1. About Capula Investment Management LLP
www.capulaglobal.com (“our site”) is a website operated by Capula Investment Management LLP (“we” and/or “us”) and the information on our site is issued by us both inside and outside the United Kingdom. We are registered in England and Wales registration number OC313398 and have our registered office at 4th Floor Phoenix House, 1 Station Road, Reading, RG1 1NB. Our contact e-mail address is admin@capulaglobal.com. Our main trading address is 7 Clarges Street, London W1J 8AE. Our VAT number is 867 4565 75. We are authorised and regulated by the UK Financial Conduct Authority (“FCA”). We are registered as a commodity pool operator with the US Commodity Futures Trading Commission and are a member of the US National Futures Association. We are not registered as an investment adviser with the US Securities and Exchange Commission.

2. Investment information
The distribution of information contained on our site in certain countries may be restricted by law and persons who access it are required to inform themselves and to comply with any such restrictions. This information does not constitute an offer or solicitation in any jurisdiction in which such an offer or solicitation is not authorised or to any person to whom it is unlawful to make such an offer or solicitation. Persons interested in acquiring any investment should inform themselves as to: (i) the legal requirements within the countries of their nationality, residence, ordinary residence or domicile for such acquisition; (ii) any foreign exchange control requirement which they might encounter on the acquisition or sale of investments; and (iii) the income tax and other tax consequences which might be relevant to the acquisition, holding or disposal of any investment. We, our affiliated companies and our and their members and/or directors, officers and/or employees may have holdings in the investment funds referred to on our site (“Funds”) and may otherwise be interested in transactions that you effect in such Funds.

3. Risk Factors
Past performance may not be repeated and should not be seen as a guide to future performance. The value of the investments and the income therefrom may go down as well as up and investors may not get back the original amount invested. You are not certain to make money from your investments and you may lose money. Exchange rates may cause the value of overseas investments and the income therefrom to rise and fall. The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences. Nothing contained on our site constitutes investment, legal, tax or other advice, nor is it to be relied upon when making investment or other decisions. The information on our site is provided solely on the basis that you make your own investment decisions. You should obtain relevant and specific professional advice before making any decision to enter into an investment transaction.

4. Sales Restrictions
Each Fund is, or, when and if established, will be, both an unrecognised collective investment scheme for the purposes of the UK Financial Services and Markets Act 2000 (“FSMA”) and an alternative investment fund (“AIF”) for the purposes of the EU and UK Alternative Investment Fund Managers Directive (“AIFMD”). Our site is exempt from the restriction in section 238(1) of FSMA on the communication of an invitation or inducement to participate in a collective investment scheme, by virtue of Section 238(5) of FSMA and Chapter 4.12 of the FCA Conduct of Business Sourcebook. Accordingly, our site is directed only at persons who are categorised as either a professional client or an eligible counterparty (within the meaning of the FCA Rules) in respect of interests in the relevant Fund. The investments and investment services to which our site relates are only available to such persons and other persons should not act or rely on it. In particular, no investment or service to which our site may relate is intended for retail clients nor will be made available to retail clients. Investors in the Funds will not benefit from the rules and regulations made under FSMA for the protection of investors, nor from the Financial Services Compensation Scheme. Interests in the Funds are not dealt in or on a recognised or designated investment exchange for the purposes of FSMA, nor is there a market maker in such interests, and it may therefore be difficult for an investor to dispose of his interests otherwise than by way of redemption. An application for interests in any of the Funds should only be made having read fully the relevant prospectus. It is your responsibility to use such prospectus and by making an application you will be deemed to represent that you have read such prospectus and agree to be bound by its contents.

Information for investors in the European Union (“EU”), the European Economic Area (“EEA”) and the United Kingdom (“UK”)
In relation to the UK and each member state of the EU or EEA (each, a “Member State”) which has implement AIFMD, this document may only be distributed and the interests in the Funds may only be offered or placed in the UK and a Member State to the extent that: (1) the Fund is permitted to be marketed to professional investors in the UK or Member State in accordance with AIFMD (as implemented into the local law/regulation of the relevant Member State); or (2) such offering or placement is otherwise lawful in the UK or that Member State (including at the initiative of the potential investor).

