Our Commitment to Privacy

This policy applies to:

1. Neuberger Berman Europe Limited (company number 05463227) with registered office The Zig Zag Building, 70 Victoria Street, London SW1E 6SQ (“NBEL”), on behalf of itself, its representative offices, branches and subsidiaries (and their respective branches and representative offices) including:
2. Neuberger Berman AIFM S. à r. l. (company number B222747), with registered office 9 rue du Laboratoire, L-1911, Grand Duchy of Luxembourg;
3. Neuberger Berman Asset Management Ireland Limited (company number 629805), with registered office 2 Central Plaza, Level 2, Dame Street, Dublin, D02 T0X4, Ireland; and
4. Neuberger Berman (Switzerland) GmbH (company number CHE-314.552.483, with registered office Dreikönigstrasse 7, Second floor, Zürich 8002 – Switzerland,

(together “Neuberger Berman”, “we”, “us”, “our” or “the firm”).

We are committed to protecting and respecting the privacy of our customers, clients, users of our website, suppliers, individuals who contact us, and those other external parties whose personal data we may otherwise process in the course of our business (“you” and “your”).

This privacy policy ("Policy") sets out the basis on which we will collect, process and protect your personal data in order to provide our services to you, when you visit our website or interact with us. The terms of this Policy shall also apply to the handling of the personal data of any individual in the European Union (“EU”) or United Kingdom ("UK") by a member of the Neuberger Berman Group established outside of the European Economic Area (“EEA”), to the extent that such handling is subject to Data Protection Legislation.

In this Policy, “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679 ("GDPR"), the GDPR as it as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018, the Swiss Data Protection Act and its Ordinances (together the "Swiss DPA"); together with all other applicable legislation relating to privacy or data protection in the jurisdictions in which we operate and the terms “personal data”, “data subject”, “controller”, “processor” and “process” (and its derivatives) shall have the meanings given to them in the Data Protection Legislation.

Information We Collect

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may collect, record and use information about you and the services you receive from us in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Policy.

Your ‘information’ includes your personal data, which means information that can be used to identify you, including (but not limited to) the following types of personal information:

• your contact information, such as your home or work address and contact details (including your mobile telephone number);
• your date of birth, marital/civil partnership status, details of dependents and next of kin;
• your employment status and national insurance number;
• other information about you that you disclose to us;
• details of any complaints or concerns raised by you;
• information we collect from the way you do business with us, such as or when you use our telephone services or websites;
• information we collect when you write to us; or when you apply for our products or services; or any other time you contact us, including through social media; and
• information we obtain from third parties for a legitimate purpose, such as information that we obtain when verifying details supplied by you as part of your application. This information obtained from other third party organisations or people may include other Neuberger Berman Group companies, employers, credit reference agencies, employers, fraud prevention agencies or other similar organisations.

Some of the information that we collect about you may include special categories of personal data (such as information about your racial or ethnic origin, criminal or alleged criminal offences or your health and lifestyle) in connection with our obligations under applicable anti money laundering laws.¹

Any such special categories of personal data or sensitive information will be processed only as is necessary for this purpose.

If you fail to provide us with the personal data we request from you, or you object to us processing such information (see below for more information about your rights in relation to your information) the consequences are that we may be unable to provide our services to or for you.

Providing third party information to us

If any information which you provide to us relates to any third party, by providing us with such personal information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with the above provisions, or are otherwise permitted to give us this information. You further confirm that you will make such third parties aware of this Policy.

Purposes and Legal Bases for using your personal data

We will process your personal data only in accordance with the applicable Data Protection Legislation. Most commonly, we will use your personal data for the purposes and on the legal bases set out in the table below. Generally we do not rely on consent as a legal basis for processing your personal data. Where we have asked for your consent and you have given it, you have the right to withdraw it at any time by contacting us. You always have the right to unsubscribe from any direct marketing that you receive from us, by clicking the link that is included in each message or by contacting us. For more detail on your rights regarding your personal data, see below.

This table describes in more detail the various categories of personal data we collect (as set out above in "Information We Collect") and the lawful ground on which we rely for processing this personal data.

