MetLife Investment Management Limited

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MetLife Investment Management Limited

Best Execution Disclosure

Privacy Notices

UK Stewardship Code Disclosure Statement

Pillar 3 Disclosure

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 Limited (“MIML”) has a requirement to summarise and make public, for each class of financial instrument, the top five execution venues in terms of trading volumes where MIML executed client orders in the preceding year, as well as information on the quality of the execution obtained.

This report summarises how MIML seeks to achieve best execution for its clients and includes the following information:

1. volume of client orders executed on that execution venue expressed as a percentage of total executed volume;

2. number of client orders executed on that execution venue expressed as a percentage of total executed orders;

3. confirmation of whether MIML has executed an average of less than one trade per business day in the previous year in that class of financial instruments.

This report also explains the critical factors affecting the approach to client order execution and the relative importance that MIML gives to these critical execution factors.

 

Information on the top five execution venues and quality of execution obtained

Class of Instrument EUR & GBP denominated public bonds   
Notification if <1 average trade per business day in the previous year YES

 

                        
Proportion of volume traded as a percentage of total in that class   Proportion of orders executed as percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
Name and Venue Identifier (MIC or LEI) Goldman Sachs International W22LROWP2IHZNBB6K528 52% n/a n/a n/a
Name and Venue Identifier (MIC or LEI) HSBC Bank plc MP6I5ZYZBEU3UXPYFY54 11% n/a n/a n/a
Name and Venue Identifier (MIC or LEI) Credit Agricole CIB 1VUV7VQFKUOQSJ21A208 8% n/a n/a n/a
Name and Venue Identifier (MIC or LEI) JP Morgan Securities PLC K6Q0W1PS1L1O4IQL9C32 6% n/a n/a n/a
Name and Venue Identifier (MIC or LEI) ING Bank London Branch 3TK20IVIUJ8J3ZU0QE75 6% n/a n/a n/a

 

For all trades, price has been the most important factor when determining with which counterparty to trade, followed by ability of the counterparty to settle on time and in line with our requirements.

There have been no conflicts of interest with respect to any execution venues used. MIML 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. Where the potential risk cannot be prevented,MIML must disclose this to its client before providing services. A copy of MIML’s Conflicts of Interest Policy is available upon request.

Our trading has been directed to counterparties able to provide us with the best execution for our clients, without external influence and no payments, rebates or non-monetary benefits have been derived from these trades.

There have been no changes to the list of execution venues.

There is no differentiation in client treatment.

RTS 27 is not applicable as we are not an execution venue, and we have not used output of a consolidated tape provider.

MIML’s approach to monitoring its execution arrangements is set out in its Order Execution Policy.

A copy of MIML’s Order Execution Policy is available upon request.

For any queries, please feel free to contact Lisa Gray

(lisa.l.gray@metlife.com or +1 973 355 4021) or by writing to:

MetLife Investment Management Limited
1 Angel Lane, 8th Floor
London
EC4R 3AB

 

Privacy Notices

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Limited ("MetLife"). We are registered in England and our registered address is Level 34, One Canada Square, Canary Wharf, London, England, E14 5AA. Our EU Representative is MetLife Investment Management Europe Limited.

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 MetLife Investment Management Limited and its affiliates. The name of the specific MetLife entity that processes your personal data will depend on the type of investment management services you receive.

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").

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[1]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.

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[1]money laundering procedures, terrorist financing procedures, Politically Exposed Person checks, and sanctions checks).

2.2 We do not hold special categories of personal data about you. This includes types of personal data which might show a person’s race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, details about their health and any genetic or biometric data.

3. USES OF YOUR PERSONAL DATA

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 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, accountancy and audit services, and the administration of IT systems.
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  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.
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;
(ii) carry out verification, 'know your client', terrorist financing, sanctions, and anti-money laundering and Politically Exposed Persons checks;
(iii) verify the identity and addresses of our investors and their directors, officers and employees (and, if applicable, their beneficial owners);
(iv) comply with requests from EEA regulatory, governmental, tax and law enforcement authorities;
(v) maintain statutory registers; and
(vi) comply with EEA legal sanctions requirements.

3.1.3 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.

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 MetLife, 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.

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 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. 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. 

4.2 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 MetLife, 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; 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.