Information for investors outside the EU, the EEA and the UK
United States of America: The information on our site is not directed at any United States person and our site is not intended to be used by any United States person. However, to the extent a United States person does wish to use our site, it may only be accessed by our existing and prospective clients who are qualified as to both suitability and net worth and with whom we or any of the Funds has a substantive pre-existing relationship.

To the extent the interests of any Fund are offered or sold in the United States or to a US person, none of such interests have been or will be registered under the US Securities Act of 1933, as amended (the “1933 Act”) or the securities laws of any US state. Such Fund interests may only be offered or sold directly or indirectly in the United States or to any US person in reliance on certain exemptions from registration under the 1933 Act and rules promulgated thereunder. In addition, no such Fund has been nor will be registered as an investment company under the US Investment Company Act of 1940, as amended.

Switzerland: The information provided herein does not constitute an offer of any Fund in Switzerland pursuant to the Swiss Financial Services Act (“FinSA”) and its implementing ordinance. This is solely an advertisement pursuant to FinSA and its implementing ordinance. The marketing and offer of any Fund in Switzerland will be exclusively made to, and directed at, qualified investors (the “Qualified Investors”), as defined in Article 10(3) and (3ter) of the Swiss Collective Investment Schemes Act (“CISA”) and its implementing ordinance, at the exclusion of qualified investors with an opting-out pursuant to Art. 5(1) FinSA and without any portfolio management or advisory relationship with a financial intermediary pursuant to Article 10(3ter) CISA (“Excluded Qualified Investors”). Accordingly, no Fund will be registered with the Swiss Financial Market Supervisory Authority (“FINMA”) and no representative or paying agent have been or will be appointed in Switzerland. This advertisement and/or any other marketing materials may be made available in Switzerland solely to Qualified Investors, at the exclusion of Excluded Qualified Investors. The legal documents may be obtained free of charge from investors@capulaglobal.com.

5. Your use of our site
These terms of use set out the terms on which you may make use of our site, whether as a guest or a registered user, and apply to every page on our site, whether or not such pages are individually disclaimed. Please read these terms of use carefully before you start to use our site. By using our site, you have indicated that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site. You must NOT use our site (or permit or procure others to use it) as follows: (A) for any unlawful, improper or illegal purpose or activity; (B) to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason; (C) in a manner intended to threaten, harass, or intimidate; (D) to violate our or any third party’s copyright, trademark, proprietary or other intellectual property rights; (E) to damage our name or reputation or that of our affiliated companies or any third parties; (F) to impersonate any of our employees or other person or use a false name while using our site or implying an association with us; (G) to penetrate our security measures or other entities’ systems (“hacking”); (H) to transmit unsolicited voluminous emails (for example, spamming) or to intercept, interfere with or redirect email intended for others using our site; (I) to generate excessive amounts of internet traffic, to interfere with our network or other’s use of our site or to engage in activities designed to or having the effect of degrading or denying service to users of our site or others; (J) to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into our site or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from our site is free from such items; (K) to post or transmit information that is defamatory, fraudulent or deceptive, including but not limited to scams such as “make-money-fast” schemes or “pyramid/chain” letters; and/or (L) to transmit confidential or proprietary information, except solely at your own risk. When using our site, you must comply with all applicable local, national and international laws and regulations, including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on our site in certain countries and we and our affiliated companies disclaim all responsibility if you download any information from our site in breach of any law or regulation of the country in which you reside.

6. User identification code and password
Certain information on our site is restricted and may be accessed only with a user identification code and password. Such information is confidential to us and is neither to be disclosed to any other person, nor copied or reproduced in any form, in whole or in part, without our prior written consent. If you are provided with a user identification code and password, you must not disclose them to any third party or allow any third party to use them to access any information on our site. You agree to notify us immediately if you suspect any unauthorised use of our site or of your user identification code or password.