Category of personal data collected	Purpose for collection	Legal basis for processing
Your contact information, such as your home or work address and contact details (including your mobile telephone number).	to manage and administer any of the services provided by us to you; for day to day operational and business purposes; investor relationship management; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; to carry out statistical analysis and market research; to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes; certain marketing purposes, unless you have opted out of this; and for other legitimate business purposes as may be determined by us from time to time.	Where we need to perform the contract we are about to enter into or have entered into with you. Where we need to comply with a legal or regulatory obligation. Where it is necessary for our legitimate interests (or those of a third party): to prevent fraud; to protect our business interests; or to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
Your employment status and national insurance number.	to consider you for potential employment or engagement by us; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes; to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings); and for other legitimate business purposes as may be determined by us from time to time.	Where we need to perform the contract we are about to enter into or have entered into with you. Where we need to comply with a legal or regulatory obligation. Where we need to comply with a legal or regulatory obligation. Where it is necessary for our legitimate interests (or those of a third party): to prevent fraud; or to protect our business interests.
Your date of birth, marital/civil partnership status, details of dependents and next of kin.	for day to day operational and business purposes; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; to carry out statistical analysis and market research; to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes; for the purposes of credit risk reduction; and for other legitimate business purposes as may be determined by us from time to time.	Where we need to perform the contract we are about to enter into or have entered into with you. Where we need to comply with a legal or regulatory obligation. Where it is necessary for our legitimate interests (or those of a third party): to prevent fraud; or to protect our business interests.
Other information about you that you disclose to us.	to manage and administer any of the services provided by us to you; to consider you for potential employment or engagement by us; for day to day operational and business purposes; investor relationship management; to track your visits to our website, in order to provide you with a better service and to understand how you use it; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; to carry out statistical analysis and market research; to comply with legal and regulatory obligations applicable to you and us including anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including Office of Foreign Assets Control (OFAC) and Politically Exposed Persons (PEP) screening for these purposes and to comply with United Nations, European Union and other applicable sanctions regimes; for the purposes of credit risk reduction; to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings); certain marketing purposes, unless you have opted out of this; and for other legitimate business purposes as may be determined by us from time to time.	Where we need to perform the contract we are about to enter into or have entered into with you. Where we need to comply with a legal or regulatory obligation. Where it is necessary for our legitimate interests (or those of a third party): to prevent fraud; to protect our business interests; to evaluate, develop or improve our products and services; or to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
Details of any complaints or concerns raised by you.	for day to day operational and business purposes; investor relationship management; for any other specific purposes where you have given specific consent to that processing for those purposes; to protect the rights, property, or safety of us, our clients, or others (which may include establishing, exercising or defending legal rights or for the purpose of legal proceedings); or for other legitimate business purposes as may be determined by us from time to time.	Where we need to comply with a legal or regulatory obligation. Where it is necessary for our legitimate interests: to protect our business interests; to ensure that complaints are investigated; or to evaluate, develop or improve our products and services.
Information we collect from the way you do business with us, such as or when you use our telephone services or websites.	to manage and administer any of the services provided by us to you; for day to day operational and business purposes; to track your visits to our website, in order to provide you with a better service and to understand how you use it; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; to carry out statistical analysis and market research; certain marketing purposes, unless you have opted out of this; and for other legitimate business purposes as may be determined by us from time to time.	Where it is necessary for our legitimate interests to evaluate, develop or improve our products and services.
Information we collect when you write to us; or when you apply for our products or services; or any other time you contact us, including through social media.	to manage and administer any of the services provided by us to you; to consider you for potential employment or engagement by us; for day to day operational and business purposes; investor relationship management; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; to carry out statistical analysis and market research; certain marketing purposes, unless you have opted out of this; and for other legitimate business purposes as may be determined by us from time to time.	Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party): to protect our business interests; to evaluate, develop or improve our products and services; or to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.
Information we obtain from third parties for a legitimate purpose, such as information that we obtain when verifying details supplied by you as part of your application. This information obtained from other third party organisations or people may include other Neuberger Berman Group companies, employers, credit reference agencies, employers, fraud prevention agencies or other similar organisations.	to consider you for potential employment or engagement by us; for day to day operational and business purposes; for record keeping, security and/or training purposes; for any other specific purposes where you have given specific consent to that processing for those purposes; for the purposes of credit risk reduction; and for other legitimate business purposes as may be determined by us from time to time.	Where we need to perform the contract we are about to enter into or have entered into with you. Where we need to comply with a legal or regulatory obligation. Where it is necessary for our legitimate interests (or those of a third party): to prevent fraud; to protect our business interests; to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.