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 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).

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[1]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/board/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 MIMLPrivacyChampion@metlife.com.

10.2 Our EU Representative may likewise be contacted at 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-limited/). This Privacy Notice was last updated on 20 September 2021

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Limited ("MetLife"). We are registered in England and our registered address is Level 34, One Canada Square, Canary Wharf, London, England, E14 5AA. Our EU Representative is MetLife Investment Management Europe Limited.

1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Regulation (EU) 2016/679 (General Data Protection 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 MetLife Investment Management Limited and its affiliates. The name of the specific MetLife entity that processes your personal data will depend on the particular entity providing or arranging financing with respect to your organization. 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 and employees 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.

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

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 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.

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 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.

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;
(ii) carry out verification, 'know your client', terrorist financing, sanctions, and anti-money laundering and Politically Exposed Persons checks;
(iii) verify the identity and addresses of our investees and their directors, officers and employees (and, if applicable, their beneficial owners);
(iv) comply with requests from EEA regulatory, governmental, tax and law enforcement authorities;
(v) maintain statutory registers; and
(vi) comply with EEA legal sanctions requirements.   

3.1.3 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.

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 MetLife 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 your funding;(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. 

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 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. 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.

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 MetLife, our customers or others;

4.2.4 to regulators (including but not limited to the Financial Conduct Authority in the UK) 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.

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 and may be permitted to disclose your personal data to other parties in accordance with applicable law.

5. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE EEA

5.1 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.

5.2 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. 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.

7. 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.

8. YOUR RIGHTS

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

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

8.1.2 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;

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

8.1.4 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 6 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;

8.1.5 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;

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

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

8.1.8 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. 

8.2 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.

8.3 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/board/members_en

9. CONTACTING US

9.1 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 MIMLPrivacyChampion@metlife.com.

9.2 Our EU Representative may be contacted at MetLifeInvestmentsEUPrivacyChampion@metlife.com.

10. UPDATES

We may amend this Privacy Notice from time to time. Any 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-limited/). This Privacy Notice was last updated on 20 September 2021.

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Limited ("MetLife"). We are registered in England and our registered address is Level 34, One Canada Square, Canary Wharf, London, England, E14 5AA.

1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 No. 419 ("UK GDPR") and the Data Protection Act, 2018 ("DPA", together "Applicable Data Protection Laws"), we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with Applicable Data Protection Laws. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the UK GDPR. This Privacy Notice is issued on behalf of MetLife Investment Management Limited and its affiliates.

1.2 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 your browser 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 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 MetLife, 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 to provide you with information, products and services that you request from us;

3.1.2 to operate, manage, develop and promote our business and, in particular, our business relationship with you or the organisation you represent;

3.1.3 to operate, administer and improve our website and premises, including to protect the security of our website and premises;

3.1.4 to monitor the quality of our products and services;

3.1.5 to train our staff;

3.1.6 to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;

3.1.7 to confirm your identity and to comply with our legal and regulatory obligations and bring and defend civil, regulatory and criminal claims;

3.1.8 to investigate any complaint you may make;

3.1.9 to provide evidence in any dispute or anticipated dispute between you and us; and

3.1.10 where you have given us your permission to do so, 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.

3.2 Where we process your personal data in relation to the above purposes, we do so by relying on one of a number of lawful bases under Article 6 UK GDPR, depending on the nature and purposes of processing carried out. Our basis for processing may include:

3.2.1 Pursuing our legitimate interest or those of a third party. The lawful basis of such processing is Article 6(1)(f) of the UK GDPR, namely the processing 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;

3.2.2 Complying with legal obligations. The lawful basis of such processing is Article 6(1)(c) of the UK GDPR, namely the processing is necessary to discharge a relevant legal or regulatory obligation to which we are subject; and

3.2.3 Performance of a contract. The lawful basis of such processing is Article 6(1)(b) UK GDPR, namely the 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.

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

3.4 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 as controller and may be permitted to disclose your personal data to other parties in accordance with applicable law.

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 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 UK AND EEA

6.1 Your personal data may be transferred to, or stored in, a destination outside the UK in countries which may not have similarly strict data protection and privacy laws. It may also be processed by individuals operating outside of the UK 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 UK, 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 relevant authority in the UK).

