The name “Winton” and the Winton “W” logo are registered trademarks of Winton Group Limited (together with its affiliates, hereafter referred to as “Winton”). Except as expressly permitted by this policy or as otherwise agreed by Winton in writing, no person shall have any right to use the name or trademarks (including the logo) of Winton under any circumstances, including, without limitation, in the name of any investment product. Winton may change this policy at any time.

This policy sets out the limited circumstances in which a third party may use the name of Winton Group Limited or any of its affiliates or refer to the name “Winton”, in the absence of an express agreement between Winton and such third party governing such use.

Policy scope

This policy applies in respect of:

• a third party which distributes one or more investment products managed or advised by Winton or one or more investment products that provide direct exposure to another investment product or entity that is managed or advised by Winton (in each case, the “Product”); and
• a third party which includes or references data relating to Winton or any investment product managed or advised by Winton (or data derived from such data) (in each case, “Data”) in materials or on websites targeting investors or potential investors in Products.

The use of Winton name

Where this policy applies, a third party may in marketing materials (including, without limitation, any brochures, fliers or presentations), offering memoranda, investor reports, websites and regulatory documentation relating to the Product or containing the Data (collectively, “Materials”) and in oral communications with investors and prospective investors in the Product or recipients of the Data:

• cite Winton’s name and accurately describe Winton’s role in respect of the relevant Product or Data; and
• accurately describe Winton’s business and the Winton investment program that is relevant to the Product or Data by using disclosure contained in Winton’s current SEC Form ADV, Part 2A (available at www.adviserinfo.sec.gov), provided that any Materials contain a disclaimer of Winton’s responsibility and liability for the contents of such materials in the following form:
  Neither Winton Group Limited nor any of its affiliates take responsibility for the contents of these materials and disclaim any and all liability for any losses or damages incurred by any party arising from reliance on these materials.