Terms of Use

These terms of use are an agreement between you and ExodusPoint Capital Management, LP and its affiliates (“ExodusPoint,” “we,” “our” or “us”), and your access to and use of www.exoduspoint.com, including any content, functionality, and services offered on or through www.exoduspoint.com (the “Website”), is conditioned upon you accepting these terms of use. By accessing and using the Website you confirm that you agree with and understand the following terms and conditions (the “Terms of Use”) without any modification, limitation, or qualification. If you do not want to agree to these Terms of Use, you must not access or use the Website.

We may revise and update these Terms of Use at any time in our sole discretion. All changes are effective immediately when we post them. Your continued use of the Website after we post revised Terms of Use means that you accept and agree to the changes. You should periodically check this page to review the current Terms of Use.

The information on the Website is provided for informational purposes only. We do not warrant the accuracy, completeness, or usefulness of this information. If you rely on such information, you do so strictly at your own risk. We disclaim all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to the Website, or by anyone who may be informed of any of its contents.

Account Security and Privacy

All information that is submitted via the Website is governed by our Privacy Policy, and you consent to all actions we take with respect to your information consistent with our Privacy Policy. Our Privacy Policy is incorporated into these Terms of Use by reference.

We may change or disable the Website and any services or materials on the Website at any time in our sole discretion and without any notice to you. We do not guarantee that the Website will be available at any particular time or that it will be error free, and we will not be liable if all or any part of the Website is unavailable at any time or for any period.

You are responsible for making all arrangements necessary for you to have access to the Website and ensuring that all persons who access the Website through your internet connection are aware of these Terms of Use and comply with them.

If we ask you to provide registration details in order to access the Website or some of the resources on the Website, you agree to provide complete and accurate information and to keep the information up-to-date. If you are provided with an account for the Website, you acknowledge that your account is personal to you and you agree not to provide any other person with access to the Website or portions of it using your account. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. We may disable any account at any time in our sole discretion and for any reason, including if, in our opinion, you have violated these Terms of Use.

Intellectual Property Rights

We, our licensors, or other providers of material, own the Website, and its content, features, and functionality (including, but not limited to, all information, software, images, video, audio, and design elements) (collectively, the “Website Content”). The Website Content is protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property laws. Nothing contained within the Website shall be construed as granting, by implication, estoppel or otherwise, any license or right to use any Website Content. These Terms of Use permit you to use the Website and Website Content for your personal, non-commercial use only.

The ExodusPoint name, its logo, and all related names, logos, product and service names, designs, and slogans are trademarks of ExodusPoint or its licensors. You must not use any of them without our prior written permission. All other names, logos, product and service names, designs, and slogans on the Website are the trademarks of their respective owners.

We may change the Website Content at any time in our sole discretion and for any or no reason. Website Content may also be out of date, and we are under no obligation to update any Website Content.

Prohibited Uses

You may use the Website only for lawful purposes and in accordance with these Terms of Use. You agree not to use the Website:

• In violation of any applicable law or regulation;
• To exploit or harm any person or entity or attempt to exploit or harm any person or entity;
• To transmit or cause the transmission of any advertising or promotional material without our prior written consent, including any “junk mail,” “chain letter,” “spam” or any other similar solicitation; or
• To engage in any other conduct that restricts or inhibits anyone’s use or enjoyment of the Website, or which, as determined by us, may harm us or users of the Website or expose us or them to liability.

Additionally, you agree not to:

• Use the Website in any manner that could disable, overburden, damage or impair the Website or interfere with any other party’s use of the Website;
• Use any robot, spider or other automatic device, process, or means to access the Website for any purpose;
• Use any manual process to monitor or copy any of the material on the Website or for any other unauthorized purpose without our prior written consent;
• Attempt to gain unauthorized access to, interfere with, damage or disrupt any parts of the Website, the server on which the Website is stored, or any server, computer or database connected to the Website; or
• Otherwise attempt to interfere with the proper working of the Website or any user’s access to or use of the Website.

Third-Party Websites

The Website may link to websites that are not owned or operated by us (“Third Party Websites”), and these links do not represent, warrant, or imply that we endorse or have reviewed such Third Party Websites or any of the materials, opinions, goods or services available on them. These Terms of Use do not apply to your use of Third Party Websites, and you should review any similar terms that exist on such Third Party Websites prior to your use of them.

Disclaimer of Warranties

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DENIAL-OF-SERVICE ATTACK, VIRUSES, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE WEBSITE, THE WEBSITE CONTENT, THIRD PARTY WEBSITES AND ANY SERVICES OR ITEMS OBTAINED THROUGH ANY OF THE FOREGOING IS AT YOUR OWN RISK. THE WEBSITE, THE WEBSITE CONTENT, THIRD PARTY WEBSITES AND ANY SERVICES OR ITEMS OBTAINED THROUGH ANY OF THEM ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PROVIDED BY LAW, WE HEREBY DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT, AND FITNESS FOR PARTICULAR PURPOSE.

THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

Limitation of Liability

TO THE FULLEST EXTENT PROVIDED BY LAW, IN NO EVENT WILL WE, OUR LICENSORS, SERVICE PROVIDERS OR OUR OR THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AGENTS, LICENSORS, SUPPLIERS, SUCCESSORS OR ASSIGNS BE LIABLE TO YOU OR TO ANY THIRD PARTY FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, WEBSITE CONTENT, THIRD PARTY WEBSITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH ANY OF THE FOREGOING, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, EVEN IF FORESEEABLE.

THE FOREGOING DOES NOT AFFECT ANY LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

Indemnification

You will defend, indemnify, and hold harmless ExodusPoint, its licensors, its service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors, and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, and fees (including reasonable attorneys’ fees) arising out of or relating to your violation of these Terms of Use or your use of the Website, including, but not limited to, your User Contributions, any use of the Website’s content, services, and products other than as expressly authorized in these Terms of Use or your use of any information or materials obtained from the Website.

Miscellaneous

Informal Dispute Resolution. If you have any questions or concerns regarding your use of or inability to use the Website, please email us at info@exoduspoint.com so we can attempt to answer your questions or address your concerns. We and you agree to make reasonable efforts to settle any genuine dispute, claim, question, or disagreement directly through consultation and good faith negotiations prior to initiating a lawsuit.

Applicable Law; Jurisdiction. You agree that federal laws and the laws of the State of New York, without regard to principles of conflict of laws, will govern these Terms of Use and any claim or dispute that has arisen or may arise between you and us. You hereby consent to the exclusive jurisdiction of the Southern District of New York or any New York State Court located in the Borough of Manhattan, New York in all disputes arising from or relating to the Terms of Use or your access to or use of the Website. You hereby waive any objection to venue or inconvenient forum laid therein.

Entire Agreement. The Terms of Use and the policies referred to herein constitute the sole and entire agreement between you and ExodusPoint regarding the Website and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding the Website.

Assignment. We may assign our rights under these Terms of Use in whole or in part without your consent. You may not assign any of your rights or delegate any of your obligations under these Terms of Use – whether by operation of law or otherwise – without our prior written consent.

Severability. These Terms of Use operate to the fullest extent permissible by law. If any one or more of the provisions of these Terms of Use are for any reason held to be invalid, illegal or unenforceable, the remaining provisions of these Terms of Use shall be unimpaired and shall remain in full force and effect, and the invalid, illegal or unenforceable provision shall be replaced by a valid, legal and enforceable provision that comes closest to the parties’ intent underlying the invalid, illegal or unenforceable provision.

Waiver. If we fail to enforce these Terms of Use in any instance or instances, it shall not be a waiver of the applicable portion of these Terms of Use.

Our Relationship. Nothing in these Terms of Use create an agency, partnership, joint venture, employer-employee or franchisor-franchisee relationship of any kind between us and you.

Contacting Us. The Website is operated by ExodusPoint Capital Management, LP (65 East 55th Street, New York, NY 10022). Except as otherwise indicated in these Terms of Use, all feedback, comments, requests for technical support, and other communications relating to the Website should be directed to: info@exoduspoint.com.

ExodusPoint Global Privacy Notice

Effective April 3, 2023

This Global Privacy Notice describes the policies and procedures followed by ExodusPoint Capital Management, LP and its affiliates (together, “ExodusPoint”, “we”, “our”, or “us”) regarding the collection, use, and disclosure of your personal information when you visit our website or otherwise interact with ExodusPoint. For the purposes of European, Dubai International Financial Centre (“DIFC”), and UK data protection laws, ExodusPoint is the data controller of your personal information. Please note that when using the website, this Global Privacy Notice should be read in conjunction with our Terms of Use and is incorporated into our Terms of Use.

If you are an individual investor in the United States, your privacy rights are described in our GLBA Notice.

Collection of Personal Information. When you visit the website, receive services from us or otherwise interact with ExodusPoint, we may collect and process the following data about you:

• Information that you give to us – you may give us personal information including your name, company name and contact details, including address(es), telephone number(s) and email address. If you are an investor, we may also collect your passport information, social security number, information about your assets, account balances, transaction history, investment experience, and wire transfer instructions. You are not under any obligation to provide any of this information. However, if you withhold requested information, we may not be able to provide certain services to you.
• Information that we collect about you – we may automatically collect basic technical information from all visitors to the website through our automatic data collection tools, which may include cookies and other commonly used technologies (see section on Cookies below). These tools collect certain standard information that your browser sends to the website, such as your browser type and language, access times and the address of the site from which you came to the website. They may also collect your Internet Protocol address or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.
• Information that we receive from other sources – we may collect personal information from different sources, including social media, analytics providers, and search information providers, including search engines and other public sources.
• Information may also be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails to us). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used only for legal, compliance, or security purposes.