Automated processing

When we use your information, we may use automated processes. In particular, in order to comply with our obligations under AML legislation, we are required to verify the identity of all clients and other information (including but not limited to details of any nationality, citizenship or rights of residence you hold) to satisfy our regulatory obligations. We may do this using an electronic verification system that we consider suitable or by asking you for documentary evidence. We do not carry out any automated-decision making when processing your personal data.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk:

• we may refuse to provide the services you have requested, or we may stop providing existing services to you; and
• a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

If you want to know more about your rights in relation to automated processing, please see below or contact us using the details below.

Recipients of your personal data

We may disclose your information to other recipients or categories of recipients, including associates or affiliates within the Neuberger Berman Group, or to our or their agents, counterparties and support service or data providers, wherever located. In certain circumstances, we may transfer your information abroad. See “International Transfers” below for more information.

We will ensure that if we share your information with third parties, any such disclosure is at all times in compliance with Data Protection Legislation.

The following recipients, or categories of recipients, may receive your personal data and process it for the purposes outlined above:

• our third party suppliers, service providers and other agents or advisers, including anyone providing a service to us or our funds or acting as our agent (which may include distributors, depositaries, investment managers, administrators or companies within their groups of companies);
• our advisers (including, but not limited to, accountants, lawyers, auditors or other professional advisers);
• any revenue service or tax authority including to HMRC, the Revenue Commissioners (in Ireland) and Luxembourg tax authorities, if obliged to do so under any applicable legal or regulatory requirements;
• credit reference agencies in order to perform credit and identity checks. To do this, we will supply your personal information to the credit reference agencies and they will give us information about you and they may record that a search has been made and the results of such search (including the information that we provide). We may continue to exchange information about you with credit reference agencies while you have a relationship with us. The credit reference agencies may in turn share your personal information with other organisations;
• fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. We and fraud prevention agencies may also enable law enforcement agencies to access and use your information to detect, investigate and prevent crime. If fraud is detected, you could be refused certain services or finance;
• other UK and overseas regulators (such as, but not limited to, the Central Bank of Ireland, the Commission de Surveillance du Secteur Financier in Luxembourg and the Swiss Financial Market Supervisory Authority) and authorities in connection with their duties (such as crime prevention), or other organisations who are required by law to receive such data, or who need to receive it for the purposes of crime prevention, fraud reduction, to comply with any legal obligation, or to protect people’s rights, property, or safety;
• any other person or organisation after a restructure, sale or acquisition of any Neuberger Berman Group company, as long as that person uses your information for the same purposes as it was originally given to us or used by us (or both);
• anyone to whom we may transfer our rights and/or obligations under our terms with you; and
• your advisers (including, but not limited to, accountants, lawyers or other professional advisers) where authorised by you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third party processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In any case where we share personal data with a third party controller (including, as appropriate, other members of the Neuberger Berman Group), the use by that third party of the personal data will be subject to the third party’s own privacy and data protection policies.

International Transfers

Information about you in our possession may be transferred to other countries (which may include countries outside the United Kingdom, EEA, Switzerland or the country from which it originates, such as jurisdictions in which and through which transactions are effected; jurisdictions where your investments are held; jurisdictions from which you regularly receive or transmit information about your investments; or jurisdictions where our third parties conduct their activities). The above recipients of your personal data may also be based either within or outside the United Kingdom, EEA, Switzerland or the country from which it originates (based primarily in North America or Asia).

You understand and accept that such other countries may have differing (and potentially less stringent) laws relating to the protection of your data and the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

Where your personal data is transferred to outside of the United Kingdom, EEA, Switzerland or the country from which it originates to any country not considered to have an adequate level of data protection under the applicable Data Protection Legislation, we or our permitted third parties will impose contractual obligations on the recipients of that data to protect your information to the standard required in under applicable Data Protection Legislation, unless we can rely on a legal derogation.². We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where the transfer is to a country deemed to provide adequate protection of your information by the relevant supervisory authority; or you have requested the transfer. There are adequacy decisions in place for transfers to the UK, Canada, Japan, and Switzerland and other countries and therefore, collectively, these decisions will govern transfers to the relevant group companies in those countries

If we transfer your information outside the United Kingdom, EEA, Switzerland or country from which it originates in other circumstances (for example because we have to provide such information by law), we will put in place appropriate safeguards to ensure that your information remains adequately protected. This, in particular, relates to the USA and Singapore where no adequacy has been adopted with the European Commission and, as the case may be, the Federal Data Protection and Information Commissioner ("FDPIC") or the Swiss Federal Council.

