confidentiality requirements and they will only process your personal data as described in this Privacy Notice (or as otherwise notified to you);

4.2.2 to the extent required by law, regulation or court order (for example, if we are under a duty to disclose your personal data in order to comply with any legal obligation);

4.2.3 to establish, exercise or defend our legal rights, property, or the safety of MIM Europe, our customers or others;

4.2.4 to regulators, where we or the regulator may deem it appropriate in the context of the regulatory regime; and

4.2.5 in connection with investments in, or the sale of, our business or assets or an acquisition of our business by a third party and such data may include the fact that you are a client.

4.3 Some recipients will process your personal data on our behalf as processor. Others will determine the purposes and means of processing of your personal data, acting as separate controllers, and may be permitted to disclose your personal data to other parties in accordance with applicable law.

5. PERSONAL DATA OF THIRD PARTIES

5.1 To the extent that you provide us with personal data of third parties, you agree and acknowledge that you have informed them of, and they have agreed to, our use, collection and disclosure of their personal data including the purposes of such use, collection and disclosure of personal data as set out in this notice.

6. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE EEA

6.1 Your personal data may be transferred to, or stored in, a destination outside the EEA in countries which may not have similarly strict data protection and privacy laws. It may also be processed by individuals operating outside of the EEA who work for us or for one of our service providers.

6.2 To the extent required by law, where personal data is transferred outside the EEA, we will ensure that our arrangements to transfer such personal data are governed by appropriate safeguards or data transfer agreements, designed to ensure that your personal data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission). When personal data is transferred to the United Kingdom, we rely on an adequacy decision from the European Commission which recognises the UK as ensuring an adequate level of protection for personal data transferred to it. When personal data is transferred to the United States, we rely on Standard Contractual Clauses approved by the European Commission. For a copy of the Standard Contractual Clauses or other safeguards used, please contact MetLifeInvestmentsEUPrivacyChampion@metlife.com.

7. RETENTION OF PERSONAL DATA

We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations or such period as is required or permitted by law or regulatory obligations which apply to us. We will generally retain personal data about you throughout the life cycle of any funding we have provided or arranged and may retain some personal data after your relationship with us ends.

8. AUTOMATED DECISION-MAKING (INCLUDING PROFILING)

We do not currently use any processing systems which make decisions and produce legal effects for you, or which may otherwise significantly affect you, based solely on automated processing of your personal data.

9. YOUR RIGHTS

9.1 You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

9.1.1 the right to obtain information regarding the processing of your personal data and access to the personal data that we hold about you;

9.1.2 in some circumstances, the right to receive personal data in a structured, commonly-used and machine-readable format and/or to request that we transmitthat data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;

9.1.3 the right to request that we rectify your personal data if it is inaccurate or incomplete;

9.1.4 in some circumstances, the right to request that we erase your personal data. Please note that your right to erasure that applies in certain circumstances under the EU GDPR and other applicable data protection laws within your EU Member State is not likely to be available in respect of the personal data we hold, given the purposes for which we collect such data, as described above. Additionally, please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled or required to retain it;

9.1.5 in some circumstances, the right to object to our processing of your personal data. Again, there may be circumstances where you object to our processing of your personal data but we are legally entitled or required to continue processing your personal data;

9.1.6 in some circumstances, the right to request that we restrict our processing of your personal data;

9.1.7 the right not to be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect on you; and9.1.8 the right to lodge a complaint with the data protection authority (details of which are provided below) if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details set out under "Contacting Us" below. When exercising any of these rights, we may request specific information from you to prove your identity to our satisfaction so that we can safeguard your personal data from unauthorized access by someone impersonating you.

9.3 You can lodge a complaint or find out more information about your rights by contacting your EU Member State's data protection supervisory authority. For a list of these authorities and their contact details, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

10. CONTACTING US

10.1 If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, or to exercise of any of the rights listed above, please address questions, comments and requests to MetLifeInvestmentsEUPrivacyChampion@metlife.com.

11. UPDATES

We may amend this Privacy Notice from time to time. Any material changes we make to this Privacy Notice in the future will be posted to our website (https://investments.metlife.com/regulatory-disclosures/metlife-investment-management-europe-limited/). This Privacy Notice was last updated on 22 April 2022]