Use of your Personal Information. We may use the personal information you give us to carry out the following purposes:

Purpose	Lawful Basis
To contact you and to respond to your requests, inquiries and other communications	We have a legitimate interest in responding to your requests and inquiries for ongoing business administration
To deliver services to you	To manage and perform our contract with you
For employment recruitment purposes	We have a legitimate interest in considering an applicant for a role or vacancy in accordance with our employment recruitment process and contractual obligations and/or to take pre-contractual steps (such as background screening, vetting or reference checks)
For business administration, including statistical analysis	We have a legitimate interest in the proper management and administration of our relationship with you and to ensure that we are as effective and efficient as we can be
To personalize your visit to the website and to assist you while you use the website	We have a legitimate interest in the proper management and administration of our relationship with you and to ensure that we are as effective and efficient as we can be
To improve the website by helping us understand who uses the website	We have a legitimate interest in the proper management and administration of our relationship with you and to ensure that we are as effective and efficient as we can be
In connection with corporate sales or other restructuring events	We have a legitimate interest in the processing of your data in connection with the sale or reorganization of all or part of our business or its assets
For fraud prevention and detection and to comply with applicable laws, regulations, or codes of practice including complying with any obligations derived from anti-money laundering and counter-terrorism legislation	To comply with our legal obligations and our legitimate interests

You have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest. An objection will be deemed justified unless compelling grounds for such processing override your interests as a Data Subject. As such, the right to object is not absolute.

Sharing your Personal Information. We may use selected third parties to provide us with services or technical support for the website who may have access to your personal information.

• If you are an investor, we may also disclose certain personal information to our affiliates and service providers, such as fund administrators (including, but not limited to, Northern Trust Global Fund Services Cayman Limited and its affiliates), custodians, broker-dealers, accountants, and lawyers, as necessary to effect and administer the fund and enforce our rights and obligations. All service providers, including providers of software as a service, are permitted to use data only for the purpose of performing services on our behalf.
• Similarly, we may share your personal information as required by law to protect our rights and property, or the rights, property, or safety of others, including with advisers, law enforcement agencies, and judicial and regulatory authorities.
• Subject to applicable laws, we may also share your personal information with our affiliates for their marketing purposes. If you do not want us to share information with our affiliates for their marketing purposes, please contact us using the information below.
• We may transfer or share a copy of personal information about you in the event that we or one of our assets, affiliates or subsidiaries goes through a business transition, such as a merger, being acquired by another company, being reorganized or liquidated or the sale of a portion of our or their assets. Nothing in this Privacy Notice is intended to interfere with our ability to transfer all or part of our or one of our asset’s, affiliate’s or subsidiary’s business and/or assets to an affiliate or independent third-party at any time, for any purpose, without any limitation whatsoever. We specifically reserve the right to transfer or share a copy of personally identifiable information collected from our or their websites to the buyer of that portion of our or their business relating to that information during any diligence process.

Rights of Individuals in Europe and the United Kingdom (and certain other jurisdictions). As a Data Subject, you have certain data privacy rights that may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification and erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information be provided to you, or a third-party in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority. Such rights are subject to applicable exemptions and restrictions under applicable laws. For questions and to submit a rights request, please contact us as described below under “Contact Us”.

• Individuals in Andorra, Argentina, Australia, Canada, Faroe Islands, Guernsey, Hong Kong, Isle of Man, Israel, Jersey, Mexico, New Zealand, South Korea, Switzerland, Uruguay, and certain other jurisdictions may also exercise these or similar rights.

California Privacy Rights. Under California law California residents are entitled to ask us for a notice describing which categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a request to us via privacy@exoduspoint.com. Please allow thirty (30) days for a response.

To the extent applicable, California law also provides California residents with the following rights with respect to their personal information:

• The right to know the categories and specific personal information collected from you that ExodusPoint has collected, used, disclosed, and sold. To submit a request to know this information, California residents may contact us as described below under “Contact Us.” California residents may also designate an authorized agent to make a request for access on their behalf.
• The right to request that ExodusPoint correct any inaccurate personal information that it has collected. To submit a request for correction, California residents may contact us as described below under “Contact Us.” California residents may also designate an authorized agent to make a request for correction on their behalf.
• The right to request that ExodusPoint delete any personal information it has collected. To submit a request for deletion, California residents may contact us as described below under “Contact Us.” California residents may also designate an authorized agent to make a request for deletion on their behalf.
• The right to appeal any decision ExodusPoint makes regarding your California privacy rights. To submit an appeal, California residents may contact us as described below under “Contact Us.” Please clearly indicate that your request is an “Appeal.” California residents may also designate an authorized agent to make an appeal on their behalf.