7. Termination and suspension of access to our site
We reserve the right to deny you access to our site, or immediately to suspend or terminate your access to our site, or to disable any user identification code or password (whether chosen by you or allocated by us) at any time if your use of our site (in our sole discretion) in any manner breaches these terms of use.

8. Liability for use of our site
Access to our site is permitted on a temporary basis and we reserve the right to withdraw or amend the service we provide on our site without notice. We do not accept any liability if for any reason our site is unavailable at any time or for any period. The materials and information displayed on our site are provided without any guarantees, conditions or warranties as to accuracy or completeness and are not intended to amount to advice. We disclaim all liability and responsibility arising from any reliance placed on such materials and information by any visitor to our site, or by anyone who may be informed of any of its contents. Except as otherwise stated, the information on our site has been prepared, approved and issued by us and the information and opinions contained on our site have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, to the extent permitted by law, we, our affiliated companies and other third parties connected to us hereby expressly exclude all conditions, warranties, representations and other terms which might otherwise be implied by statute, common law or the law of equity and any liability for any direct, indirect or consequential loss or damage of any kind incurred by any user in connection with our site or in reliance on the information or opinions contained in it, or in connection with the use, inability to use, or results of the use of our site or any websites linked to it or materials posted on it. This does not affect our liability for any loss or damage which cannot be excluded or limited under applicable law. The internet is not a completely reliable transmission medium and neither we nor any of our affiliated companies accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from us or any of our affiliated companies. Any such transmission of information is entirely at your own risk. Where our site contains links to other websites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those websites or resources and neither we nor any of our affiliated companies make any representation as to the accuracy or completeness of such sites or resources and have not and will not review or update them. Neither we nor any of our affiliated companies accept any responsibility for websites and resources provided by third parties or for any loss or damage that may arise from your use of them. You undertake to indemnify and hold us harmless from and against all or any claims, actions, liabilities, demands, proceedings or judgements (“Proceedings”) brought or established against us and against all losses and all reasonable costs, charges and expenses (including legal fees) which we may suffer or incur (including, but not limited to, all such losses, costs, charges or expenses reasonably suffered or incurred in disputing or defending any Proceedings and/or in establishing its right to be indemnified and/or in seeking advice in relation to any Proceedings) and which in any such case arise in connection with or out of any breach or alleged breach by you of any of your obligations and/or undertakings under these terms. This does not exclude or restrict any duty or liability that we have to our customers under the regulatory system in the United Kingdom.

9. Intellectual property rights
We are the owner or the licensee of all intellectual property rights in our site, and in the materials published on it. Those works are protected by laws and treaties around the world. All such rights are reserved. You may use the materials on our site and reproduce them in hard copy for your own reference only. Such materials may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without our prior written consent. Nothing on our site should be construed as granting any licence or right in relation to any of our trademarks or those of our affiliated companies or any third party.

10. Law and variation
These terms of use are governed by and shall be construed in accordance with English law. English courts will have exclusive jurisdiction over any dispute arising from, or related to, use of our site and it is a condition of using our site that you waive any objection to proceedings in such courts on the grounds of venue or that proceedings have been brought in an inconvenient forum, although we retain the right to bring proceedings against you for breach of these terms of use in your country of residence or any other relevant country. We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you.

11. Website privacy notice
Our website privacy notice is available via our site, and is hereby incorporated into these terms of use. Our site may use cookies by default. A “cookie” is a small text file that a website stores on a user’s hard drive containing information about how that user uses the website. Cookies may be used in order to enhance user experience of our site and/or provide us with data that can help us to improve our site. By using our site you agree to the use of cookies for such purposes. You can refuse to accept cookies by modifying the settings in your browser. If you do refuse to accept cookies, you may not be able to use all of the features of our site.