Content Policy

1. About This Policy

Although efforts have been made to ensure material which infringes the law will not be present on our website, the risk cannot be entirely eliminated. This document aims to provide clarity about our policy in relation to content which infringes the law and/or our Website Terms of Use by detailing:

1. • our content standards; and
   • the process that should be followed to make a complaint.

Should you have any questions about this policy, please email David Clark, Chief Compliance and Business Ethics Officer at

2. Interactive Services

We may from time to time provide interactive services on our site, including, without limitation on chat rooms and bulletin boards (“interactive services”). Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical). We will do our best to assess any possible risks for users from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not. The use of any of our interactive services by a minor is subject to the consent of their parent or guardian.

3. Content Standards

These content standards apply to any and all material which you contribute to our site (“contributions”), and to any interactive services associated with it.

You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any contribution as well as to its whole.

Contributions must:

1. • Be accurate (where they state facts);
   • Be genuinely held (where they state opinions); and
   • Comply with applicable law in the UK and in any country from which they are posted.

Contributions must not:

1. • Contain any advertising material;
   • Contain links to other website;
   • Contain any personally identifiable information relating to any individual other than you;
   • Contain any material which is defamatory of any person;
   • Contain any material which is obscene, offensive, hateful or inflammatory;
   • Promote sexually explicit material;
   • Promote violence;
   • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age;
   • Infringe any copyright, database right, trade mark or any other right of any other person;
   • Be likely to deceive any person;
   • Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence;
   • Promote any illegal activity;
   • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety;
   • Be likely to harass, upset, embarrass, alarm or annoy any other person;

•Be used to impersonate any person, or to misrepresent your identity or affiliation with any person;

• Give the impression that they emanate from us, if this is not the case; and
• Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

1. Uploading Material to Our Site

Whenever you make use of a feature that allows you to upload material to our site, or to make contact with other users of our site, you must comply with the content standards set out above. You warrant that any such contribution does comply with those standards, and you indemnify us for any breach of that warranty.

Any material you upload to our site will be considered non-confidential and non-proprietary, and we have the right to use, copy, distribute and disclose to third parties any such material for any purpose. We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy.

We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of our site. We have the right to remove any material or posting you make on our site at any time in our discretion.

4. Takedown Policy and Procedure

As a responsible website publisher, we support the protection of your reputation and the protection of your intellectual property rights. We do not edit, pre-vet or review any third party material displayed on this website. We operate a notice and takedown procedure regarding such material. Accordingly, we have established the procedures below to report any items that you believe are in breach of these terms, including anything which defames you or constitutes copyright or trade mark infringement.

5. Notice and Procedure for Making Claims

If you believe that any content on this website breaches these terms, including anything which defames you or constitutes copyright or trademark infringement, please email David Clark, Chief Compliance and Business Ethics Officer at

Your written notification must include the following:

1. • Your contact information including your name, postal address, telephone number and email;
   • Identification of the content in question and its location on this website – where possible, please cut and paste (or provide screenshots) in your written notification;
   • A good faith statement, that the information provided by you in the notification is accurate and true;
   • An explanation as to why the content breaches these terms or other reason as to why it should be removed;
   • If the content is allegedly defamatory, a statement as to why the content is untrue and the extent that it is damaging to you; and
   • If the content infringes an intellectual property right, a physical or electronic signature of a person authorised to act on behalf of the owner of an exclusive right that is allegedly infringed and identification of the rights claimed to have been infringed (including e.g. the trademark registration number).

Upon receipt of a notification as set out above, where we deem it satisfactory and appropriate, we will take down or disable access to the material that is claimed to be infringing. You may be asked to provide further information and/or supporting statements in relation to the content or your concern.

Please be aware that providing false or misleading information in the notification of claim may result in civil and/or criminal liability.