When California residents exercise these rights and submit a request, ExodusPoint will verify their identity by asking them for information such as their email address, telephone number, and/or information about their account with us. We will endeavor to honor requests unless such a request conflicts with certain lawful exemptions under California law, including where necessary to comply with other legal obligations. Please note that ExodusPoint is only required to honor such requests twice in a twelve (12) month-long period.

Exercise of these rights will have no adverse effect on the price and quality of our services to you.

For the twelve (12) month period prior to the date of this Privacy Notice, we have not sold any personal information and have not shared any personal information for cross-contextual advertising; nor do we have any plans to do so in the future.

Japan Privacy Rights. When we are requested by you in accordance with procedures we have specified:

• to disclose your personal information to you, we will disclose such information to you as soon as practicable, unless such disclosure would be in violation of law; and/or
• to correct, add to, or delete your personal information on the basis that such information is inaccurate, we will review the facts relating to such request without delay and will correct, add to, or delete the information on the basis of such review, to the extent required by law.

When we are requested by you to stop using your personal information on the basis that such information was collected improperly or is being used for purposes other than those specified without your consent, we will review the facts relating to such request without delay. If we find a valid reason for such request, we will cease the use of such personal information. We will receive and respond efficiently and appropriately to any inquiries and complaints concerning our handling of personal information. Please refer to the “Contact Us” section below. All your rights are subject to applicable exemptions and restrictions under applicable laws.

Hong Kong Privacy Rights. When we are requested by you to stop using your personal information on the basis that such information was collected improperly or is being used for purposes other than those specified without your consent, we will review the facts relating to such request without delay. If we find a valid reason for such request, we will cease the use of such personal information. We will receive and respond efficiently and appropriately to any inquiries and complaints concerning our handling of personal information. Please refer to the “Contact Us” section below. All your rights are subject to applicable exemptions and restrictions under applicable laws.

Singapore Privacy Rights. When you visit the website, receive services from us or otherwise interact with ExodusPoint and voluntarily give your personal information, we will deem that you have given consent for us to collect and process such information in line with this Privacy Notice. If you wish to withdraw consent or notify us that you do not consent, please contact us using the information below. All your rights are subject to applicable exemptions and restrictions under applicable laws.

International Data Transfer—Consent.

• Europe and UK. When you are based in Europe, the DIFC and/or the UK, personal information collected from you, including via the website, will be transferred to certain recipients located outside of Europe (including in the United States where the website is hosted) and/or the DIFC that may not provide a similar or adequate level of protection compared to that provided by countries in Europe, the UK and the DIFC. You hereby consent to the transfer of your personal information to recipients as described in this Privacy Notice that are located outside of Europe, the UK and the DIFC. You may withdraw your consent at any time. With regards to any personal information transferred outside of the DIFC, any such transfer shall be in accordance with applicable law and, where appropriate, ExodusPoint shall use standard contractual clauses in the form approved by the DIFC Commissioner of Data Protection (which may be found here).
• Japan and Singapore. When you are based in Japan or Singapore, personal information collected from you, including via the website, will be transferred to certain recipients located outside of Japan or Singapore (including in the United States where the website is hosted) that may not provide a similar or adequate level of protection compared to that provided in Japan or Singapore. You hereby consent to the transfer of your personal information to recipients, including in the United States, as described in this Privacy Notice, that are located outside of Japan or Singapore. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal, and, subject to applicable law, it will not preclude the future processing of personal information if within our legitimate interest. All your rights are subject to applicable exemptions and restrictions under applicable laws.

Security. ExodusPoint maintains physical, electronic, and procedural safeguards reasonably designed to protect your information against loss, misuse, damage, or modification and unauthorized access or disclosure. ExodusPoint can make no guarantee that these procedures will prevent all unauthorized access and, as a result, personal information submitted through or contained on the website may be vulnerable to unauthorized disclosure to unknown third parties.

Data Quality, Storage, and Access. While we endeavor to ensure that all information we hold about you is accurate, complete and up to date, you can help us in this regard by promptly notifying us if there are any changes to your personal information.

Retention. Notwithstanding anything herein to the contrary, ExodusPoint may retain your personal information as necessary for the provision of the services, for internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g. mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Right to Raise Concerns. In the event that you are not satisfied with our processing of your personal information, you reserve the right to raise a concern or submit a complaint with the applicable supervisory authority. If you wish to raise a concern with us directly, please contact us as described below under “Contact Us”.

