Website Terms of Use & Cookie Policy

Polunin Capital Partners Limited Website Terms of Use

This website (“website” or “site”) is issued by Polunin Capital Partners Limited (“Polunin”) which is authorised and regulated by the UK Financial Conduct Authority (FRN 197479). Polunin is incorporated in England and Wales under registered number 4132122 with registered office 10  Cavalry Square, London, SW3 4RB.

Professional Investors and Eligible Counterparties Only

The information contained within these pages must not be relied upon by retail or private investors. This material is directed exclusively at persons who are experienced investors in unregulated collective investment schemes, who are “professional” or “eligible counterparty” clients as defined by the FCA. The information and documents herein are not intended for general distribution in the United States or for the account of U.S. persons (as defined in Regulation D under the United States Securities Act of 1933, as amended (the “Securities Act”)) except to persons who are “Qualified Purchasers” (as defined in the United States Investment Company Act of 1940, as amended (the “Company Act”) and “Accredited Investors” (as defined in Rule 501(a) under the Securities Act).

By accessing any page of this site, you agree to be bound by the Terms below. If you do not agree to the Terms, please exit this site. This page is designed to filter out unsuitable categories of investors from accessing the site and as such Polunin cannot be responsible for any explicit or implicit misrepresentations you may make in gaining unauthorsied access to the site.

No Offer or Solicitation

This site is not intended and must not be construed as an offer or solicitation to purchase, or an offer to sell, shares of any fund or another investment product in any jurisdiction. It should not be used for the purpose of an offer or solicitation in any jurisdiction or in any circumstances in which such offer or solicitation is unlawful or not authorised. Investors must inform themselves about the laws which are in force in their country or jurisdiction. You should ensure that you are legally allowed to access this website and its contents in the country from which you connect. Prospective investors should rely only on the prospectus or offering memorandum of a fund in making a decision to invest; In addition any investment or transaction will be subject to applicable legal and regulatory restrictions, including the eligibility criteria.

Data Protection and fair and Lawful Processing

Personal data is subject to certain legal safeguards EU General Data Protection Regulation 2016.679 (“GDPR”), and the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018 (collectively “Data Protection Legislation”). Data Protection Legislation is not intended to prohibit the processing of the personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. Standard fair processing information is provided within the GDPR Privacy Notice on the this website.


The information and opinions on this website have been obtained from sources believed to be reliable, however, accuracy cannot be guaranteed. No liability is accepted in relation to the accuracy or completeness of the information or opinions contained on this site; Save to the extent required by applicable law or regulations, no guarantee, warranty or representation (express or implied) is given by Polunin as to this website’s accuracy, suitability, reliability, completeness, performance, fitness, freedom from viruses or timeliness of the content of services contained in the site. Polunin, its members, officers and employees do not accept any liability or responsibility in respect of the information, or any views expressed herein.

Polunin accepts no liability for any loss or damage of any nature whatsoever, whether directly arising from accessing, using, consulting or navigating this site or its contents, or from links to other websites.

Users hereby acknowledge and accept that due to the nature of the internet it is impossible to guarantee the security, availability, and integrity of data downloaded from this site. Users undertake to take all appropriate measures to protect their own data, information system and/ or software from any intrusion or contamination by viruses and other forms of cyber-attacks. 

If you have accessed this site using a link from another site, Polunin does not accept any liability or responsibility for the accuracy of information contained within the sites of other providers who have links to any pages of this site or to whom this site is linked. The creation of links to this site is prohibited without our prior express permission.

All the information and opinions on this website are provided by Polunin for general information purposes only. We make every effort to ensure that the information provided on this website is accurate and complete at the time of publishing. Any view or opinion expressed on this website is subject to amendment without notice. We cannot guarantee that the information on this website has not been altered as a result of technical malfunctions. We accept no liability for any loss or damage of any nature whatsoever, whether direct arising from accessing, using, consulting or navigating this website, or from links to other websites.

Notice to persons in the United States

The information contained in this site about Polunin is not directed to any person in the United States of America. The provision of the information on this site does not constitute an offer of securities to any person in the United States or to any U.S. Person. Shares in Polunin’s funds have not been, and will not be, registered under the US Securities Act of 1933, as amended (the “1933 Act”), or qualified under any applicable state statues, and shares may not be offered, sold, or transferred in the United States of America (including its territories and possessions) or to or for the benefit of, directly or indirectly, any US Person, expect pursuant to an exemption. Polunin’s funds are not, and will not be, registered under the US Investment Company Act of 1940, as amended (the “1940 Act”), and investors will not be entitled to the benefit of such registration. Polunin has funds available to a limited number or category of US Persons under private placement.


Polunin owns all copyright and other intellectual property rights in this website and all of its content. It is forbidden to reproduce (in full or in part), publish, amend, transfer, create a link to or use this site for any public or commercial purposes without the prior consent of Polunin.

No Investment Advice

This website is not intended to influence you in making any investment decisions and should not be considered as advice or a recommendation to invest. No information contained within this site should be deemed to constitute the provision of financial, investment, taxation or other professional advice in any way The content may not be suitable for all investors, and investors must make their own investment decisions using their own independent advisers.  


This website uses cookies to analyse traffic, and to ensure the proper function and security of the site. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers. To comply with the new e-Privacy directive, we need to ask for your consent to set the cookies. This website does not capture, collect or store any personal data of any kind. By accepting these terms and conditions you will be consenting to the storage of cookies on your computer. 

Governing Law and Jurisdiction

These terms and conditions shall be governed by and interpreted in accordance with English law and the courts of England shall have exclusive jurisdiction to hear all disputes arising in connection with them or your use of this website.

Changes to website terms

Please read these terms and conditions carefully; they may be changed, amended or modified without notice to you. Your continued use of the site following any changes will be deemed to indicate that you accept such changes. If you do not agree to the modified terms and conditions, you should cease use of the website and should exit the site now.

Acceptance of terms

Click the box to confirm your acceptance of these terms and conditions. 

By clicking accept:

I confirm that I am a professional investor or eligible counterparty investor as defined in these terms. I acknowledge and agree to the terms and conditions above. I undertake to access the information contained in this website for my personal use and not for commercial use.

I confirm that I am aware of the laws in my own jurisdiction relating to the provision and sale of investment services and I warrant and represent that I will not pass on or utilise the information contained in this website in a manner that could constitute a breach of such laws by Polunin or any other person.