6.3 The disclosures described above may involve transferring your personal data overseas. If you are dealing with us within the UK, you should be aware that we may transfer your data outside of the UK. Some of these countries do not have similarly strict data privacy laws. Equally, if you are dealing with us within the EEA you should be aware that this may include transfers to countries outside the EEA, including the UK.

6.4 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 model clauses) designed to ensure that your personal data is protected on terms approved for this purpose by the ICO or as otherwise required under Applicable Data Protection Laws. If you want to request a copy of any such agreements, 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 Applicable Data Protection Laws 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 the UK's Information Commissioner's Office, or by searching its website at https://ico.org.uk.

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 MetLife to send you e-mail or postal mail, you can opt out at any time by contacting MetLife by e-mail at MIMLPrivacyChampion @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 MIMLPrivacyChamption@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-limited/). This Privacy Notice was last updated on 20 September 2021.

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Limited ("MetLife"). We are registered in England and our registered address is Level 34, One Canada Square, Canary Wharf, London, England, E14 5AA.

 1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 No. 419 ("UK GDPR") and the Data Protection Act, 2018 ("DPA", together "Applicable Data Protection Laws"), we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with Applicable Data Protection Laws. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the UK GDPR. This Privacy Notice is issued on behalf of MetLife Investment Management Limited and its affiliates. The name of the specific MetLife entity that processes your personal data will depend on the particular entity providing or arranging financing with respect to your organization. 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 and employees 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.

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 your advisers or other intermediaries. This might include information obtained for the purpose of our know-your-client procedures (which include, among other things, anti-money laundering procedures, terrorist financing procedures, Politically Exposed Persons checks, and sanctions checks).

3. USE OF YOUR PERSONAL DATA

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 UK GDPR, depending on the nature and purposes of processing carried out:

3.1.1 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. The lawful basis of such processing is Article 6(1)(b) UK 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 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.The lawful basis of such processing is processing which may be necessary to discharge a relevant UK 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;
(ii) carry out verification, 'know your client', terrorist financing, sanctions, and anti-money laundering and Politically Exposed Persons checks;
(iii)  verify the identity and addresses of our investees and their directors, officers and employees (and, if applicable, their beneficial owners);
(iv) comply with requests from UK regulatory, governmental, tax and law enforcement authorities;
(v) maintain statutory registers; and
(vi) comply with UK legal sanctions requirements.

3.1.3 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.

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 MetLife 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 your funding;
(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 UK) and industry standards;
(vi) assisting our transaction counterparties to comply with their regulatory and legal obligations (including anti-money laundering, 'know your client' and sanctions checks);
(vii) assisting with internal compliance with our policies, processes and record keeping activities;
(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 UK;
(xi) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
(xii) ensuring the security of information systems.

3.2 Where we process sensitive personal data, including 'special categories of personal data' defined in Article 9(1) UK 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) UK GDPR, such processing will be necessary for reasons of substantial public interest such as the prevention of fraud, terrorist financing and money laundering. To the extent applicable, we do so in accordance with Schedule I of the DPA, including one or a combination of the conditions set out in Part II of Schedule I (Preventing or detecting unlawful acts, protecting the public against dishonesty etc., regulatory requirements relating to unlawful acts and dishonesty etc., preventing fraud, and suspicion of terrorist financing or 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 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. 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.

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 MetLife, our customers, or others;

4.2.4 to regulators (including but not limited to the Financial Conduct Authority) 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.

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 and may be permitted to disclose your personal data to other parties in accordance with applicable law.

5. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE THE UK

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

5.2 To the extent required by law, where personal data is transferred outside the UK, 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 relevant authority in the UK).

6. 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.

7. 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.

8. YOUR RIGHTS

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

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

8.1.2 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;

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

8.1.4 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 Applicable Data Protection Laws 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;

8.1.5 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;

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

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

8.1.8 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. 

8.2 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.

8.3 You can lodge a complaint or find out more information about your rights by contacting the UK's Information Commissioner's Office, or by searching its website at https://ico.org.uk/.

9. 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 MIMLPrivacyChampion@metlife.com.

10. UPDATES

We may amend this Privacy Notice from time to time. Any 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-limited/). This Privacy Notice was last updated on 20 September 2021.