Children’s Privacy. We do not collect or maintain information through our website from those whom we actually know are under the age of 18 and no part of our website is targeted to attract anyone under 18.

Cookies. The website may use “cookies” which may automatically collect certain information and data. Cookies are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of the website. Cookies may also help us diagnose problems with our server and the website. If you do not want us to use cookies when you use the website, you can adjust your internet browser settings to not accept cookies. Your web browser’s help function should tell you how to do this. The cookies currently used are listed below but may be updated from time to time:

• incap_ses_*: Session cookie for distributed denial-of -service (DDoS) protection and web application firewall protection on all our websites.
• fonts.net: Functional cookie to render the fonts used on www.exoduspoint.com.
• .ASPXFORMSAUTH: Session cookie to ensure users remain logged in as they browse the site’s pages and provide audit and security controls on our investor portal.
• ReturnUrl: Session cookie on our investor portal.
• ASP.NET_SessionId: Session cookie to maintain the state of the session while users browse the site from page to page on our investor portal.
• RequestVerificationToken_*: Required security token to prevent Cross-Site Request Forgery.
• PopupDisclaimerAgree: Cookie added when users agree to the pre-login site disclaimer banner/popup on our investor portal.
• AutomaticUserGUID: Cookie created when users check the “Remember Me” option on the login screen of our investor portal.
• AutomaticUserToken: Cookie created when users check the “Remember My Device” option on our investor portal.
• Google Analytics: Cookie to measure how users interact with website content on our investor portal.

Revisions to this Privacy Notice We may revise or supplement this Privacy Notice from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a notice on our website before the change becomes effective. We encourage you to refer to this Privacy Notice on an ongoing basis so that you understand our current privacy practices.

Contact Us. If you have any questions or comments about our Privacy Notice, or if you are located in California, Europe, Hong Kong, Japan, or Singapore and wish to exercise your rights as described above, please feel free to contact us at privacy@exoduspoint.com

UK/EU Related Disclosures

U.K. Stewardship Code Statement

Pursuant to Rule 2.2.3R of the Financial Conduct Authority’s Conduct of Business Sourcebook, ExodusPoint Capital Management UK, LLP (“ExodusPoint UK”) is required to disclose whether it commits to the UK Financial Reporting Council's Stewardship Code (the "Stewardship Code") or explain why it does not, having consideration to its investment approach.

ExodusPoint UK acts a sub-advisor within the broader structure of the ExodusPoint group. The ExodusPoint group manages investments across a number of asset classes and markets globally following a number of diversified strategies, including assets other than UK listed equities or fixed income assets. The ExodusPoint group does not have an activist approach to its investments. In the limited cases where ExodusPoint UK does have interaction with UK investee companies, it does so in accordance with our firm policies which are designed to act in the best interests of our investors.

As such, while ExodusPoint UK generally supports the Stewardship Code and its principles, it is not appropriate to commit to it given the nature of the funds’ investment strategies.

Shareholder Rights Directive Statement

ExodusPoint Capital Management UK, LLP (“ExodusPoint UK”) is making this statement in Compliance with Rule 2.2B.5R of the FCA's Conduct of Business Sourcebook (“COBS”).

COBS requires every FCA authorised asset manager that invests in listed equities to:

(1) develop and publicly disclose on its website, a copy of its engagement policy which includes the content specified in the amended EU Shareholder Rights Directive (Directive 2007/36/EC); and

(2) publicly disclose on an annual basis how its engagement policy has been implemented, including a general description of its voting behaviour, an explanation of its most significant votes and details of its use of the services of proxy advisors,

or, in either case, to publicly disclose a clear and reasoned explanation of why it has chosen not to comply with those requirements.

ExodusPoint UK has considered carefully whether it wishes to adopt an engagement policy and to make the disclosures described above. ExodusPoint UK is a subadvisor within the broader structure of the ExodusPoint group, and manages assets in accordance with a multi-strategy investment approach that involves a wide variety of assets. When ExodusPoint UK invests in shares, it has a general policy not to vote proxies. There may be some limited situations where ExodusPoint UK would consider voting a proxy, but these situations are limited and subject to the firm’s policies and procedures designed to act in the best interest of our investors.

Therefore, while ExodusPoint UK supports the general principles of shareholder engagement, it does not at this time (for the reasons set out above) consider it appropriate to adopt an engagement policy with respect to the Shareholder Rights Directive. ExodusPoint UK will keep its position under review and will update this section of its website accordingly if there is a change in its approach.

Modern Slavery Act Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) in respect of ExodusPoint Capital Management UK, LLP and its affiliate, ExodusPoint Capital Management UK Technologies, Ltd (collectively, “ExodusPoint” or “we”) in respect of the financial year ended 31 December 2021.