You can request further information on our data transfers including (i) whether or not an adequacy decision exists for the relevant jurisdictions and (ii) for a copy of such safeguards by contacting us in writing using the contact details below.

Retention of your Personal Data

We are obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes. We will only keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject or if we have a legitimate interest, pursuant to the Neuberger Berman Group Retention Policy. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required.

Your rights in relation to your personal data

Depending on the applicable Data Protection Legislation, you have the following rights, at any time and under certain circumstances, in respect of your personal data which we process:

• to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated processing, including profiling, and the logic, significance and envisaged consequences);
• to request access to or a copy of any personal data we hold about you;
• to request the rectification of your personal data, if you consider that it is inaccurate;
• to request the erasure of your personal data, if you consider that we do not have the right to hold it;
• to object to your personal data being processed for a particular purpose or to request that we stop using your information;
• as a general rule, to request not to be subject to a decision based on automated processing (including profiling) which produces legal or similarly significant effects and to have safeguards put in place if any such processing of your personal data occurs;
• to ask us to transfer a copy of your personal data to you or to another service provider or third party where technically feasible;
• to withdraw any consent that you have previously given to us for our use of your personal data; ;
• to ask us to stop or start sending you marketing messages at any time; and
• in some jurisdictions, the right not to be discriminated against for exercising the above rights.

You can exercise any of these rights by contacting us in writing using the contact details below and we will respond within one month unless taking into account the complexity and number of requests an extension is required. Please note that we may ask you to verify your identity and ask you for more details about your request. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, as long as there is no overriding legitimate ground or other legal reason for us to continue to hold or use that information. There may be some information which we are not legally able to disclose to you. Also, in exceptional circumstances, it may not be practicable for us to provide you with copies of all the documents that you request. If this is the case, we will explain our reasoning to you. Please note that if you exercise some or all of the above rights, the performance of our services may be impaired or no longer possible.

If you have any concerns about our use of your information, you also have the right to complain to our regulators about the firm's information rights procedures. Our UK regulator is the UK Information Commissioner's Office (the "ICO"). Our Swiss regulator is the FDPIC. Our lead EU regulator is the Irish Data Protection Commission. The contact details of the firm's regulators are set out below. Where we have branches in other locations, we may also have local regulators there, details of which are available on request:

UK	Information Commissioner's Office	https://ico.org.uk/concerns/
Ireland	Data Protection Commission	https://www.dataprotection.ie/en/contact/how-contact-us
Luxembourg	Commission nationale pour la protection des données (« CNPD »)	https://cnpd.public.lu/fr.html
Switzerland	Federal Data Protection and Information Commissioner	https://www.edoeb.admin.ch/edoeb/en/home.html

The Internet

Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by browsing the website and communicating electronically with us, you acknowledge and understand that your personal data may be processed in this way.

We will do our best to protect your personal data, but we cannot guarantee the security of any data transmitted to our website; and to the extent permitted by Data Protection Legislation, any transmission is at your own risk.

The website may, from time to time, contain links to other websites. These are not covered by this Policy and are outside of our control. If you access other websites using the links provided we do not accept any responsibility or liability for these other websites. Please check the privacy policies of those websites before you submit any personal data to them.

Cookies

Some of your personal data that we process may consist of cookies, which are small text files that often include a unique identifier that is sent by a web server to your internet enabled device when you visit a website. For details of how we deal with cookies, please see our Cookie Policy.

Marketing Communications

We and other members of the Neuberger Berman Group may use your information from time to time to inform you by letter, telephone, text (or similar) messages, email and other electronic methods, about similar products and services (including those of third parties) which may be of interest to you in accordance with the requirements under Data Protection Legislation.

You may, at any time, request that we and/or other members of the Neuberger Berman Group do not send such information to you by one, some or all channels, by contacting us in the way described below.

Contacting Us

Any queries or complaints regarding our use of personal data or the exercise of your rights should be addressed in the first instance to your usual Neuberger Berman relationship manager or NBEuropeDataProtection@nb.com or in writing to the following address: NB Data Protection Adviser c/o Neuberger Berman Europe Limited, The Zig Zag Building, 70 Victoria Street, London, SW1E 6SQ.

We may make changes to this Policy and how we use your information in the future. If we do this, we’ll post an updated version of this Policy on our website.

Last updated: 27 September 2023