Your privacy is very important to us. In this notice (this "Privacy Notice"), "we", "us" and "our" means MetLife Investment Management Limited ("MetLife"). We are registered in England and our registered address is Level 34, One Canada Square, Canary Wharf, London, England, E14 5AA.

1. ABOUT THIS PRIVACY NOTICE

1.1 For the purposes of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 No. 419 ("UK GDPR") and the Data Protection Act, 2018 ("DPA", together "Applicable Data Protection Laws"), we are a controller in respect of your personal data. We are responsible for ensuring that we process your personal data in compliance with Applicable Data Protection Laws. The terms "controller", "processor", "data subject", "personal data", and "processing" used in this Privacy Notice have the meanings given to them in the UK GDPR. This Privacy Notice is issued on behalf of MetLife Investment Management Limited and its affiliates. The name of the specific MetLife entity that processes your personal data will depend on the type of investment management services you receive.

1.2 This Privacy Notice applies to directors, officers and employees of current, prospective and former clients (i.e., institutions to which we provide investment management services) ("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.

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 Persons checks, and sanctions checks).

2.2 We do not hold special categories of personal data about you. This includes types of personal data which might show a person’s race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, details about their health and any genetic or biometric data.

3. USES OF YOUR PERSONAL DATA

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 UK GDPR, depending on the nature and purposes of processing carried out:

3.1.1 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, decision-making in relation to accountancy and audit services, and the administration of IT systems.

The lawful basis of such processing is Article 6(1)(b) UK 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 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.

The lawful basis of such processing is processing which may be necessary to discharge a relevant UK 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;
(ii) carry out verification, 'know your client', terrorist financing, sanctions, and anti-money laundering and Politically Exposed Persons checks;
(iii) verify the identity and addresses of our investors and their directors, officers and employees (and, if applicable, their beneficial owners);
(iv) comply with requests from UK regulatory, governmental, tax and law enforcement authorities;
(v) maintain statutory registers; and
(vi) comply with UK legal sanctions requirements.

3.1.3 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.

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 MetLife, 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 UK) 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 UK;
(xi) establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
(xii) ensuring the security of information systems.

3.2 Where we process sensitive personal data, including 'special categories of personal data' defined in Article 9(1) UK 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) UK GDPR, such processing will be necessary for reasons of substantial public interest such as the prevention of fraud, terrorist financing and money laundering. To the extent applicable, we do so in accordance with Schedule I of the DPA, including one or a combination of the conditions set out in Part II of Schedule I (Preventing or detecting unlawful acts, protecting the public against dishonesty etc., regulatory requirements relating to unlawful acts and dishonesty etc., preventing fraud, and suspicion of terrorist financing or 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 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. 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.

4.2 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 MetLife, our customers, or others;

4.2.4 to regulators (including but not limited to the Financial Conduct Authority) where we or the regulator may deem appropriate in the context of the regulatory regimes in which it operates; 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.

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 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 UK

6.1 Your personal data may be transferred to, or stored in, a destination outside the UK in countries which may not have similarly strict data protection and privacy laws. It may also be processed by individuals operating outside of the UK 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 UK, 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 relevant authority in the UK).

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 Applicable Data Protection Laws 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 unauthorized access by someone impersonating you.

9.3 You can lodge a complaint or find out more information about your rights by contacting the UK's Information Commissioner's Office, or by searching its website at https://ico.org.uk/.

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

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 MIMLPrivacyChampion@metlife.com.

11. UPDATES

11.1 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-limited/). This Privacy Notice was last updated on 20 September 2021.

MetLife Investment Management Limited UK Stewardship Code Disclosure Statement

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

MIML does not currently comply with the Code for the following reasons: 

The Firm’s investment strategy involves only fixed-income securities and a variety of private credit opportunities and does not invest in the shares of UK-listed companies. Therefore, although the Firm supports the objectives set out within the Code, the provisions are not deemed to be relevant to the type of investment strategies and trading currently undertaken by the Firm. Should any material changes occur to our strategies which would make the Code relevant, MIML will review its commitment to the Code at that time and make appropriate disclosure.

Pillar 3 Disclosure

The purpose of this document is to set out the Pillar 3 disclosures of MetLife Investment Management Limited (MIML) as of 31 December 2021. Download the document.