ExodusPoint Capital Management UK, LLP is a limited liability partnership incorporated in England and Wales. It is an investment management firm, authorised and regulated by the Financial Conduct Authority. ExodusPoint Capital Management UK Technologies, Ltd is a limited company incorporated in England and Wales.

References to the term “modern slavery” in this statement includes slavery, servitude and forced or compulsory labour, and human trafficking, as defined in the Act.

ExodusPoint neither condones nor tolerates the presence of modern slavery in its business or its supply chains. Whilst we believe the risk of modern slavery taking place in our business is low, ExodusPoint has policies and procedures in place to ensure adherence with the Act and applicable law, including bribery and corruption, money laundering, employment and discrimination, whistleblowing and escalation of staff concerns or issues. ExodusPoint’s Code of Ethics reflects its commitment to acting ethically and with integrity in all areas of its business and its supply chain.

ExodusPoint has taken steps to detect potential modern slavery and human trafficking or the presence of forced labour within its business, including carrying out due diligence on all vendors and suppliers, and provides training and awareness of the Act to staff to inform them of how to take appropriate action if they suspect a case of modern slavery or human trafficking.

This statement was approved by the Members of ExodusPoint Capital Management UK, LLP and the Board of Directors of ExodusPoint Capital Management Technologies, Ltd. in May 2022.

MiFID II Best Execution Disclosure

Best Execution Disclosure for 2020.pdf
Best Execution Disclosure for 2020.xls
Best Execution Disclosure for 2019.pdf
Best Execution Disclosure for 2019.xls

ExodusPoint UK Tax Strategy

“ExodusPoint Group” is a global, multi-strategy, multi-manager investment firm headquartered in New York City with operations in the UK and globally. This tax strategy sets out the ExodusPoint Group’s outlook on UK taxation and applies to each of ExodusPoint Capital Management UK, LLP, ExodusPoint Services UK, Ltd and ExodusPoint Capital Management UK Technologies, Ltd (each a “ExodusPoint UK entity” and, together, “ExodusPoint UK”) for the year ended 31 December 2022.

Approach to risk management and governance arrangements

ExodusPoint UK emphasizes a culture of timely and accurate tax compliance, robust internal financial and tax controls, and no tolerance for undue risk taking. This effort is overseen by the Global Head of Tax and broader tax team, through close interaction across departments, and with involvement of UK and global senior management where necessary. Such collaboration ensures that the Tax team can proactively and thoroughly identify and address tax risks and obligations with proper points of escalation.

The Global Head of Tax and broader tax team escalate and address tax matters to UK and global senior management. Tax compliance is a key focus for the ExodusPoint Group, and ExodusPoint UK also relies on external UK tax advisors for their expertise where needed. In particular, careful consideration is given to the corporate criminal offense rules to ensure that ExodusPoint UK has reasonable procedures in place to prevent the facilitation of tax evasion by its associated persons.

Attitude to UK tax planning and management of tax risks

ExodusPoint UK strives to be a best-in class platform for its stakeholders, which includes an emphasis on both tax efficient planning and risk management related to tax positions. While tax efficiency is sought where feasible and permissible, ExodusPoint UK prioritizes the mitigation of financial and reputational risks. ExodusPoint UK works closely with its external UK tax advisors to ensure predictable outcomes and a high degree of comfort in its business endeavours and filing positions.

Approach towards dealings with HMRC

ExodusPoint UK strives for transparent and candid dialogue with HMRC and hopes to ensure timely and effective resolutions for both parties. By doing so, ExodusPoint UK hopes to build long term trust and credibility with HMRC.

The publication of this tax strategy has been reviewed and approved by the ExodusPoint Group’s Head of Tax, Chief Financial Officer, and respective UK governing bodies. The tax strategy complies with ExodusPoint UK’s obligations to the Finance Act 2016.

Approved 6 December 2022

Published 3 January 2023

Important Disclaimers

ExodusPoint is an SEC-registered investment adviser located in New York, New York. Registration does not imply a certain level of skill or training. The Website is provided for informational purposes only. Under no circumstances should any information presented here be used or construed as an offer, or solicitation of any offer, or other form of invitation or inducement, to sell or buy any securities or other investments, or to provide advice regarding investments or a recommendation to purchase, sell or hold any security or other investment, or to pursue any investment style or strategy. There can be no assurance that any particular strategy or investment will prove profitable and the information contained herein should not be interpreted to provide a guarantee of future performance. Investment strategies may be added, removed or adjusted, and/or the investment approach may be changed, at any time in ExodusPoint’s sole discretion and without any notice. There can be no guarantee that any strategy or approach employed by ExodusPoint will achieve its investment objective or avoid losses. There can be no guarantee that ExodusPoint’s risk management framework will prevent losses from occurring. Past performance is not indicative of future results. ExodusPoint does not make any representations as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to the Website or incorporated herein, and takes no responsibility therefore.

The material on this web site does not constitute an offer to sell, or the solicitation of an offer to buy, advisory services or any securities or any interests in investment funds managed by ExodusPoint Capital Management LP or any of its affiliates. Offerings of securities are made only by prospectus or private offering memoranda by persons who are authorized to do so. Such offerings are made, and such investment advisory services are offered, only to persons who are “accredited investors” as defined under the Securities Act of 1933, as amended. This web site is not intended for use by any person in any jurisdiction or country where such use would be contrary to local law or regulation. ExodusPoint makes no representations or warranties that the content of this web site is applicable or appropriate for use in locations outside of the United States of America.

HONG KONG RELATED DISCLOSURES

PERSONAL INFORMATION COLLECTION STATEMENT

EMPLOYEE HIRING

Thank you for your application to ExodusPoint.

Why do you need to collect my personal data?

As part of our hiring process, we need to collect your personal data for the purpose of, among other things: (a) assessing your suitability to assume the duties and responsibilities of the position for which you have applied; (b) determining your remuneration (including bonus payments and other benefits); (c) conducting interviews with you; (d) assessing you by way of written tests and assessments; (e) obtaining references; (f) conducting background checks; and (g) for any other purpose that you have agreed.

Do I need to supply my data?

In order for us to process your application, you must provide to us your personal data which may include, for example, the following types of information.

(A)	Personal details including name, title, address, contact information, date of birth, gender, nationality and permanent residence (but not your HKID number)
(B)	Information about your academic history, professional qualifications and work experience
(C)	Information from the results of your tests and assessments
(D)	Information from your referees.

If you do not provide us with such personal data, we will be unable to process and review your application.

Who else will receive my personal data?

In order to process your application, we may transfer or disclose your personal data to the following classes of persons who may be in or outside of Hong Kong: (a) our affiliated companies; and (b) our agents, vendors, contractors or third party service providers who help us on human resources matters. We will take all practicable steps to ensure that these persons keep your personal data confidential. We may also transfer or disclose your data to relevant government authorities (including securities regulatory and enforcement authorities), courts and tribunals as necessary or desirable or to comply with law, regulation or codes of practice.

What happens if my personal data becomes inaccurate?

Based on what you provide to us, we will take all practicable steps to ensure that your personal data is accurate taking into account the purpose for which we will use your personal data. Where we believe that your personal data is inaccurate, we will not use the data unless and until we believe that the data is no longer inaccurate e.g. by correcting or erasing the data.

If we find out that your personal data which we disclosed to a third party (e.g. a referee) was materially inaccurate at the time of disclosure taking into account the purpose for which the data is to be used by that third party, we will inform the third party that the data is inaccurate. Where we have the correct information, we will provide the third party with such particulars so it can correct the data.

How safe will my personal data be?

We take all practicable steps to ensure that your personal data is protected against unauthorized or accidental access, processing, erasure, loss or use. We store personal data in a [cloud-based database] access to which is password protected. We restrict access to those persons who "need to know" and who have been trained to handle personal data properly. We have strict personal data security policies.

How long will you keep my personal data for?

We will take all practicable steps to ensure that we do not keep your personal data for longer than is necessary for the purpose that we collected it. For unsuccessful applicants, we will usually keep your personal data for two years. During this period, unless you inform us in writing, we will use your application and personal data to consider you for other positions that may be open from time to time. We may however be required to keep your personal data for a longer period for legal and compliance reasons.

What rights do I have?

You have the right to ascertain what personal data of yours that we hold (with certain exceptions, such as information provided by a referee or personal data that we have in order to assess your suitability for the position for which you are being considered), You can request access to your personal data (via the prescribed data access request form) and the correction or destruction of your personal data held by us (in the case of unsuccessful applicants). If you have any such request, please contact us at [insert email] with the request marked "Data Access Request".

Please also read our Human Resources Privacy Policy Statement.

HUMAN RESOURCES PRIVACY POLICY STATEMENT

ExodusPoint is committed to protecting the confidentiality and security of your personal data by complying with the requirements of the Personal Data (Privacy) Ordinance. We explain here what we will, and will not do, with your personal data. Where applicable, please read this together with our Personal Information Collection Statement (PICS).

Why we collect personal data and how we use it

We collect, store, use and process your personal data for all aspects of hiring, managing, incentivizing, training and developing our employees. This may include using your personal data, for example: (a) to assess applicants for positions in our organization; (b) to determine remuneration and other benefits; (c) to conduct interviews and other tests and assessments; (d) to conduct background checks; (e) to manage our payroll; (f) to appraise, train and promote our employees; (g) to prepare tax returns; and (h) to use for any other purpose that you have agreed.

The personal data we collect and how we collect it

We collect and/or request personal data from you when you submit personal data to us in one of various ways and through our interactions with you. The type of personal data we collect from you will depend on where in the hiring process you are and whether you become an employee and may include but is not limited to the following types of personal data:

• Personal details including name, title, address, contact information, date of birth, gender, HKID number, relationship status, nationality and permanent residence
• Similar details of your immediate family
• Information about your academic history, professional qualifications and work experience
• Information about your current and prior remuneration
• Bank account details
• Information from the results of your tests and assessments
• Information from your referees.

Some of the information we require is mandatory otherwise we will not be able to process and review your application, make any employment decisions or to provide you compensation or benefits.

No direct marketing

We will not provide your personal data to third parties for direct marketing or other unrelated purposes.

Retention of personal data

We will take all practicable steps to ensure that we do not keep your personal data for longer than is necessary for the purpose that we collected it. We may however be required to keep your personal data for a longer period for legal and compliance reasons.

Sharing your personal data

We would not ordinarily disclose or transfer personal data to a third party without your prior consent. Spouses, children, relatives, and other service providers have no automatic right of access to your personal data. There are occasions when we may disclose your personal data to external people or agencies, such as: (a) our affiliated companies; (b) our agents, contractors or third party service providers who help us on human resources matters; (c) our insurers and bankers; (d) our Mandatory Provident Fund Scheme administrators; and (e) medical practitioners providing treatment to our employees and their families. We may also transfer or disclose your data to relevant government authorities (including tax, securities regulatory and enforcement authorities), courts and tribunals as necessary or desirable or to comply with law, regulation or codes of practice.

Security of personal data

We store personal data in authorized locations and we restrict access to those persons who "need to know" and who have been trained to handle personal data properly. We have strict personal data security policies.

Access to and correction of personal data

You have the right to ascertain what personal data of yours that we hold (with certain exceptions, such as information relevant for an evaluative process e.g. an employment or promotion decision, that has not concluded). You can request access to your personal data (via the prescribed data access request form) and the correction or destruction of your personal data held by us. If you have any such request, please contact info@exoduspoint.com marking the request with the subject heading "Data Access Request". In some cases, we may charge you a small fee for complying with a data access request. We may amend this Privacy Policy Statement (Human Resources) at any time and from time to time in order to inform you of any changes to the way we collect, store, handle and process personal data.

Equal Employment Opportunity Policy

ExodusPoint Capital Management, LP (together with its affiliates, "ExodusPoint" or the "Firm") is an Equal Opportunity Employer. In accordance with applicable anti-discrimination law, it is the purpose of this policy to effectuate these principles and mandates. ExodusPoint prohibits discrimination and harassment of any type and affords equal employment opportunities to employees and applicants without regard to race, color, descent, creed, religion, sex, intersex status, gender identity, age, national or ethnic origin, marital status, pregnancy, family status, disability status, sexual orientation, or any other characteristic protected by applicable law. The Firm conforms to the spirit as well as to the letter of all applicable laws and regulations.

The Firm will provide reasonable accommodation for any individuals with disabilities, pregnancy, childbirth, and related medical conditions, religious beliefs, observances, and practices; or for victims of domestic violence, sex offenses, or stalking. Where the specific accommodation requested is impracticable, the Firm will seek to implement an appropriate alternative reasonable accommodation.

Our policy reflects and affirms the Firm's commitment to the principles of fair employment and the elimination of all discriminatory practices.

If you believe that someone has violated any employment policy (whether or not the alleged violator is a co-worker, manager, or third party), you should bring the matter to the immediate attention of HR, who will promptly investigate the facts and circumstances of any claim of perceived harassment or discrimination in a manner which is timely, impartial, and documented. No employee will be subject to, and ExodusPoint prohibits any form of discipline or retaliation for, reporting violations of the Firm's policies, including reporting incidents of harassment or discrimination in violation of the Firm's employment policies, pursuing any such claim or cooperating in the investigation of such reports. ExodusPoint is committed to enforcing these employment policies against all forms of harassment and discrimination. The effectiveness of our efforts, however, will depend largely on your telling us about inappropriate workplace conduct. If you feel that you or someone else may have been subjected to conduct which violates these policies, you should report it immediately. If employees do not report such conduct, the Firm may not become aware of possible violations of these policies and may not be able to take appropriate corrective action. Retaliation or victimization is a serious violation of these policies and should be reported immediately. Any person found to have retaliated against another individual for reporting discrimination or harassment will be subject to appropriate disciplinary action, up to and including termination.

Transparency in Coverage

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.